HomeMy WebLinkAbout97-05914
\
"
.~
~
VJ
'"
"
~
~
~
t
~
~
.......
.
.s
cJ
~
'"
00-
\c)
I ,
t--
0-
\
I
I
~
i,\
T",
"
I'I-..r
. .
ell
r.J
nl ~'r'1~'
, t' .'
.. 'C")
..' ,1-
'I~ 1
,;i
I'IJ'I,.'
~) ,,~. .
\'t~:' _,' '\
;,.-.....1
ti
If
, J ,'" -
i';
\'.' "
10 -D)tIJ17 dvl. tI~ 1~.Btr ?f; c/~ ~/<:'
I0;;l11'17 'n'14t Mag", i ?'4tY
/0 'dll.ti7 ~~ -?1t1~"/ ;t ail ~~
(: C)
t--:..= (",' r~~
till
I ~:
f;~ I
t ~':.
.. 'i'
r . ~ ~
~~ & ~
"'J ....J,..
ff0-':&'
~ "h0
~ ~~
__ "1l .
~~
,
- .
\,.' ..,
'..' '.
I
,
L:
~.~, r--
c' (:j
~
RENEE L, STRAYER,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 9706914 CIVIL TERM
: IN CUSTODY
v,
JEFFREY ALLEN STRAYER,
Defendant
COURT ORDER
AND NOW, this ""'~of .b",v~
\G'i'i I
, 11l8'7, upon consideration of the
within Stipulation It is ordered and decreed as fonows:
1. Damon Ray Strayer, date of birth February 9, 1996, is the natural chlJd of Jef1'tey
Allen Btrayer, hereinafter referred to as "Father", ond Renee L. Strayer, hereinafter referred to as
'Mother" .
2. LegaJ custody pursuant to 23 Pa.C.B.A I 5301, et seq., will be ahared by the parties,
3. The parties shall share phyoica1 custody on on alternating weekly basis Sl:COrding to the
following schedule:
a. On alternate weeks, beginning with Sunday, November 9, 1997 until Sunday,
November 16, 1997, the Mother shall have partial custody of the minor child. Beginning with
Sunday, November 16, 1997 until Sunday, November 23, 1997, the Father shall have partial
custody of the minor child. Both parties shall alternate on a week to week basis for the
continuation of this Order.
b. On altel'llllte holiduys, b<,girming with Thanksgiving, 1997. The holldaya are:
New Years Day, Memorial Day, Fourth of July, Labor Day, and Thanksgiving Day. Such
custody shall begin at 9:00a.m. ond end at 7:00p.m.
e. The Christmas Eve and Christmas Day holidays shall be as mutually agreed
upon by the parties. In the event that the parties cannot resch an amicable agreement as to
these holidays, the followin" schedule shall spply: in even numbered years, the Father shall
have partial phyoical custody from 12:00 noon on Christmas Eve until 12:00 noon on ChrIstmaa
Day; in odd numbered years, the Father shall have partial phyolcal custody from 12:00 noon on
Christmas Day until 12:00 noon on December 26th. This provision supersedes aU others.
d, The Father shall have the right of custody on every Father's Day from
9:00a.m. until 6:00p.m. with the Mother luwing that same right every Mother'a Day &om
9:00a.m. until 6:00p.m. This provision supersedes aU others.
e. The child's birthday shall be handled as folloWll: ;n odd numbered years,
Mother shall have the child from 8:00a.m. until 12:00 noon and Father shall have the chlJd
from 12:00 noon until 4:00p.m.; in even numbered years, the Father shall have the child &om
8:00a.m. until 12:00 noon ond Mother shall have the child from 12:00 noon until 4:00p.m.
Thesa perloda wID altemate bal:k amI forth from ye8l' to ye8l'. Thl.I prov\alon lupenedel aJ1
othen.
f. If either Mother or Father wish to take more than the required week of
vialtation during the school summer vecation, then that party shaJI give at least a thirty (80)
Day written notification to the other party,
4. Medical Care/I'realment. Each party shaJI inform the other party of any medicaJ
emergenciea occurrltlg while the child ill in that parents r.are.
O. Relocation. Each party shaJllmmedlately Inform the other party of hla or her new
address and telephone number in the event of pending relocation. temporary or permanent,
6. Seat Belts and Child Restraint Seats. Both parties shaJI utlll.e child restraint seats and
seat belts when transporting the child by automobile.
7. TeleDhone contact. The non-custodia1 parent shaJI have liberal rights of telephone
contact with the child while the child ill in the other party's physical custody.
8. 'I'ranBoortation. The non-custodia1 parent shaJI provide transportation unIeSll otherwise
agreed upon by the parties. Thl.I means that the party commencing hleIher period of partlaJ CUlItody
shaJI provide the transportation.
9. Cumberland County shall retain continuous, exclusive jurisdiction over thla custody
matter as long as at least one party or the child remains a resident of Cumberland County, or unless
otherwise agreed upon by the parties.
10. The parties agree to cooperate in deciding which IIChoo\ the child ill to attend when he
reaches school age,
By the Court,
.//
/
J,
I
.
F Lr:D.O;-f-~C::
,,- .,,' r ,..".,. "T/c'{
u'. I' .' "':.."..) \1\
l)f\.,":-l ~i\111:!)9
Cl/,',!..:;' I .,.' ;"(:'''';I,:'iY
~jl.j\l; ,./,'i~J;. \.\
:1'
RENEE L. STRAYER,
P1alntilT,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
,
,
: NO. 97-0914 CML TERM
: IN CUSTODY
JEFFREY ALLEN STRAYER,
Defendant
CUSTODY STIPULATION AND AGREEMENT
AND NOW, this
day of
, 1997, it is hereby atipulated and agreed
between the parties as follows:
1. Damon Ray Strayer, date of birth February 9, 1996, is the natural child of Jeffrey
Allen Strayer, hereinafter referred to as 'Father', and Renee L. Strayer, hereinafter referred to as
'Mother'.
2. Legal custody pursuant to 23 PaC.SA I 5301, et seq., will be shared by the parties.
3. The parties shall share physical custody on an alternating weekly basis according to the
following schedule:
a On alternate weeks, beginning with Sunday, November 9, 1997 until Sunday,
November 16, 1997, the Mother shall have partial custody of the minor child. Beginning with
Sunday, November 16, 1997 until Sunday, November 23, 1997, the Father shall have partial
custody of the minor child. Both parties shall alternate on a week to week basis for the
continuation of this Order.
b. On alternate holidays, beginning with Thanksgiving, 1997. The hollduys are:
New Years Day, Memorial Day, Fourth of July, Labor Day, and Thanksgiving Day. Such
custody shalJ begin at 9:00a.m. and end at 7:00p.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 following schedule shall apply: in even numbered years, the Father shall
have partial physical custody from 12:00 noon on Christmas Eve until 12:00 noon on Christmas
Dsy; in odd numbered years, the 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. The Father shall have the right of custody on every Fsther's Day from
9:00am. until 6:00p.m. with the Mother having that same right every Mother's Day from
9:00am. until 6:00p.m. This provislor, supersedes all others.
e. The child's birthday shall be handled as foilows: in odd numbered years,
Mother shall have the child from B:OOa.m. until 12:00 noon and Father shall have the child
from 12:00 noon until 4:00p.m.; in even numbered years, the Father shall have the child from
8:00a.m. untll12:00 noon and Mother shall have the child from 12:00 noon until 4:00p.m.
