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HomeMy WebLinkAbout98-00438 ~.. 0\ j; lr. .~.. f~ .. :-;)~ C> !':::! t3~ ~_.. "'- 00,'. roO 0.: l-:l~ ..~r!: .. c- '0 ..;:?:;; '. l1: N ~I;;! '~..... ""in . "O:~~ - 111, ~o _c, cl".lll.. . F. ..., :~ . i.L CD . :;) 0 0'\ U . '.~.......' . '-. . . . "',. '. . , . ~ .' '. . '<CIl", ...:$.. .' ..~......~:i..........~. /', ~-,." 0 ':Z, '.~. O .,~ . .."CIl :I:'8.r:.~ ,.:1:. HU 8~, ;r;,;I::-zo .:..0.. ~O.Z .. ....CIlH 'llll~~.. .0.:1: r&l.r:. '~ll< :U.U ..:I. .. . . H .r&l..... >'. .=.0 H .E-t .... .U' ..Z '1:1 . . = UIloI H..... ~:;:l s:: . or! Oftl ~ E-tll< E-t r&l .p:; III (. . . .' j' . >. \~,'f . = U H ~-g ftl .'tl p:;s:: Q) .r:..... ..:IQ) ..:10 r&l tll ~ ~ ~~ I'r) ......~ \\ >< o o E-t CIl ~ U p:; o .... E-t Z H .r: ..:I ~ o U ~ el !: 'l!I~:!;. .. Z z . -;l: ,.;/i! ~:S~~>I1.. O~~ ~. o/l ell> ~, el~~~r . ~ <S1~~ ~g~ - ....~ o .~ I i 81.... .. I 7, The mother of the child is Angella R. Urich who currently resides at 549 North Front street, steelton, Dauphin county, pennsylvania. 8. she is married to Brett D. Urich. 9. The father of the child is Brett D. urich who currently resides at 618 Hi.gh street, West Fairview, cumberland county, pennsylvania. 10. He is married to Angella R. Urich. 11. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with his parents, Peggy L. Urich and Barry E. urich. 12. The relationship of Defendant to the child is that of mother. The Defendant currently resides alone. 13. plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 14. plaintiff has concerning the child no information of a custody proceeding pending in a court of this commonwealth. 15. plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 16. The best interest and permanent welfare of the child, Rebecca E. urich, will be served by granting primary legal custody and primary physical custody to plaintiff because he has been the primary caretaker since birth and has been responsible for .... <X) '>- q; c: E;: ~ ..... ~j 7J.~=r: ~..,. ",-' ~J% . C> '-- .;' Iff\: c.: ,.);:.: "J 0.' .:~ e-; ,C. el au N ''''<;.. UJL~. i'r~ :;-; .-Ju: r:;:, L,l ;fJ U::r. 1,,1.1 ::~: CL.. ,- lL. ..:,; 1.1. t"'J~ "5 0 '" u .1 .... -~ VB. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY BRETT D. URICH, Plaintiff ANGELLA R. URICH, Defendant ;' ~ , NO, 98-438 AFFIDAVIT OF MAILING COMMONWEALTH OF PENNSYLVANIA ss . . . . COUNTY OF CUMBERLAND Stephen G. Held, Esquire, the attorney for Plaintiff, being duly sworn according to law, says that he mailed by certified, restricted mail, return receipt requested, a true and correct copy of the plaintiff I s complaint in Divorce in this action to the Defendant at her residence, and that Defendant did receive same as evidenced by the signed receipt attached hereto as Exhibit "A". st~~~ Attorney for Plaintiff 28 North 32nd street Camp Hill, PA 17011 717-975-2840 Sworn to and subscribed before me this ~ day of Fpl'!.,eUA.e.<I , 1998. ~a.au-tc~>U' E. =S:vn:.Ud</.A tt;tary Public .f NOTA:'J"L ~c:AL CAROLCN! e. :',~I\~~4.t'iO Net....., Pv"c Co '.'1 . .... o. mp .11' ~'::'.l, "''':::''~:;',:;!z.,;:l ~J., [1^ My Commu.lon CxI1:'PI AprjJ :l:>, 3001 BRE'IT D. URICH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98-438 CIVIL TERM ANGELLA R. URICH, Defendant CIVIL ACTION - LAW CUSTODY aIDER OF CXXJRT AND toi, this ~ J.J. day of ~ l~ (..~ ' 1998, upon consideration of the att~tody Conciliation Report, it is ordered and directed as follows: 1. The Father, Brett D. Urich, and the Mother, Angella R. Urich, shall have shared legal custody of Rebecca E. Urich, born December 24, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. To the extent one parent has possession of any records or information, that parent shall be responsible to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. The Father shall have primary physical custody of the Child. 3. The Mother shall have partial physical custody of the Child on alternating weekends from Friday after work until Sunday at 7:00 p.m., beginning March 20, 1998. In addition, the Mother shall also have custody of the Child every Wednesday from after work until 7:00 p.m. and on alternating Mondays, fOllowing the Father's periods of weekend custody, from after work until 7:00 p.m. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon until Christmas Day at 12:00 noon, and Segment B, which shall run from Christmas Day at 12:00 noon until December 26 at 12:00 noon. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. The Father shall have custody of the Child during Segment A in odd numbered years and during segment B in even numbered years. B. Thanksgiving: The parties shall alternate having custody of the Child on Thanksgiving Day from 9:00 a.m. until 5:00 p.m., with the N..~C'>:. <<,mI ....., rc\)'\)' \,.,\,:.r)\I'~\' ~,."...,?(',~\. ~." .. \'1'-' - (Jr'''' ~\\.,I.)\ \,,'i\ 7.\\ \o" ~?>~ . rJO\'i~ "'J ,D ' "1\ ,,~'(l;l:);'\",\~.,~~~\ . \..J \"'(..""\"\~ .. .. . . . --'..... Father having custody in even numbered years and the Mother having custody in odd numbered years. C. Alternating Holidays: The parties shall alternate having custody of the Child on the specified holidays from 9:00 a.m. until 5:00 p.m. in accordance with the following schedule: The Mother shall have custody of the Child on Easter sunday and July 4th in odd numbered years and on Memorial Day and Labor Day in even numbered years. The Father shall have custody of the Child on Easter sunday and July 4th in even numbered years and on Memorial Day and Labor Day in odd numbered years. ,. , ~ , D. Mother's Day/Father's Day: The Mother shall have custody of the Child every year on Mother's Day frClll 9:00 a.m. until 5:00 p.m. The Father shall have custody of the Child every year on Father's Day from 9:00 a.m. until 5:00 p.m. 5. Both parties shall be entitled to have custody of the Child during the sumner each year for two (2) consecutive weeks upon providing as much advance notice as possible to the other party. 