'These periods wl11 alternate back and forth from year to year. Thla provlalon lupersedes all
others.
f, If either Mother or Father wish to take more than the required week of
visitation during the echool summer vacation, then that party shall give at least a thirty (30)
Day written notificallon to the other party.
4. Medieal Caretrreatment. Eaeh party shalllnform the other party of any medical
emergencies oreurrlng while the ehild is In that parents eare.
6. Relocation, Eaeh party shalllmmediately inform the other party of hla or her new
address and telephone number In the event of pending relocation, temporary or permanent.
6. Sest Belts and Child Restraint Seats. Both parties shall utilize ehild restraint seals and
seat belts when transporting the ehild by automobile.
7. Telephone eontaet. The non-custodia1 parent shall have liberal righta of telephone
eontaet with the ehild while the ehild is In the other party's physical eustody.
8. Transoortation. The non-custodia1 parent shall provide transportation unless otherwise
agreed upon by the partie.. This means that the party eommenelng his,lher period -:If partial euatody
shall provide the transportation.
9. Cumberland County shall retain eontlnuous, exelusive jurisdietlon over thla euatody
matter as long as at least one party or the ehild remains a resident of Cumberland County, or unless
otherwise agreed upon by the parties.
10. The parties agree to eooperate In deciding whieh echool the ehild is to attend when he
reaches echool age.
11. Both Mother and Father agree that they are voluntarUy entering Into this Stipulation
with fuU knowledge In asking the Court to enter a Custody Order reflecting the terms of thla
Stipulation.
A~.
Date
~
rt.U-.j '-/) 511(t' (-.)
nee L. Strayer
,
/~ / /997
,
,-
'--f",{;(J !lJJ! /Vy/
Date
'-~
_ l...
+~
';3 ~
~ 't
~ ..:i
;.3'::i
.\
i
.,.
...
"
,
-
~. :
eJ
..;1
'~J
II"
. -
1;::
l~~: '
(',.
t:: :"
, ,
L...,'
:..-.
;.-
,
,.
v
'-
,-
~,
~.)
:~ Lf r,; 'C :r,~~'>,
c.:';,. :r""':itJ;Y
99 AUG 16 AllID::14
CUMGE/1Vl';u WUN'lY
PENNS''f1..VANIA
f'/t.~~ dvl. t'~ /H4-:..L.". -t 4 '+
(' I~ .9~ 71t'lk /H.~ 71 :fI ~ ~
(./~ .ti1 11~ IM:tJ/ -t 4 ~"
"
I
II
,
IIN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
RENEE L. STRAYER, n/k/a
RENEE L. WISE,
Plaintiff
No, 97-5914
v.
CIVIL ACTION
JEFFREY ALLEN STRAYER,
Defendant
CUSTODY
AND NOW, this 4'" day of August, 1999, comes the Plalndff, RENEE L. WISE, by
and through her attorney, Daniel F. Wolfson, Esquire, and the law firm of Wolfson &
sodates, P .c., and flies the within Petition of which the following Is a statement:
I. The Plaintiff, RENEE L. WISE, Is an adult Individual currendy residing 2848
Oakland Road, Dover, York County, Pennsylvania 17315.
2. The Defendant, JEFFREY ALLEN STRAYER, Is an adult Individual currendy
residing at P.O. Box 251, 225 Red Tank Road, Boiling Springs, Pennsylvania 17007,
3. The Plalndff and Defendant were married on the II'" day of April, 1992,
and subsequendy divorced on March I I, 1998,
4. The parties are the nawral parents of one minor child, Damon Ray Strayer,
born February 9, 1996.
5. Plaintiff, RENEE L. WISE, seeks a modi fica don In the current custody order
dated January 2, 1998.
The chlid was not born out-of-wedlock.
The parties currendy share physical custody of the child.
The mother of the child Is Plalndff, currently residing at 2848 Oakland Road,
Dover, York County, Pennsylvania 17315.
She Is married.
The father of the child Is Defendant, currently residing P.O. Box 251, 225 Red
ank Road, Boiling Springs, Pennsylvania.
He Is not married,
5, The relationship of Plaintiff to the child Is that of mother. The Plalntlff
currently resides with the following persons:
~
Relatlonshlo
Scott Wise
Husband
6. The relationship of Defendant to the child Is that of father. The Defendant
currently resides with the following persons:
~
Relatlonshlo
Charity Giles
Mother
7. The parties participated as a party to the action docketed at number 97.
5914.
8, Pursuant to the above docket number, an Order of Court was entered
pursuant to the agreement of the parties. (Said Order Is attached hereto as Exhibit "A"
and Incorporated herein by reference.)
2
!
t
r
I
I
9. That the Plalndff Is currendy seeking a modlflcadon of the exlsdng order to
Include the following terms:
a. The Plalntlff desires malorlty physical custody of the child with
Father having partial physical custody of the child.
b. Vlsltadon for the father would Indude: altemadng bl-weekly vlsltadonj
alternating holldaysj Christmas vlsltadon, Mother's DaYj Father's Day.
c. The child Is approaching school age,
10. The best IntereS[ and permanent welfare of the child will be served by
grandng the relief requested because:
a. the Plalndff Is more stable, and more capable of providing the proper
parental care, and can better provide for the physical and emodonal
needs of the child and the necessary condnulty.
II . Each parent whose parental rights to the child have not been terminated and
the person who has physical custody of the child have been named as parties to this acdon.
WHEREFORE, the Plalndff requests the Court to modify the current order of court
to the following:
Respectfully submitted,
~.j?df~-C---
Daniel F. Wolfson, quire
1.0. No, 2061 7
Attorney for Plalndff
WOLFSON & ASSOCIATES, P.C.
267 East Market Street
York, PA 17403-2000
Telephone No. (717) 846-1252
3
. .
RENEE 1. STRAYER,
Plaintill',
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 9H914 CIVIL TERM
: IN CUSTODY
v.