6. 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 agreement. In the absence of mutual agreement, the terms of this order shall control. BY THE COURT, cc: stephen G. Held, Esquire - Counsel for Father - C~ (T""'~ '3/;J'f{ 98'. Elizabeth A. Hoffman, Esquire - Counsel for Mother xf.~ J. ....... ....'; . BRE'IT D. URICH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 98-438 CIVIL TERM . : ANGELLA R. URICH, : CIVIL ACTION - LAW Defendant : CUSTOD:l CUS'lUDY <nlCILIATI~ SlJIMARY REJ:lCRT IN Aca:IUlANCE WITH CDIBERLAND axml( RULE OF CIVIL 1'~ 1915.3-8, the undersigned custody Conciliato~ submits the following report: 1. The pe~tinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH aJRRmTLY IN cusrooy OF Rebecca E. Urich Decembe~ 24, 1995 Father 2. A Conciliation Conference was held on Ma~ch 12, 1998, with the following individuals in attendance: The Fathe~, B~ett D. Urich, with his counsel, Stephen G. Held, Esqui~e, and the Mother, Angella R. U~ich, with her counsel, Elizabeth A. Hoffman, Esqui~e. 3. The pa~ties ag~eed to entry of an ~der in the form as attached. oB~~ CUstody Conciliator mCVI (11 If 1'1 C;,; Date I ~..... '" ~ U. '- ~..r I~' ": ':~ ') .". " ~ T."t '..);.') :-r.: '.J :1: I:: H.. '''j~:j ',. , "- r.1\ ~'.: ~I:l , ('oJ ,J;",:- " IJ:~ '" ;~ 11J1.l': I "ic.... ~. I ~" C;J ~J Cl 0 U ~ Z N ~ io~ ~ ~~&;~~ 2 o .:I.,,_N ! :I: ~ & <;:: i '~Jla.- Ii < t- .!:: E e '€~. i Qo-a'" . t: Z 'E ~ j ~<o~~ N N ~ . ::l N N '" ;:: !::: , JUN.3.~ BRETT D. URICH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 98.438 CIVIL TERM ACTION IN CUSTODY v. ANGELA R. URICH, DefendanVPetltloner v, PEGGY and HARRY URICH, Respondent NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claims set forth In the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attomey and filing In writing with the Court your defenses or objections to the claims set forth against you, You are warned that If you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief required by the Plaintiff, You may lose money or property or other rights important to you, 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. Office of the Court Administrator Courthouse, 4th Floor Carlisle, PA 17013 (717) 240-6200 ~.. .~. Ellzabe1h A, Hoffman, Esquire 106 Walnut Street Harrisburg, PA 17101 (717) 236.2956 BRETT 0, URICH, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-436 CIVIL TERM ACTION IN CUSTODY v. ANGELA R, URICH, DefendanUPelllloner v, PEGGY and HARRY URICH, . Respondents DEFENDANT'S PETITION TO MODIFY CUSTODY ORDER 1, DefendanUPetllioner Angela Urich (hereinafter "Mother") is an adult Individual whose mailing address is 307 Summit Ridge Drive, Middletown (Dauphin County), Pennsylvania 17057. 2, Plaintiff/Respondent Brett D. Urich (hereinafter "Father") Is an adult individual whose mailing address Is 568 East Old York Road, Boiling Springs (Cumberland County), Pennsylvania 17007, 3, Respondent Peggy and Hany Urich (hereinafter "the patemal grandparents") are adult individuals whose mailing address is 618 West High Street, West Falrview (Cumberland County), Pennsylvania 17025, 4, Mother seeks primary physical custody of the minor child, Rebecca E, Urich, through modification of the current custody order entered by this Honorable Court on March 21, 1996, (See Exhibit "A"), 5, The current custody order gives Father primary physical custody of the minor child and partial physical custody to Mother, 6, The minor child was born on December 24, 1995, WHEREFORE, Mother respectfully requests that this Honorable Court enter an order to modify the current custody order by granting primary physical custody to Mother. Respectfully submitted, IIza h A. Hoffman, Esq e AUomey for PetltlonBr 106 Walnut Street Harrisburg, PA 17101 717-236-2956 Attorney 10 #71000 I I I I I I I I I I i i I i I 1 I I , , VERIFICATION 1 VBrify that the statBments made in the allached Petlllon to Modify Custody OrdBr are true and correct to the best of my knowledge, Informallon, and belief, I understand that false statements herein are made subject to the penallles of 18 Pa,C,S,A, !j4904, rBlallng to unswom Date:C; - "::l. :1 - CJC) af/%,~V;/ 8"gela Uric falslflcallon to authorilles, CERTIFICATE OF SERVICE I, Elizabeth A. Hoffman, Esquire, do hereby certify that a true and correct copy of the attachBd Respondent's Petition to Modify Custody Order was sent by U.S, mall to the following. person: Brett 0, Urich 566 East Old York Road Bolling Springs, PA 17007 Peggy and Harry Urich 618 High Street West Fairvlew, PA 17025 Date: Eliza th A, Hoffman Attomey for Petitioner 106 Walnut Street Harrisburg, PA 17101 717-236-2956 Attomey 10 #71000 AUG I . '.' "\ BRETT D, URICH, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs, NO, 98-438 ANGELA R. URICH Defendant/Petitioner CIVIL ACTION - LAW vs, CUSTODY PEGGY and HARRY URICH/Respondents : ORDER OF COURT AND NOW, this 't tL day of ~ ....,~ ~ "::. t , 2000, upon consideration of the attached Custody Conciliation report, it is orde d and directed as follows: 1, The Mother, Angela R. Urich, and the Father, Brett D, Urich, shall have shared legal custody of Rebecca E, Urich, born December 24, 1995, Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding her health, education and religion, Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, school and medical records and information, To the extent one parent has possession of any records or information, that parent shall be responsible to share the same, or copies thereof, wilh the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2, The Mother shall have primary physical custody of the child, 3, The Father shall have partial custody of the child on alternating weekends from Friday after work until Sunday at 7:00 PM, In addition, the father shall have custody of the child every Wednesday after work until 7:00 PM and on alternating Mondays following mother's periods of weekend custody, from after work until 7:00 PM, 4. follows: The parties shall share or alternate having custody of the child on holidays as 1. Christmas: The Christmas holiday shall be divided into Segment A, which runs from Christmas Eve at 12:00 Noon until Christmas Day at 12:00 Noon, and Segment B, which shall run from Christmas Day at 12:00 Noon until December 26 at 12:00 Noon, Mother shall have custody of the child during Segment A in even-numbered years and Segment B during odd- numbered years, Father shall have custody of the child during Segment A in odd-numbered years and during Segment B in even-numbered years, 2, Thanksgiving: The parties shall alternate having custody of the child on Thanksgiving Day from 9:00 AM until 5:00 PM, with Father having custody in even-numbered years and Mother having custody in odd-numbered '~) .. . . ',~. .'