JEFFREY ALLEN STRAYER,
Defendant '
COURT ORDER
/'i'lt
, 1I8'r. upon conaIdaration of the
-,
AND NOW, this .J '........ day 01\.... j'-~1
withln Stipulation it is ordered and decreed 85 follows:
1. Damon Ray Strayer, date of birth February 9, 1996, is tha natural child of Jeffrey
Allen Strayer, hereinafter referred to 85 "Father", and Renee 1. Strayer, hereinafter referred to 85
"Mother',
2. Legal custody pursuant to 23 Pa.C.S.A. ~ 5301, et seq., will be shared by the parties,
3, The parties shall share physical custody on an aiternating weekly basis eccording to the
following schedule:
a. On aiternate weeks, beginning with Sunday, November 9, 1997 until Sunday,
November 16, 1997, the Mother shall have partial custody of the minor child. Beginning with
Sunday, November 16, 1997 until Sunday, November 23, 1997, the Father shall have partial
custody of the minor child. Both parties shall alternate on l!. week to week basis for the
continuation of this Order.
b, On aiternate holidays, beginning with Thanksgiving, 1997. The holidays are:
New Years Dsy, Memorial Day, Fourth of July, Labor Day, and Thanksgiving Day. Such
custody shall begin st 9:00a.m. and end at 7:00p.m.
c. The Christmas Eve and Christmas Day holidays shall be 85 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: in even numbered years, the Father shall
have partial physical custody from 12:00 noon on Christmas Eve until 12:00 noon on Christmas
Day; in odd numbered yesrs, the Father shall have partial physical custody from 12:00 noon on
Christmas Day until 12:00 noon on December 26th. This provision supersedes aU others.
d. The Father shall have the right of custody on every Father's Day from
g:OOa.m. until 6:00p.m. with the Mother having that same right every Mother's Day from
9:00a.m. until 6:00p.m. This provision supersedes aU others.
e. The child's birthday shall be handled as follows: in odd numbered years.
Mother shall have the child from 8:00a.m. until 12:00 noon and Fether shall have the child
from 12:00 noon until 4:00p.m.; in even numbered yesrs, the Father shall have the child from
8:00a.m. until 12:00 noon and Mother shall have the child from 12:00 noon until 4:00p.m.
VERI FICA TION
I verify that the statements made In the foregoing PETITION FOR
MODIFICATION are true and correct to the best of my knowledge, Information and
belief. I understand that false statements herein are made subject to the penalties of 18
Pa,C.S. ~4904, relating to unsworn falsification to authorities.
Date: 1/~ !CfCf
&"Yi(Q~,
enee L. Wise
..
~~
~I~~~ .. -1 ~ HH~
~~~I~ E ~~
I~
- ~ ..
~!~61 r . II 1jl j .
~ ~. f
~ !~ il
ftl~~ J :oJ . liii~
~ 2 i i
. '. 4
. ..
~ ."..
.Li'
. ,
RF.NEE L. S'l'RAn:R, . IN THE OOURT OF CXX>IMOO PLEAS OF
.
Plaintift : CUMBERLAND CXXJNT1{, PENNSYLVANIA
I
.
,
va. . NO. 97-5914 CIVIL TERM
.
.
.
JEFrR!Y ALLEN STRAYER, : CIVIL ACTION - LAW
r.tendant .
.
. CUSTODY/VISITATION
.
alDER Ol" CXlRl'
All) rDf, thia lit+- day of D~
consideration ot the attached Custody Conciliation
and directed sa tollowsl
, 1999, upon
Report, it is ordered
1. 'I't1e prior Order of this Court dated January 2, 1998 shall continue
in ettect as moditied by the provisions of this order.
2. Pending turther order of Court or agreement of the parties, the
parties ahall share having physical custody of the Child on an alternating
bi-weekly basis as to11ows:
'I't1e Mother shall have custody of the Child from September 21, 1999
through SundllY, October 3, 1999 at 6:00 p.m.
'I't1e Father shall have custody of the Child from october 3, 1999 at
6:00 p.m. through Friday, October 15, 1999 in the evening.
The Mother shall have custody of the Child from October 15, 1999
through Sunday, October 31, 1999 in the m:lrning.
'I't1e Father shall have custody of the Child from October 31, 1999
through Sunday, November 14, 1999.
'I't1ereatter, the parties shall continue to alternate having custody
ot the Child a1 a biweekly basis with the exchange to take place
on alternating sundays, unless otherwise arranged between the
parties.
3. 'I't1e holiday custody schedule set forth in the January 2, 1998
order shall supersede and take precedence ove~ the regular custody
achedule.
4. 'I't1e Father shall be responsible to provide transportation for all
exchanges of custody between the Father's residence in Pittsburgh and the
agreed upon meeting place in the local area of the Mother's residence.
5, 'I't1e parties shall cooperate in selecting the school at which the
Child will attend kindergarten by January 2001. In the event the parties
are not able to resolve this issue by agreement by that date, either party
IMY tile a Petition to have the matter resolved through the legal process.
6. In the event either party is unavailable to provide care for the
Child during his or her period of custody for an overnight period or
longer, that party shall give the other party the opportunity to have
custody during his or her period of unavailability prior to contacting
third party babysitters. This provision shall not apply in the event
either party makes arrangements for the Child to spend overnight periods
with grandparents or other relatives.
7. The parties shall cooperate in making decisions regarding the
advisability of exchanging custody during bad weather conditions. In the
event the parties are unable to exchange custody due to travel conditions,
the parties shall arrange for the party who was unable to obtain custody to
have a make-up period as soon as possible.
8. The parties and counsel shall attend a second CUstody conciliation
Conference in the office of the Conciliator, Dawn S. Sunday, Esquire, on
January 4, 2000 at 11:00 a.m.
9. This Order is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of
this Order by mutual consent, In the absence of mutual consent, the terms
of this Order shall control.
BY THE
J,
ee: Daniel F, Wolfson, Esquire and Steven Courtney, Esquire - Counsel for
Mother
Ron Turo, Esquire - Counsel for Father
Cut:u., r"~~..c...(, Ie /5 /q q .
,..!. . -0'.
,
,- ,
RENEE L. STRAYER,
plaintiff
IN THE CXlURT OF CX)tollolOO PLEAS OF
CUMBERLAND CCXlNTY, PENNSYLVANIA
vs,
NO, 97-5914 CIVIL TERM
JEFFREY ALLEN STRAYER,
Defendant
CIVIL ACTION - LAW
CUSTODY/VISITATION
ammy CXH:ILIATlOO SlMIARY REI'CRl'
IN AClXIUlllNCE WITH cnmERLAND CD.Nl'Y RIJLB Of!' crvn. PKlo .... -JUt
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1, The pertinent information concerning the Child who is the Subject
of this litigation is as follows:
NAME
DATE OF BIR'l'II
IN CUSTCIlY OF
Damon Ray Strayer
February 9, 1996
Mother/Father
2. A Conciliation Conference was held on September 21, 1999, with the
following individuals in attendance: The Mother, Renee M, Wise, formerly
strayer, with her counsel, Steven Courtney, Esquire, and the Father,
Jeffrey Allen Strayer, with his counsel, Ron Turo, Esquire and David
Greene, Esquire.
3, The parties agreed to entry of an order in the form as attached,
SqIb1m btA cH _ 1'1 'i 1
Date '
U~..J~d~
Dawn S, Sunday, Esquire
CUstody Conciliator
. R~f\~~ ~~o.'1cr
Plaintiff
: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
: CIVIL ACTION LAW
; No.S9\L\ CIVIL 1991
: CUSTODY VISIT AnON
.je\\.'R'\ I\\\CI\ ~~o,\-C r
Defendant
ORDER OF COlIRT
And nDW, this \ \ \ :)\9'\ ,upon consideration of the attached complaint, it is hereby directed
that the above parties and their respective c;ounseJ appear before
Esquire, the conciliator, at 3 - .