.. years, 3, Alternating Holidays: The parties shall alternate having custody of the child on the specific holidays from 9:00 AM until 5:00 PM in accordanr:e with the following schedule: Mother shail have custody of the child on Easter Sunday and July 4th in odd-numbered years and on Memorial Day and Labor Day In even-numbered years. Father shall have custody of Ihe child on Easter Sunday and July 4th in even-numbered years and on Memorial Day and Labor Day in odd-numbered years, 4. Mother's Day/Father's Day: Mother shall have custody of the child every year on Mother's Day from 9:00 AM until 5:00 PM. Father shall have custody of the child every year on Father's Day from 9:00 AM until 5:00 PM, 5. Both parties shall be entitled to have custody of the child during the summer each year for up to two (2) consecutive weeks upon providing as much advanced notice as possible to the other party, 6. The parties have agreed that the exchange point for custody shall be the home of the paternal grandparents, Peggy and Barry Urich. 7. 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 agreement. In the absence of mutual agreement, the terms of this Order shall control. BY THE COURT, Dlst: Elizabeth A, Hoffman, Esquire 106 Walnut Street arrlsbu'g, PA 17101 Brett D. Urich 566 East Old yo,k Road Boiling Springs, PA 17007 Peggy and Ha,ry Urich 618 High Street West Falrvlew , PA 17025 J.~ (\ ^',lI) f\\'{. 00 L. eN'"' <&,10 ~ T'""'''= r'--" r--"".~ "",:r,:::,.i) I .. ". \.\ r.jl,and n I . an': ;;\.: :l~':~ v ~;,:! J (J..lll at (M1i3b, pa. 1h;, c'ay of . . ............., ........ ""..................... ............................................. ..... Prolhonotary {" ,i. . ; ~.; -~:~':":-'::-::~"iT/.nY 'J'. 201;11 . I I' "( - i' I I, .', O -" , " , ....,'UNTY ' " , \i~J ' U I Cu "'I'll", '" 1':PE~iNSyi.IJAl"I1A ,5, If'()! SI/'tJ/ .5"ll1/ M'~~z;q~ ~~~~ ~ ~ "iI.df~ ." -- i: r >- 0' t':'": _3 r.~ .r; .'. ,.. C~~J :.:J..... "~'I II! '~';:--.J , !> ''C: I ~ ;) :.:: ,I lJ_ ~1 ::J ~ (.rl; .,. .'- ..... .) if} ~ I,; c-" ,-'r~ ~iJ t..:. C." 1:1lf! d. ,'- fJI ~ .~-. -.. ~ '0 ... "C) fl.. :.J - '.J Cl U - - - Q ~ ~ 'b} CJ - z -< ~ ~~_O~ O tll :H;::::~ .... ~ - '" :x: ... Vi <_ .t'S-;D..!::: -< to.: .,;t: :J:: c:s:: 5 . !-l'" ..c to ~ ~ cg'E~ =-<-:o~ t:s x~ :3 ;:: "-l t: ~ , f I i 8 ! . i AUG 7 2DDD '::' BRETT D, URICH, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 98-438 CIVIL ACTION - LAW CUSTODY Plaintiff vs, ANGELA R. URICH Defendant/Petitioner vs. PEGGY and HARRY URICH/Respondents : ORDER OF COURT AND NOW, this q-l:h day of j:) II f\ I . e. t. , 2000, upon consideration of the attached Custody Conciliation report, i~ted as follows: 1. The Mother, Angela R. Urich, and the Father, Brett D. Urich, shall have shared legal custody of Rebecca E. Urich, born December 24, 1995, Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding her health, education and religion, Pursuant to the terms of this paragraph, each parent shall be entitled to all records and Information pertaining to the child including, but not limited to, school and medical records and information, To the extent one parent has possession of any records or information, that parent shall be responsible to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. The Mother shall have primary phYSical custody of the child, 3, The Father shall have partial custody of the child on alternating weekends from Friday after work until Sunday at 7:00 PM, In addition, the father shall have custody of the child every Wednesday after work until 7:00 PM and on alternating Mondays following mother's periods of weekend custody, from after work until 7:00 PM. 4. follows: The parties shall share or alternate haVing custody of the child on holidays as 1, Christma!1: The Christmas holiday shall be divided into Segment A, which runs from Christmas Eve at 12:00 Noon until Christmas Day at 12:00 Noon, and Segment B, which shall run from Christmas Day at 12:00 Noon until December 26 at 12:00 Noon, Mother shall have custody of the child during Segment A in even-numbered years and Segment 8 during odd- numbered years, Father shall have custody of the child during Segment A in odd-numbered years and during Segment 8 in even-numbered years, 2. Thanksgiving: The parties shall alternate having custody of the child on Thanksgiving Day from 9:00 AM until 5:00 PM, with Father haVing custody in even-numbered years and Mother having custody in odd-numbered Plalnllff/Respondenl JY\J~ (f 521iO~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRETT D, URICH, vs, ANGELA R. URICH, DefendanUPetilloner NO, 98.438 vs. PEGGY AND HARRY URICH, Respondenls CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this ~I ft day of ~ u ( I ' 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1, Legal Custody, The parents, Brett D, Urich and Angela R. Urich, shall have shared legal custody of the minor Child, Rebecca E. Urich, born December 24, 1995. Each parenl shall have an equal right, to be exercised joinlly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not Iimiled to, all decisions regarding her health, education and religion, Pursuant to the terms of Pa. C, s. 9 5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parenl has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as 10 make the records and information of reasonable use to the other parent. 