Pennsylvania, on the \ l.\ day of , 1999, at A.M.
for a Pre-hearing Custody Conference. At such conference, an effort will be made tD resolve the
issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard
by the court, and to enter into a temporary order. All children age five or older may be present at
the conference. Failure to appear at the conference may provide grounds for the entry of a
temporary or permanent order.
FOR THE COURT:
By:
~'\
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
THE CUMBERLAND COUNTY BAR ASSOCIATION
~ LIBERTY AVENUE
CARLISLE,PA 17013
(717) 249-3166
1-800-990-9108
,
,'" ~ --- I' ", "';
".
;
~~'",?y
"11'~"
-' , -." /.
'. .. I: ',:
'-,",
<', :
~~ 4ntiJ'd
11-'/-99
1t(1(
d"-H t-.I~ ~-t- 4/ 1Jf/v- ".,;t(...~
1/./f4f t'~ ,~ ~ aif ~~
. .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
RENEE L, STRAYER, n/k1a
RENEE L, WISE,
PlaIntiff
No, 97.5914
v.
CIVIL ACTION
JEFFREY ALLEN STRAYER,
Defendant
CUSTODY
ORDER OF COURT
You, Jeffrey Allen Strayer, Defendant, have been sued in Court to obtain custody of
the child: DAMON RAY STRAYER, born February 9, 1996
You are ORDERED to appear in person at the Cumberland County Court House,
Carlisle, Pennsylvania, on the _ day of . 1999, at a.m.lp.m., for:
.x. a conciliation or mediation conference.
_ a pretrial conference.
_ a hearing before the Court.
_ The presence of the child is not required.
_ The presence of the child is required.
If you fail to appear as provided by this Order or to bring the child, if so ordered, an
order for custody, partial custody or visitation may be entered against you, or the Court
may issue a warrant for your arrest.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Cumberland County Court House
1 Courthouse Square
Carlisle, PA 17013-3387
Telephone No. (717) 240-6100
BY THE COURT:
Dated:
P.).
COURT ADMINISTRATOR'S NOTICE: Attention is directed to Local Rule 1915.1
which requires submittal of a memorandum at the time of the conference,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
RENEE L. STRAYER, n/kla
RENEE L. WISE,
Petitioner/Plaintiff
No. 97.5914
v.
CIVIL ACTION
JEFFREY ALLEN STRAYER,
Respondent/Defendant
CUSTODY
. fIi
AND NOW, this J}2!!.. day of ~ 1999, comes the Petitioner,
enee L. Wise, by and through her attorney, DanIel F, Wolfson, Esquire, and the law linn
f Wolfson & Associates, P.c., and flies the followIng Petition of which the following Is a
tatement:
I. The Petitioner, Renee L. Wise, Is and adult Individual currently residing 2848
akland Road, Dover, York County, PennsylvanliJ J 73 15.
2. The Respondent, Jeffrey Allen Strayer, Is an adult Individual currently residing at
P.O. Box 251, 225 Red Tank Road, Boiling Springs, Pennsylvania 17007.
3, That on or about September 2 J, I 999 the parties met before concllllator,
Dawn M. Sunday, Esquire and an Order was entered giving the parties until January to try
to resolve these Issues by doing a two week onltwo week off arrangement. (Said Order Is
attached hereto as Exhibit "A" and Incorporated herein by reference.)
4, Petitioner has found this to be highly dIsruptive to the child and to the parent-
child relationship.
RENEE L. STRAYER,
Plaintiff
IN THE CXlURT OF c:n-tMC:::tl PLEAS OF
: CUMBERLAND CCXJNTl{, PENNSYLVANIA
:
:
I NO, 97-5914 CIVIL TERM
I
I CIVIL ACTION - LAW
I
CUSTODY/VISITATION
vs.
JEFFREY ALLEN STRAYER,
Defendant
.!!!JI!R a! CDJRT
AND N:JoI, this 4-;tJ.. day of (Q(:'~t.l'- , 1999, upon
consideration of the sttached Custody concilIation Report, it is ordered
and directed ~ follows:
1. The prior order of this Court dated January 2, 1998 shall continue
in effect as modified by the provisions of this order.
2. Pending further Order of Court or agreement of the parties, the
parties shall share having physical custody of the Child on an alternating
bi-weekly basis as follows:
The Mother shall have custody of the Child from September 21, 1999
through Sunday, October 3, 1999 at 6:00 p.rn,
The Father shall have custody of the Child fran October 3, 1999 at
6:00 p.rn, through Friday, October 15, 1999 in the evening.
The Mother shall have custody of the Child from October 15, 1999
through Sunday, October 31, 1999 in the morning,
The Father shall have custody of the Child from October 31, 1999
through Sunday, Noverrber 14, 1999.
Thereafter, the parties shall continue to alternate having custody
of the Child on a biweekly basis with the exchange to take place
on alternating Sundays, unless otherwise arranged between the
parties.
3, The holiday custody schedule set forth in the January 2, 1998
order shall supersede and take precedence over the regular custody
schedule.
4. The Father shall be responsible to provide transportation for all
exchanges of custody between the Father's residence in Pittsburgh and the
agreed upon meeting place in the local area of the Mother's residence.
5. The parties shall cooperate in selecting the school at which the
Child will attend kindergarten by January 2001. In the event the parties
are not able to resolve this issue by agreement by that date, either party
may file a Petition to have the matter resolved through the legal process.
&~W'A"
6. In the event either party is unavailable to provide care for the
Child during his or her period of custody for an overnight period or
longer, that party shall give the other party the opportunity to have
custody during his or her period of unavailability prior to contacting
third party babysitters, This provision shall not apply in the event
either party makes arrangements for the Child to spend overnight periods
with grandparents or other relatives.
7. The parties shall cooperate in making decisions regarding the
advisability of exchanging custody during bad weather conditions. In the
event the parties are unable to exchange custody due to travel conditions,
the parties shall arrange for the party who was unable to obtain custody to
have a make-up period as soon as possible.
8. The parties and counsel shall attend a second CUstody Conciliation
Conference in the office of the Conciliator, Dawn S. Sunday, Esquire, on
January 4, 2000 at 11:00 a.m.
9. This Order is entered PJrsuant to an agreement of the parties at a
CUstody Conciliation Conference. The parties may modify the provisions of
this order by rrutua1 consent. In the absence of mutual consent, the tllrms
of this Order shall control,
BY THE OXJRT,
/5/ &lw....J.. ~. .JJLkd...- J.
ee: Daniel F, Wolfson, Esquire and Steven Courtney, Esquire - Counsel for
Mother
Ron 'l'uro, Esquire - Counsel for Father
~~ "T c'py fROM RECORD
> '. ,'( JI, I hero 1:"'1 set .,'v h<1lld
',t'j' .
, '-' '0'. lou,f ~f CMLS!J, PJ.
11,.4.;#"... d.y of..lsk-c.. 1? QG
,. I ,.,to/.
......"...". D ~ .~ l1. . Y.)~. .
~ .".....""'.Q."'i_.-g. ~~.."__..
J) . PrOf hJno I ~ "I
RENEE L, STRAYER,
Plaintiff
IN THE CXlURT OF CCJtollolCN PLEAS OF
CUMBERLAND OJUNTY, PENNSYLVANIA
VII,
NO. 97-5914 CIVIL TERM
JEFFREY ALLDl STRAYER,
Defendant
CIVIL ACTION - LAW
CUSTODY/VISITATION
amaJl( CXH:ILIATICN SlJllMARY REPCRl'
IN AaDlDANCB WITD cnmmuJ\ND 0JlN1'l( RllLB ar CIVIL PR:I.,., -lIB
1915.3-8, the underlligned CUstody Conciliator submitll the following report:
1, The pertinent information concerning the Child who is the subject
of thill litigation is as follows:
NAME
DATE ar BlRl'H
IN CU::i'~UJ1' ar
Damon Ray Strayer
February 9, 1996
Mother/Father
2, A COnciliation COnference was held on September 21, 1999, with the
following individuals in attendance: The Mother, Renee M, Wise, formerly
Strayer, with her counsel, Steven Courtney, Esquire, and the Father,
Jeffrey Allen Strayer, with his counsel, Ron Turo, Ellquire and David
Greene, Esquire.
3. The parties agreed to entry of an Order in the form as attached,
~/bYYIb,A ~~, /9'1
Date '
c;~ ...J~c1 ==t
Dawn S, Sunday, Esquire
CUstody Conciliator
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
RENEE L. STRAYER, n/kla
RENEE L. WISE,
Peddoner/Plalndff
No. 97-5914
v.
CIVIL ACTION
JEFFREY ALLEN STRAYER,
Respondent/Defendant
CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this rr~ay of Ir.iob€~_, 1999, I, Daniel F. Wolfson, Esquire,
do hereby certify that I have served a copy of the foregoing Peddon to Terminate Current
Order and List Case for Custody Trial upon the parties and counsel of record In the
following manner and addressed as follows:
Ron Turo, Esquire
32 South Bedford Street
Carlisle, PA 17013
Attorney for Respondent
Respectfully submitted,
~~
~)/~Iel F, Wolfson, e
WOLFSON & ASS CIATES, p,c.
267 East Market Street
York, PA 17403
(717) 846-1252
10 No. 20617
Attorney for Peddoner
Y.E.JilllCAIlQ.
I verify that the statements made In the foregoing PETITION TO TERMINATE
CURRENT ORDER AND TO LIST CASE FOR CUSTODY TRIAL are trUe and correct to
the best of my knowledge, Information and belief. I understand that false statements
herein are made sublect to the penalties of 18 Pa.C.S. ~4904, relating to unsworn
falsification to authorities.
Date: 10 /tE/99
.
"
i~~ ~ ..., ~
il~~1 j -I ff~j!
~;
18
. ~!~il r . ljIj .
~ J~ j~f
~
fil~~~ J ji ~
:2
!
~ ~ i
. ,
14M - \I LllIlIL,~
t> -""'d
, .
RENEE L. STRAYER,
Plaintiff
IN TflE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
NO, 97-5914 CIVIL TERM
.
.
JEFFREY ALLlli STRAYER,
Defendant
: CIVIL ACTION - LAW
I IN alSWDY/VISITATION
OODER OF (DJRT
AND toI, this '7~ day of ~
upon consideration of the attached Custody Conciliation
ordered and directed as follows:
, 2000,
Report, it is
1. The prior Order of this Court dated January 2, 199B shall continue
in effect as modified by the provisions of this Order. The prior Order of
this Court dated October 4, 1999 is vacated.
2. The parties shall submit themselves, their minor Child, and any
other individuals deemed necessary by the evaluator to a custody evaluation
to be performed by a professional selected by agreement of the parties.
'Itle purpose of the evaluation shall be to obtain independent
recoomendations concerning ongoing custody arrangements which will serve
the best interests of the Child. The parties shall equally share all costs
of the evaluation. In the event the parties are unable to select an
evaluator by mutual agreement, each party reserves the right to obtain a
separate evaluation to be perfOrmed by a professional selected by that
party at the party's sole cost.
3. Pending completion of the evaluation and agreement of the parties
or further Order of Court, the parties shall share having physical custody
of the Child on an alternating weekly basis with the exchange of custody to
take place each Sunday at 5:00 p.m. The alternating weekly schedule shall
coomence with the Mother having custody of the Child beginning Sunday,
March 12, 2000 at 5:00 p.m. The Father shall have custody of the Child
from February 24, 2000 through March 12, 2000 at 5:00 p.m., with the
exception of the Mother's period of custody from March 3, 2000 at 6:00 p.m.
through March 5 with the time to be arranged by agreement of the parties
but which shall not be before 2:00 p.m,
4. The holiday custody schedule set forth in the January 2, 199B
Order shall supersede and take precedence over the regular custody
schedule.
5. The parties shall cooperate in selecting the school at which the
Child will attend kindergarten by January 2001. In the event the parties
are not able to resolve this issue by agreement by that date, either party
may file a Petition to have the matter resolved through the legal process.
6. In the event either party is unavailable to provide care for the
Child during his or her period of custody for an overnight period or
longer, that party shall give the other party the opportunity to have
custody during his or her period of unavailability prior to contacting
third party caregivers. This provision shall not apply in the event either
party makes arrangments for the Child to spend overnight periods with
grandparents or other relatives.
7. 'l11e parties shall cooper:lte in making deeis.tons regarding the
advisability of exchanging custody during bad weather conditions. In the
event the parties are unable to exchange custody due to travel conditions,
the parties shall arrange for the party who was unable to obtain custody to
have a makeup period as soon as possible.
8. Upon completion of the custody evaluation and in the event the
parties are not at that time able to reach an agreement as to ongoing
custody arrangements, counsel for either party may contact the Conciliator
to schedule an additional CUstody Conciliation Conference,
9.
consent.
control.
The parties may modify the provisions of this Order by mutual
In the absence of mutual consent, the terms of this Order shall
BY 'rHE
cc:
Edward E. Guido, J. /
Daniel F, Wolfson, Esquire - Counsel for Mother /l~. ~ ^ I /YYla12'-tL
Rebert Mulderig, Esquire - Counsel for Father LP~.OO
RK5
,
(,': . .. '.,
1< -', (;'i ~;.f:
~!ilY
00 Hf.R -8 t,ii B: 16
ClJl'L;'" i I. '.,rrv
.. ..t'l...'.tU "'-''''IHr
FEM'!;,YLVNf;\
'.
. ~- ,..-.;::;::....::.. - ____..S- . ~
I
"'"
----~. .
RENEE L. STRAYER,
Plaintiff
IN TilE CXlURT OF OOMMOO PLEAS OF
: CUMBERLAND COONTY, PENNSYLVANIA
vs.