2. Physical Custody, Mother shall have primary physical custody subject to Falher's rights of partial physical custody which shall be arranged as follows: A. Each Tuesday and Thursday evening from after work until 7:00 p,m. B, Alternating weekends from Friday after work until Sunday at 7:00 p.m, 3, Christmas, The Christmas holiday shall be divided into Segment A which runs from Christmas Eve at 12 Noon until Christmas Day at 12 Noon, and Segment B which shall run from Christmas Day at 12 Noon until December 26th at 12 Noon, Molher shall have custody of the Child for Segment A in even-numbered years and Segment B during odd-numbered years, Falher shall have custody of the Child during Segmenl A in odd-numbered years and during Segment B in even-numbered years, I: '~ CUlf' j..~' P".C',,:";" 'I II I.!),,,dl..i ~',Ji ( >~f \ j( , . . --....._" ..~.IJ>' No, 98-438 4, Jhanksglving, The parties shall alternate having custody of the Child on Thanksgiving Day from 9:00 a,m. until 5:00 p,m.. with the Father having cuslody In even- numbered years and the Mother having custody in odd-numbered years, 5, Alternating Holidays, The parties shall alternate having custody of the Child on specific holidays from 9:00 a,m, until 5:00 p,m, in accordance with the following schedule: A. Mother shall have custody of the Child on Easter Sunday and Independence Day in odd-numbered years and on Memorial Day and Labor Day In even-numbered years. B, Falher shall have custody of the Child on Easter Sunday and Independence Day in even-numbered years and on Memorial Day and Labor Day in odd-numbered years. . I :t I 6, Mother's Day/Father's Day. Mother shall have custody of the Child every year on Mother's Day from 9:00 a,m. until 5:00 p,m. Father shall have custody of the Child every year on Father's Day from 9:00 a,m. until 5:00 p,m, 7. Both parties shall be entitled to have custody of the Child during the summer each year for up to two (2) consecutive weeks providing as much advanced notice as possible to the other party. 8. The exchange point for custody shall be the home of the Paternal Grandparents, Peggy and Barry Urich, unless otherwise agreed. \ J 1 '\ , I 9, TransDortation, in the event that Mother is unable to provide the transportation or that road conditions would make it more reasonable for Father to provide the transportation in his four-wheel-drive vehicle, Father shall provide transportation at the end of his custodial period, It shall also be permissible for the Maternal Grandmother to provide transportation in the event that Mother is not able to do so at the conclusion of Father's custodial period, The transportation for holidays shall be arranged as follows: Mother shall deliver the Child to the Father at the beginning of his holiday custodial time and Father shall provide the transportation home at the conclusion of his custodial holiday time, ! ~ ! ( i , I I l ..~ I { Ii " ,: \,. , 'I BY THE COURT, J, Dlst: Brett 0, Urich, 618 High Street, Enola, PA 17025 '" ' Elizabeth A. Hoffman, Esqul,e, 106 Walnut St'eet. Harrisburg, PA 17101 / 4fU' ,.,,,,..j...{ ').11(.1/ !, 9-, IlIUlTI' D, URICII PLAINTIFF IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 98.438 CIVIL ACTION LAW ANGELA R, URICH DEFENDANT IN CUSTODY OIWEI{ OF COllin AND NOW, Monday, December 09, 2002 ,upon eonsiderution of the attached Complaint, it is hereby directed that parties and their respective counsel appenr before Melissa p, Greev):, Esq, , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Tuesday, January 07,2003 at 11:00 AM for a Pre-Hearing Custody Confcrenee, At such eonl'crence, nn cff0l1 will be madc to rcsolve the issues in dispute; or if this cannot be aeeomplisbed, to deline and narrow the issues to be heard by the court, and to enter into a temporary order. All children nile live or older may also be present at the conference, Failure to appenr at the conference may provide grounds for entry of a tempornry or permnnent order, The court herehy directs the pnrtles to furnish any nnd nil existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 honrs prior to scheduled hearing. FOR THE COURT. By: /s/ Melissa p, Greevy. Esq. {/ Custody Conciliator 'nle Court of Common Pleas ofCumberJand County is required by law to eomply with the Amcricans with Disabililes Aet of 1990, For information about acccssible facilities and reasonable neeolTImodntions available to disabled individuals having business before the court, please contact our olliee, All alTllllgements must be made at least 72 hours prior to any hearing or business before lhe eourt. You must allend the scheduled conference or hearing. YOU SHOULD TAKE TIIIS PAPER TO YOUR ATJ'ORNEY AT ONCE, IF YOU DO NOT HAVE AN ATroRNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORHI BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty A venue Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 '-"'. I, f:....'r ,:(:L OF',' ., '}:IJ1Y 02 DEe 10 P/l :1: :10 CUtvlEdlL/ .'lU COUNTY PENNSYLV/\NIA ):; j,t) fj.:J j.;:) '/0 '0,) I;; ./tJ .tJcJ dJ,df;/{f ,Irv:A/'6 4' ~ ~ IU~ Z aZj 7'/#tA""- t~ 114adJY ;;t 4 ~ 5, Scvcrnlproblcms huve misen Wilh lhe eurrcnt custody order, lInd the Petitioncr is desirous of modi tying thc currenl Order, 6, Spccifically, PClitioncr has hud to scek medicol trcatmcnt for thc partics' minor child who wus diugnoscd with ringwonn by her family physician, 7. Upon infonnution nod bclicf, in uddition to not initially seeking medical trcatmcnt tor the parties' minor child, Respondent has not ensured lhat her daughter maintains proper hygiene and properly nod consistently applies the necessary medication. 8. Petitioner has also been made aware of his daughter's social and educational difficulties at her elementary school. 