:
: NO, 97-5914
I
I
I
CIVIL TERM
JEFFREY ALLEN STRAYER,
Defendant
CIVIL ACTION - LAW
IN cusroDY/VISITATION
PlUal.ruDGB: Bdvard B. Qlido
ClJS'la)Y f.XJlCILIATIOO 5lM1I\RY REl'CRT
IN ACXXJUlANCE WITII cnmmr.AND <XUflY RULB Cf! CIVIL PMo."".m
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
DATE OF BIRTH
aJRRml'Ly IN CllSTlDY Cf!
Damon Ray strayer
Mother/Father
February 9, 1996
2. A Conciliation Conference was held on February 24, 2000, with the
following individuals in attendance: The Mother, Renee L. Wise (formerly
Strayer), with her counsel, Daniel F. Wolfson, Esquire, and the Father,
Jeffrey Allen Strayer, with his counsel, Robert Mulderig, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
r:;kwo-~ ri-r. tk;OD f),.. j j ,L
Date. I' ~~~
Custody Conciliator
" .
I :
RENEE L. STRAYER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 97-5914
: CIVIL ACTION - CUSTODYNlSITATION
v.
JEFFREY ALLEN STRAYER,
Defendant
ORDER OF COURT
AND NOW, this ~ day of t:)~ , 2000, upon consideration
of the within Stipulation, it is ordered cnd decreed as follows:
1. The prior Orders of this Court, specifically the Order dated January 2,
1998 and the Order dated March 7,2000 are vacated.
2. Primary physical custody of the child shall be in the mother subject to the
following periods of partial custody with the father:
a. Three (3) weekends per month from Friday at 6:00p.m. through
Sunday at 6:00p.m. The Father also has the option to obtain custody of the child
an additional two (2) days per month with reasonable advanced notice.
b. Five full weeks during the months of June, July and August.
c. Alternating holidays from 9:00a.m. to 6:00p.m. The holidays shall
be New Year's Day, Memorial Day, 4th of July, Labor Day and Thanksgiving Day.
d. And such other times as the parties mutually agree.
4. The Christmas Eve and Christmas Day holidays shall be as mutually
agreed upon by the parties. In the event that the parties can not reach an amicable
agreement as to these holidays, the following schedule shall apply: in even numbered
years, the Father shall have partial custody from 2:00 p.m. on Christmas Eve until 2:00
p.m. on Christmas Day; in odd numbered years the Father shall have partial custody
from 2:00 p.m. on Christmas Day until 2:00 p.m. on December 26fh, this provision
supercedes all others.
5. Mother shall have physical custody from 9.00am. until 6.00p.m. on
Mother's Day and Father shall have physical custody from 9.00a.m. unlll 6.00p.m. on
Father's Day. This provIsion supercedes all others.
6. The child's birthday shall be handled as follows: In odd numbered years
the Mother shall have the child from 9.00 a.m. until 6:00 p.m.; In even numbered years
the Father shall haye the child from 9:00 a.m. until 6.00 p.m., this provIsion supercedes
all others.
7. The parties Will share transportation responsibilities dUring exchanges of
custody prOVided that the parties continue to live Within a thirty (30) minute drive of each
other. The parties further agree to use pre-established sWitch points, which are within
the thirty (30) minute drive time. If either party moves outSide of a thirty (30) minute
drive time of the other's residence or pre-established switch points, it Will be their
responsibility to provide for the extra transportation time. The party receiving custody
shall provide transportation from the custodial parent's reSidence.
8. The custodial parent shall inform the non-custodial parent immediately of
all-medical appointments and problems pertaining to the child.
9. Neither parent shall do or say anything that may estrange the chila from
the other parent, injure the opinion of the child as to the other parent or hamper the free
and natural development of the child's love and respect for the other parent.
10. Both parents shall have liberal and reasonable telephone contact with the
child when the child is in the custody of the other parent.
11. The custodial parent shall provide copies of the child's report card and
other reasonable papers affecting the child's education, medical condition, or welfare.
12. Both parents must agree to any extraordinary medical procedures, school
or extra curricular activities, and any other mailers regarding the health, safety and
welfare of the child.
13. The parities agree to maintain continual residence In one of four (4)
Pennsylvania Counties: York, Adams, Cumberland or Franklin. Should either party
relocate outside of this area, this entire agreement shall be subject to re-negotiation.
14. The parties agree that Father's child support obligations shall be
maintained at $65.00 per week plus $5.00 per week for arrearages until such time as
the arrearages are paid In full. Thereafter, the child support obligation shall remain at
$65.00 per week. If the Father does not pay hiS obligalion pursuant to this paragraph
the Mother retains the option to file for child support subject to re-negoliatlons regarding
the chlld's needs.
15. The Mother shall open an account at a financial Institution patronized by
the Father. The Father Will then make arrangements to have the support monies
transferred into the Mother's account. 80th parties are responsible for tracking the
amount of arrearages owed.
16. The Father agrees to pay any co-pays and any un-covered, reasonable
and necessary medical expenses. However, when Father eat.ablishes any permanent
employment With medical benefits superior to those of the Mother, the Father shall have
the option of switching the child over to his benefits and remain responsible for co-pays
and reasonable and necessary un-covered medical expenses.
16. The parties agree that when the child completes the eighth (8Ih) grilde, he
may choose which parent with whom to reside and neither party Will interfere with the
child's choice. This decision in no way affects either parties right to continual visitation
with the child.
BY THE COURT,
J.
G.~
~O' ~.OO
~~
"!Ii
RENEE L. STRAYER.
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLANO COUNTY, PENNSYLVANIA
: NO. 97-5914
: CIVIL ACTION - CUSTODYNlSITATION
v.
JEFFREY ALLEN STRAYER,
Defendant
PETITION TO MODIFY CUSTODY
AND NOW comes the Defendant, Jeffrey Allen Strayer, by and through his
allorney, David A. Greene, Esquire, and pelitlon the Court as follows:
1. On January 2, 1998 and March 7, 2000 this Court entered Custody Orders
in the above captioned matter. These Orders are allached and hereby
incorporated as Exhibit A.
2. The parties have reached an agreement regarding the custody of their
child, Damon Ray Strayer. A copy of this Stipulation is allached and
hereby incorporated to this Petition as Exhibit 8.
WHEREFORE, Defendant requests that this Court vacate the previous Orders of
January 2,1998 and March 7, 2000 and enter an Order consistent with the Stipulation
of the parties.
Respectfully Submilled
TURO LAW OFFI~ES
David A. Greene, squir
28 South Pill Stree
Carlisle, PA 17013
(717) 245-9688
Attorney for Jeffrey Allen Strayer
RENEE L. STRAYER, : IN THE COURT OF COMMON PLEAS
:OF
Plaintiff : CUMBERLAND COUNTY,
.PENNSYLVANIA
v. : NO. 97-5914
JEFFREY ALLEN STRAYER, : CIVIL ACTION -
:CUSTODYNISITA nON
Defendant
CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the Petition
to Modify Custody upon Daniel Wolfson, Esquire, by depositing same in
the United States Mail, first class, postage pre-paid on the -::27/!;:: day of
~ e ?qJI)~
J~fahJ8ER. ,t89Q, from Carlisle, Pennsylvania, addressed as follows:
Daniel Wolfson, Esquire
267 East Market Street
York, PA 17403
TURO LAW OFFICES
DAVID A. GREENE.