9. Upon infonnation and belicf, Respondent has not attcnded parcnllteacher \ , I conferences nor made Pctitioner awure of said confcrcnces, and Respondent docs not spend sufficient time with the parties' minor child. J \ , 10. Petitioner desires primary physical cUSlody of the child and joint Icgal custody with periods of visitation to Respondent as can be mutually arranged between the parties. II. The best interests and pennanent welfare of the child requires that the Court grant the Petitioner's request as sel forth above, I I ~ . ,',l, !f . I I I 2 Plalntlff/RBspondent JUl 0 5 2DO' fYA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRETT D. URICH; vs, ANGELA R. URICH, DefendanVPelllloner NO. 98-438 vs, PEGGY AND HARRY URICH, Respondents CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW,this If ~ day of L1~ ,2001, upon consideration of the attached Custody Conciliation S mmary Report, it is hereby ordered and directed as follows: 1. Legal Custody, The parents, Brett D, Urich and Angela R. Urich, shall have shared legal custody of the minor Child, Rebecca E. Urich, born December 24, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, ail decisions regarding her health, education and religion. Pursuant to the terms of Pa. C. S. 9 5309, each parent shall be enlllled to all records and information pertaining 10 the Child including, but not limited to, medical, dental, religious or school records, the reslde(1ce address of the Child and of the other parent. To the extent one parenl has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent wilhin such reasonable lime as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shail have primary physical custody subject to Father's rights of partial physical custody which shall be arranged as follows: A. Each Tuesday and Thursday evening from after work until 7:00 p.m, B, Alternating weekends from Friday after work until Sunday at 7:00 p,m. 3, Christmas. The Christmas holiday shall be divided into Segment A which runs from Christmas Eve at12 Noon until Christmas Day at12 Noon, and Segment B which shail run from Christmas Day at12 Noon until December 26111 at12 Noon, Mother shall have cuslody of the Child for Segment A in even-numbered years and Segment B during odd.numbered years. Father shail have custody of the Child during Segment A in odd-numbered years and during Segmenl B in even-numbered years, No, 98.438 '; 4. thanksgiving, The parties shall alternate having cuslody of the Child on Thanksgiving Day from 9:00 a,m, until 5:00 p,m" with the Father having custody In even. numbered years and the Mother having custody In odd-numbered years, 5, Allernatina Holidays, The parties shall alternate having custody of the Child on specific holidays from 9:00 a,m, until 5:00 p,m, In accordance with the following schedule: A. Mother shall have custody of the Child on Easter Sunday and Independence Day in odd-numbered years and on Memorial Day and Labor Day In even-numbered years, B. Father shall have custody of the Child on Easter Sunday and Independence Day in even-numbered years and on Memorial Day and Labor Day In odd-numbered years, 6. Mother's Dav/Father's Dav, Mother shall have custody of the Child every year on Mother's Day from 9:00 a,m, until 5:00 p.m, Father shall have custody of the Child every year on Father's Day from 9:00 a.m, until 5:00 p,m. 7, Both parties shail be entitled to have custody of the Child during the summer each year for up to two (2) consecutive weeks providing as much advanced notice as possible to the other party. 8. The exchange point for custody sh~1I be the home of the Paternal Grandparents, Peggy and Barry Urich, unless otherwise agreed, 9, TransDortation, In the event that Mother is unable to provide the transportation or that road conditions would make it more reasonable for Father to provide the transportation in his four-wheel-drive vehicle, Father shall provide transportation at the end of his custodial period. It shall also be permissible for the Maternal Grandmother to provide transportation in Ihe event that Mother is not able to do so at the conclusion of Father's custodial period. The transportation for holidays shall be arranged as follows: Mother shail deliver the Child to the Father at the beginning of his holiday custodial time and Father shall provide the transportation home at the conclusion of his custodial holiday time, BY THE COURT, l<clq, [I I,.~'" ((lI~, (J. j, Wesley Oler, a, Dlsl: Brett D, Urich, 616 High St,eet, Enola, PA 17025 Elizabeth A, Hoffman, Esquire, 106 Walnut Street, Harrisburg, PA 17101 "~IJ'" -....,l"':lit, -. In: c:. ..A;,' 1 r-RG'i: r:<~I""rv::I" r I . '. .~~, _~.~IJ In 17;;I,m~ny '",iWt:J1, , i1.!i'S ~,~in ~r mil moo ~~I~ tl'Nl ;za' 01 said CO!ll1lrt C..rikJ"" Pa. rmi ~" ~ dayot-),,:'J . ~."'I '-';'~"< . f7 }1~'(1.~, ~2j. , Prothooctarf BRETT D:URICH; Plaintiff/Respondent JUL 0 5 200' NI\. IN THE COURT OF COMMON PLEAS o'f' CUMBERLAND COUNTY, PENNSYLVANIA vs, ANGELA R, URICH, Defendant/Petitioner NO, 98.438 vs, P~IJGY AND HARRY URICH, Respondents CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, Ihe 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 CURRENTLY IN CUSTODY OF Rebecca E, Urich December,24, 1995 Mother 2. The parties were seen on June 1 S, 2001, for a Custody Conciliation Conference based on Mother's petition to modify the Order of August 9, 2000. In attendance were the Father, Brett D, Urich, pro se; the Mother, Angela R. Urich, and her counsel, Elizabeth Hoffman, Esquire, 3. The parties reached an agreement in the form of an Order as attached. Date 1-/3/0/ I Iissa Peel Greevy, Esquire C stody Conciliator i I , CERTIFICA TE OF SERVICE I, Douglas G. Miller, Esquirc, do hereby ecrtify that I havc served a true and correct copy of the foregoing documcnt upon thc pcrsons indicatcd below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth bclow: ELIZABETH A. HOFFMAN, ESQUIRE 1 06 WALNUT STREET HARRISBURG, PA 17101 ~ ANGELA R, URICH 2001 RED BANK ROAD DOVER, PA 17315 Date: November 27, 2002 IRWIN, McKNIGHT & HUGHES ~ r ~ 'I I- ! ~ i I :! I ! Douglas . iller, squire Supreme ourt J.D. No, 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 i. i i ! ! Attorney for Petitioner, Brett Urich CERTIFICATE OF SERVICE 1 hereby certifY that I havc served a truc and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: ELIZABETH A. HOFFMAN. ESQUIRE I 06 WALNUT STREET HARRISBURG, PA 17101 Date: December 19, 2002 IRWIN, McKNIGHT & HUGHES , ~()f) 'O.jri<fL Tfl(ci D. Smith, Secretary to Douglas G. Miller West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 ANGELA R. URICH 2001 RED BANK ROAD DOVER, PA 17315 ! l n I:;, I.," I I')'. 1<< L , , I " ..,......." ,;;\1 " u:rC':"C: \ ~ :!j: \: Ll Ci;"". . ,.."..,.,..( vl-V.'.~~. .. '.' :'..J,'il PE~~;'~SYt):';" >l:t,\ ~ ,JAN 2 3 2eD3 \y BRETT D, URICH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-438 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY v, ANGELA R. URICH (SULLIVAN), Defendant INTERIM ORDER OF COURT AND NOW, this ~ ~ day of UAlIJl.UVl...Y , 2003, upon consideration of the attached Cuslody Conciliation Summary Report, it Is hereby ordered and directed as follows: 1. Leqal Custodv. The parents, Brett D, Urich and Angela R, Urich (Sullivan), shall have shared legal custody of the minor child, Rebecca E, Urich, born December 24, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of Pa,C,S, ~5309, each parent shall be entitled to all records and Information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational records, attendance records or report cards, Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, child's parties, musical presentations, back-to-school night, and the like, 2. Phvsical Custodv, Mother shall have primary physical custody subject to Father's righls of partial custody which shall be arranged as follows: A. Each weekend from Friday after work until Sunday at 7:00 p.m, 3. Christmas. The Christmas holiday shall be divided into Segment A which runs from Christmas Eve at 12 Noon until Christmas Day at 12 Noon, and Segment B which shall run from Christmas Day at 12 Noon until December 26th at 12 Noon, Mother shall have " 'i " \1, . \ 'f ,. NO, 98-438 CIVIL TERM cuslody of the child for Segment A in even-numbered years and Segment 8 during odd- numbered years. Father shall have custody of the child during Segment A in odd-numbered years and during Segmenl 8 in even-numbered years. 4, Thanksaivina. The parties shall alternate having custody of the child on Thanksgiving Day from 9:00 a,m, until 5:00 p,m,. with the Father having custody in even- numbered years and the Mother having custody in odd-numbered years. 5, Alternatina Hoildavs. The parties shall alternate having custody of the child on specific holidays from 9:00 a,m. until 5:00 p,m. in accordance with the following schedule: A. Mother shall have custody of the child on Easter Sunday and independence Day in odd-numbered years and on Memorial Day and Labor Day in even-numbered years. 8, Father shall have custody of the child on Easter Sunday and Independence Day in even-numbered years and on Memorial Day and Labor Day in odd-numbered years. 6. Mother's Dav/Father's Dav. Mother shall have custody of the child every year on Mother's Day from 9:00 a,m, until 5:00 p,m, Father shall have custody of the child every year on Father's Day from 9:00 a,m. until 5:00 p.m. 7. 80th parties shall be entitled to have custody of the child during the summer each year for up to two (2) consecutive weeks providing as much advanced notice as possible to the other party. 8. The exchange point for custody shall be Karns, unless otherwise agreed. 9. Transportation, In the event that Mother is unable to provide the transportation or that road conditions would make it more reasonable for Father to provide the transportation in his four-wheel-drive vehicle, Father shall provide transportation at the end of his custodial period, It shall also be permissible for the Maternal Grandmother to provide transportation in the event that Mother is not able to do so at the conclusion of Father's custodial period. The transportation for holidays shall be arranged as follows: Mother shall deliver the child to the Father at the beginning of his holiday custodial time and Falher shall provide the transportation home at the conclusion of his custodial holiday time. NO. 98-438 CIVIL TERM 10. In the event that Mother has to work the 2:00 p,m. to 8:00 p,m. shift, she shall first contact Father and provide him with the opportunily to provide care for the child before arranging for or contacting a third party caregiver, 11, Mother shall be obligated to promptly provide Father with copies of the child's report cards, progress reports, and any other educational records which could reasonably be expected to be of interest to a parent. 12. The parties shall submit themselves and their minor child to an independent custody evaluation to be performed by Stanley Schneider, Ed,D. The cost of the evaluation shall be shared 50/50, The parties shall sign all necessary releases and authorizations for the evaluator to obtain medical and psychological information pertaining to the parties and their child, Additionally, the parties shall extend their full cooperation in completing this evaluation in a timely fashion and in the scheduling of appointments. 13, A heari~ is scheduled in Courtroom lumber 1 of the Cumberland County Courthouse, on the tJl dav of Aoril. 2003, at : ~ o'clock A-,M., at which time testimony will b taken. For the purposes of the hearing, the Father, Brett D. Urich. shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro sa shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least ten days prior to the hearing date, E ;~~:;) J, DJsl: ....oouglas G, Mille" Esquire. 60 W, Pomf,elSl,eel. Ca,lisle, PA 17013-3222 ,)'(ngela R, U,lch. 2001 Red Bank Road, Lo1522. Dove,. PA 17315 >r~ cl L -fYlo.3 0 . l..