28 South Pitt Street
C~rlisle, PA 17013
(717) 245-9688
Attorney for Defendant
RENEE L. STRAYER,
Plaintiff
vs,
: IN THE CXXlRT OF CXXolMCtl PLEAS OF
I CUMBERLAND <:a.lN'n, PENNSYLVANIA
I
I NO. 97-5914 CIVIL TERM
I
I CIVIL ACTION - LAW
I IN CUsrooY/VISITATIOO
JEFFREY ALLEN STRAYER,
Defendant
alDI!R at CXXlRT
AND lDf, this 'Jib day of
upon conaideration of the attached CUstody
ordered and directed as fo11nwsl
, 2000,
Report, it is
1, The prior Order of this Court dated January 2,
in effect a.!I modified by the provisions of this Order.
this Court dated October 4, 1999 is vacated,
199B shall continue
The prior Order of
2. The parties shall submit themselves, their minor O1ild, and any
other individuals deemed necessary by the evaluator to a custody evaluation
to be performed by a professional selected by agreement of the parties,
The pul'p08e of the evaluation shall be to obtain independent
recullI",ildations concerning ongoing custody arrangements whicn will serve
the best interesta of the Child. The parties shall equally share all costs
of the evaluation. In the event the parties are unable to select an
evaluator by mutual agreement, each party reserves the right to obtain a
separate evaluation to be performed by " professional selected by that
party at the party's sole cost.
3, Pending canp1etion of the evaluation and agreement of the parties
or further Order of Court, the parties shall share having physical custody
of the O1ild on an alternating weekly basis with the exchange of custody to
take place each Sunday at 5:00 p.m. The alternating weekly schedule shall
carmence with the Mother hsving custody of the Child beginning Sunday,
March 12, 2000 at 5:00 p.m. The Father shall have custody of the Child
fran February 24, 2000 through March 12, 2000 at 5:00 p.m., with the
exception of the Mother's period of cust~. fran March 3, 2000 at 6:00 p,m,
through March 5 with the time to be arranged by agreement of the parties
but which shall not be before 2:00 p.m.
4. The holiday custody schedule set forth in the January 2, 1998
Order shall supersede and take precedence over the regular custody
schedule.
5. The parties shall cooperate in selecting the school at which the
Child will attend kindergarten by January 2ool. In the event the parties
are not able to resolve this issue by agreement by that date, either party
may file a Petition to have the matter resolved through the legal process.
6. In the event either party is unavailable to provide care for the
O1ild during his or her period of custody for an overnight period or
longer, that party shall give the other party the opportunity to have
I8rr
A
custody during his or her period ot unavailability prior to contacting
third party caregivers. This provision shall not apply in the event either
party maltes arrangments for the Child to spend overnight periods with
grandparents or other relatives.
7, The parties shall cooperate in malting decisions regarding the
advisability ot exchanging custody during bad weather conditions, In the
event the parties are unable to exchange custody due to travel conditions,
the parties shall arrange tor the party who was UI1lIb1e to obtain custody to
have a malteup period as soon as possible.
8, Upon carp1etion of the custody evaluation and in the event the
parties are not at that time able to reach an agreement aa to CXl90ing
custody arrangements, counsel for either party may contact the Conciliator
to schedule an additional CUstody conciliation Conference.
9.
consent.
control,
The parties may modify the provisions of this Order by mutual
In the absence of mutual consent, the terms ot this Order shall
BY TIlE CXXlRT,
lCl J ti.J.ilHl) J f, .n uk
~ E. Gu?dol J.
cc: Daniel F. Wolfson, Esquire - Counsel tor Mother
Robert Mulderig, Esquire - Counsel for Father
TP.U'; C~l'Y fR.OM RECORD
In Tesl~m"~': . .:,.'1. I II r, ,mlo set my haM
and lhe seal of silid Courl ill c~Xa,
~'I 0 ty of.. . '!Jo/
......Q....... . . ....
.- . ..... .,
rofhonolary
RENEE L. STRAYER.
PI8fDtIlt
: IN THE COURt' OF COMMON PLEAS OF
: CUMBEllLAND COUNTY; PENNSYLVANIA
Y.
.
.
: NO, 91.891~ CIVIL TERM
JEFFREY ALLEN STRAYER,
Deflllldmt
,
: IN CUSTODY
COURT ORDER.
AND NOW, thII .2 AW{ day oC /l ",..
~ I
within Stlpu1atlol1li is ordered and decreed u foilcnn:
1. DllIIIOII Ray Strayer, date of birth February g, 1996, is tha natural child oC Jemey
19ft
, ~ upolI COIIIideratlon oC the
Allen Strayer, hereinafter referred to as 'Father', and Rene& L. Straye1', hereinafter referred to as
'Mother'.
2. Legal c:usto<ly pursuant to 23 PLC.S.A. I 8301. et seq~ wil1 be shared by the parties.
3. The perlies shall share pbymca1 custody on an alternatlni week1y buIa accordIni to the
foilowlnr achedule:
L On altemeta weeks, beginning with Sunday, November g, 1997 until Sunday,
Novemiler'l6, 1997, the Mother shall have pertlal custody oCthe minor-child. Begbmlngwlth
Sunday, November 16, 1997 until Sunday, November 23, 1991, the Father shall have pertlal
custody of the minor clilld. Both parties shall altemate on a week to week buIa for- the
continuation oC thII Order.
b. On alternate holldayw, beginning with ThanlDgIving; 1997. The holidays are:
New Yesrs Day, Memorial Day, Fourth of July, Labor Day, and Thanbgivlng Day. Such
custody shaIl begin at g:OOa.m. and end. at 7:00p.m.
e. The Christmas Eve and. Chrimnaa Day holidays shall be as mutually agreed
upon by the perlies. In the event that the perlies omnot reach an amlcable agreement as to
these holldays, the fonowing scl1eduJe shall applr. In even numbered years, the Father shall
have pertlal pbymca1 custody from 12:00 noon on Chrlstmaa Eve untll12:oo noon on Chrlstmaa
Day; In odd numbered years, the Father shall have partial pbymca1 custody from 12:00 noon on
Christmas Day until 12:00 noon on December 26th. This provision lIIpOI'Bedes an others.
d. The Father shall have the right of custody on ft'fer'/' Father's Day from
9:00a.m. until 6:00p.m. with the Mother having that same right tmrr'f Mother's Day from
9:00a.m. until 6:00p.m. This provision supersedes an othlll'lL
5. The clilld's birthday shall be handled as foilowr. In odd numbered years,
Mother shaIl have the clilld from 8:00a.m. until 12:00 noon and Father shaIl have the child
from 12:00 noon until 4:00p.m.; In even numbered years, the Father shall have the clilld from
8:ooLm. until ~OO noon and Mother shaIl have the clilld tram 12:00 noon until 4:00p.m.