~3 o I . ;;.:7 - 03 , -- JAN 2 3 ZG83 ~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 98438 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY BRETT D. URICH, v, ANGELA R. URICH (SULLIVAN), Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1, The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Rebecca E. Urich December 24,1995 Mother 2. A Custody Conciliation Conference was held on January 7, 2003 pursuant to Father's Petition to modify the Order filed on November 27, 2002, The last Order was entered by an Agreement of the parties on July 9, 2001. Present for the conference were: the Father, Brett D. Urich, and his counsel, Douglas G. Miller, Esquire; the Mother, Angela R. Urich (Sullivan), attended pro se, 3. The parties did not reach an agreement as to the ultimate issue of Father's request to modify the Custody Order providing him with primary physical custody. However, they did reach some agreements with regard to an Interim Order and a custody evaluation. 4. Father's position on custody is as follows: Father would like to receive primary physical custody for the following reasons: The child contracted ringworm last fall and it had spread extensively by the time he knew and took the child to the doctor, He reports that Mother canceled the parent teacher conference and is failing to provide him with report cards and progress information from the school. He reports the child is having problems at school and that the Mother is not spending enough time with the child, He also reports the child has suffered from enuresis at school and in October 2002 that the problem had become so severe that she had sores on the inside of her upper thighs. Father reports that Mother has not shared importanl information with him regarding when the parent teacher conferences are at school. Father acknowledges that he is very uncomfortable with the new stepfather assuming his role, in particular in the areas outside the home, such as in the areas related to education, Falher is engaged and presently living with his fiancee, and her children. Father works for PennDOT and works 7:00 to 3:00, However, at times he is called out to work extra hours because of snow or ice conditions, . -- '- NO, 98-438 CIVIL TERM 5, Mother's position on custody Is os follows: Mothor claims thaI the child should remain in her primary custody and that becouso of tho child's 3chool struggles she should have less time with Father during the school wook. Mothor belloves that It Is Important for the child to have one home to go to do homowork, Mothor roports that she had the child checked by the school nurse who did not Inform hor that tho problem was ringworm. Mother acknowledges the child Is having dlfflculllos In Bchool but that she Is gelling assistance from the instructional support team, In particular In tho area of reading, There Is a reevaluallon of the child's progress going to take place In tho month of January, 2003. Mother plans to inform Father of when this meellng Is to occur so Ihat he may participate, Mother presenlly works for the Pennsylvania Liquor Control Board. In two weeks, she will be assuming a full time position, In this new poslllon, she may be required to work a 2:00 p.m, to 8:00 p.m, shift or a 10:00 a.m. to 6:00 p,m, shift. She expects thaI her work shifts will vary, Mother has remarried and has an 18 month old child to another man. 6, The parties were able to reach some agreemenls with regard to an Interim Order to give Father additional lime over the weekend, However, Father remains very concerned that he not be left out of this child's educallon, The parties acknowledge that the ringworm and enuresis problems appear to have resolved. Fortunately, they are both using one physician's office for the child's medical care. Of concern to the Conciliator Is that these parents need to acquire the ability to have the dialogue with each other wilh regard to the parent business decisions related to Rebecca's care and well-being, Their past patterns of communication have not been very helpful, Unfortunately, their period of separation and the fact that the parties have moved on to new relationships has not assisted the parties to acquire the skills to work together as a cooperative parenting team, Accordingly, a hearing before the Co rt will be needed. This will be precedecr6f8)ustody evaluation. I d-. I) 3> ul!(} -/tf2z &-e--r Date Melissa Peel Greevy, Esquire Custody Conciliator :200117 BRETT D. URICH, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ANGELA R. URICH (SULLIVAN), Respondent : 98-438 CIVIL TERM : IN CUSTODY AND NOW, this ORDER OF COURT ,~ day of ~ , 2003, upon presentation and consideration of the attached stipulation and agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. J , J. . . . ,. . " ,. " !': ~{ <'0; ...:.,"",,,,, #. ~ j' ~ ,') ~ ~ ...l ~ '~ <:f <<1 . , . ,~ ~ ,-./ 1 t ~ t J.<d 1'1" '-L'" " : i,. , :"j: ,;? .,..1:\1.\:., _ !., (,I" '0fi I".. ..,'" -;' i "I\.\), " NOW, TIIERIWORE, in consillcrulion of thc mulual covcnants, promiscs and agrccmcnts as hcreinatlcr scl Iilrlh and inlcnding to hc Icgally hound, Ihe partics herelo agree as follows: I. The parties shall have shared legal cuslody of Rcbccca E, Urich, Each parent shall have an equal right, 10 be exercised jointly with the other parent, to make all non- emergency decisions atTecting the child's general wcll-being including but not limited to, all decisions regarding hcr health, education and religion. Pursuant to the tenns of 23 Pa.C,S, * 5309, each parent shall be entitled to all records and infonnalion pertaining to the child including, but not limited to, medical, dental, religious or school records, and the residence address of the child and of the other parent. To the extent one parent has possession of any such records or infonnation, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and infonnation of reasonable use