These periodI will alternate back and rorth 1'rom 7e4r to 7MZ" Tbla prvriaIon wpenedetI all
othen.
C It either Mother or Fathar wish to take more th.au t.he I'8q\Ii1ed week ar
visitation durini the echoof lIUIDIIlllI" 'IlICatlon, then that party ahaIl p.. at leat a thIrt7 (SO)
Day writtan notl&ation to t.he other perty.
4. M....'....I Carefl'reatment. Each party shall inform the other perty ar ~ medkal
emergencies occurring "bile the child is in that parents care.
~. Relocation. Each party shaIllmmedlately inform the other party or hla or her new
address and telephone number in the nent or pending relocation, tamponuy or permanent.
6. Seat Belts and Chl1d Restro.int Seata. Both parties ahaII utl11ze chI1d restraint eesta and
seat belts when t:ran.spordng the child by automobile.
1. TeleDhone contact. The non-cuatodlal parent shall have Iibera1 righte or talephone
contact with the chI1d while the child is in the othar party'a physical cuatocI1.
8. TransDortation. The non-cuatodlal parent ahaII pI'O'Ilde trensportatlon uuIea otherwlae
agreed upon by the parties. This means that the party =encini bWber period or perdaI. custody
aha1l pI'O'Ilde the tnmaportatIon.
9. Cw:nberland County shall retain continuous, exclualve jurIsdfct:Ion ewer thla c:uatody
matter sa long sa at leat one party or the child remains a. resident oC Cumberland County, or unJ_
otherwise agreed upon by the parties.
10. The parties agree to cooperate in deciding which echool the child is to attend when he
reeches echool age.
TRue COpy FROM RECORD
lR T~ whereof, I here unto::at my h:>o
and tho seal of said C at Carii$le, Pa,
Thl " 1
Prothonotary
By t.he Court.
Is/ [;Jr.... t3. 1.1...4-
, I J
J.
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 97-5914
: CIVIL ACTION - CUSTODYNlSITATION
RENEE L. STRAYER,
Plaintiff
JEFFREY ALLEN STRAYER,
Defendant
rJe.
AND NOW, this ~........ day of SEPfEhJfl#i~" ,2000, It Is hereby
stipulated and agreed between the parties as follows:
1. Damon Ray Strayer, born February 9, 1996 is the natural child of Jeffrey
Allen Strayer hereinafter referred to as "Father" and Renee L. Strayer hereinafter
referred to as "Mother".
2. Shared legal custody of the child as contemplated by the Act of October
30,1985, P.L. 264, 23 P.S. !l5301, et seq., will be in both of the parties, as the natural
parents.
3. Primary physical custody of the child shall be in the mother subject to the
following periods of partial custody with the father:
a. Three (3) weekends per month from Friday at 6:00p.m. through
Sunday at 6:00p.m. The Father also has the option to obtain custody of the child
an additional two (2) days per month with one week advanced notice.
b. Five full weeks during the months of June, July and August.
c. Alternating holidays from 9:00a.m. to 6:00p.m. The holidays shall
be New Year's Day, Memorial Day, 4th of July, Labor Day and Thanksgiving Day.
d. And such other times as the parties mutually agree.
4. The Christmas Eve and Christmas Day holidays shall be as mutually
agreed upon by the parties. In the event that the parties can not reach an amicable
agreement as to these holidays, the following schedule shall apply: in even numbered
years, the Father shall have partial custody from 2:00 p.m. on Christmas Eve until 2:00
p.m. on Christmas Day; in odd numbered years the Father shall have partial custody
EXHIBIT
B
from 2:00 p.m. on Christmas Day until 2:00 p.m. on December 261h, this provision
supercedes all others.
5. Mother shall have physical custody from 9:00a.m. until 6:00p.m. on
Mother's Day and Father shall have physical custody from 9:00a.m. until 6:00p.m. on
Father'a Day. This provision supercedes all others.
6. The child's birthday shall be handled as follows: in odd numbered years
the Mother shall have the child from 9 a.m. until 6:00 p.m.; in even numbered years the
Father shall have tile child from 9 a.m. until 6: 00 p.m. this provision supercedes all
others.
7. The parties will share transportation responsibilities during exchanges of
custody provided that the parties continue to live within a thirty (30) minute drive of each
other. The parties further agree to use pre-establlshad switch points, which are within
the thirty (30) minute drive time. If either party moves outside of a thirty (30) minute
drive time of the other's residence or pre-established switch points, it will be their
responsibility to provide for the extra transportation time.
8. The custodial parent shall inform the non-custodial parent immediately of
ail-medical appointments and problems pertaining to the child,
9. Neither parent shall do or say anything that may estrange the child from
the other parent, injure the opinion of the child as to the other parent or hamper the free
and natural development of the child's love and respect for the other parent.
10. Both parents shail have liberal and reasonable telephone contact with the
child when the child is in the custody of the other parent.
11. The custodial parent shall provide copies of the child's report card and
other reasonable papers affecting the child's education, medical condition, or welfare.
12. Both parents must agree to any extraordinary medical procedures, school
or extra currlcula~ activities, and any other matters regarding the health, safety and
welfare of the child.
13. The parties agree to maintain continual residence in one of four (4)
Pennsylvania Counties: York, Adams, Cumberland or Franklin. Should either party
relocate outside of this area, this entire agree men: shall be subject to re-negotiatlon.
..
14. The parties agree that Father's child support obligations shall be
maintained at $65.00 per week plus $5.00 per week for arrearages until such time as
the arrearages are paid In full. Thereafter, the child support obligation shall remain at
$65.00 per week. If the Father does not pay his obligation pursuant to this paragraph
the mother retains the option to file for child support subject to re-negotlations regarding
the child's needs.
15. The Mother shall open an account at a financial institution patronized by
the Father. The Father will then make arrangements to have the support monies
transferred Into Mothers account. Both parties are responsible for tracking the amount
of arrearages owed.
16. The Father agrees to pay any co-pays and any un-covered, reasonable
and necessary medical expenses. However, when Father establishes any permanent
employment with medical benefits superior to those of the mother, the Father shail have
the option of switching the child over to his benefits and remain responsible for co-pays
and reasonable and necessary un-covered medical expenses.
17. The parties agree that when the child completes the eighth (81h) grade, he
may choose which parent with whom to reside and neither party will Interfere with the
child's choice. This decision in no way affects either parties right to continual vjsitation
with the child.
9-/3-00
Date
'. Y7 {UI,5~J
ee L. Strayer
9-/3-00
Date
J~
...... I"") r.:
.::: ".:
..,; .'
r ,-
IJI :".-: , !
, , .:
, -.. 'I ~~~
,-. 1
('.~ '_:k
.. II:"')
.' ~.;.J...
, v. ~:
, , :';1
,-, L_:'-) U