to the other parent within such reasonable time as to make the records and infonnation of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medicallreatment planning meetings and evaluations with regard to the minor child. Eaeh parent shall be entitled to full and complete infonnation from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational records, attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, child's parties, musical presentations, back-to-school night, and the like, 2. The parties shall have shared physical custody of the minor child which shall be arranged on a week on, week off basis with custody exchanges to take place every Sunday at 7:00 p,m, Father's first week of physical custody of the minor child shall commence on Sunday, February 23, 2003, at 7:00 p.m., and Mother's alternating week of physical custody shall commence on the following Sunday, March 2, 2003, at 7:00 p,m. 3. The Christmas holiday shall be divided into Segment A which runs from Christmas Eve at noon until Christmas Day at 12 noon, and Segment 8 which shall run from Christmas Day at 12 noon until December 26 atl2 noon. Mother shall have custody of the child for Segment A in even-numbered years and Segment B during odd-numbered years. Father shall have custody of the child during Segment A in odd-numbered years and during Segment B in even-numbered years. 4. The parties shall alternate having custody of the child on Thanksgiving Day from 9:00 a,m, until 5:00 p,m, with the Father having custody in even-numbered years and the Mother having custody in odd-numbered years. :2 5. The parties shall alternate having custody of the child on specific holidays from 9:00 a,m. ul1lil 5:00 p,m" unless said holiday shall filII on the Sunday in which that party otherwise has custody in which case pursuant to Paragraph Two (2) the custody exchange shall be at 7:00 p.m., in accordance with thc following schedulc: A. Mothcr shall havc custody of the child on Easter Sunday and Independence Day in odd-numbered years and on Memorial Day and Labor Day in even- numbered years, B, Father shall have custody of thc child on Easter Sunday and Independence Day in cven-numbered years and on Memorial Day and Labor Day in odd- numbered years. 6. Mother shall have custody of the child every year on Mother's Day from 9:00 a,m. until 5:00 p,m" unless said holiday shall fall on the Sunday in which Mother otherwise has custody in which case pursuant to Paragraph Two (2) the custody exchange shall be at 7:00 p.m, Father shall have custody of the child every year on Father's Day from 9:00 a.m. until 5:00 p,m., unless said holiday shall fall on the Sunday in which Father otherwise has custody in which ense pursuant to Paragraph Two (2) the custody exchange shall be at 7:00 p,m. 7. Both parties shall be entitled to have custody of the child during the summer each year for up to two (2) consecutive weeks providing as much advanced notice as possible to the other party. 8. agreed, The exchange point for custody shall be Karns grocery store, unless otherwise 9. The parties agree to share transportation for the custody exchanges, It shall be permissible for the maternal grandmother to provide transportation in the event that Mother is not able to do so. 10, Mother shall be obligated to promptly provide Father with copies of the child's report cards, progress reports and any other educational records which could reasonably be expected to be of interest to a parent. 11. The parties will keep each other advised immediately relative to any emergencies concerning the minor child and shall, further, take any necessary steps to ensure that the health and well being of the child is protected, During such illness or medical emergency, each party shall have the right to visit the child ns often as he/she deems consistent with the proper medical care of the child, 12, The parties agree that there shall be reasonable telephone contact with the child during the periods when the child is not in the custody of that party. 3 13. The parties ugree thut they will alternate claiming the minor child as a tax exemption on all applicable federal, state and local tax returns, which shall include the right to claim the child tax credit on the federal tax return, Father will claim child in even-numbered years, beginning with tax year 2002, and Mother will claim the child in odd-numbered years, beginning with tax year 2003, The parties agree to sign any applicable waivers or other documents which may be necessary or prudent to effectuate the above, 14. Neither party shall do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love or affection for the other party, 15. It shall be the obligation of each parent to make the child available to the other in accordance with the physical custody schedule and to encourage them to participate in the plan hereby agreed and ordered. 16. Neither party shall remove the child from the Commonwealth of Pennsylvania except for vacations when said party has custody of the minor child as provided herein, Each parent agrees to infonn the other parent if he or she desires to remove the child from the Commonwealth of Pennsylvania by providing notice at least seven (7) calendar days prior to the anticipated date of departure. In such an instance, the party who desires to remove the child shall provide the other parent with a general schedule of the planned vacation and its location or locations, along with a telephone number or numbers, including area code, where the child may be reached, 17. The parties desire that this Stipulation and Agreement be made an Order of Court by the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child, and shall retain such jurisdiction should circumstances change and either party desires or requires modification of said Order, 18. The parties may temporarily alter the schedule of physical custody as is mutually agreeable in order to accommodate special family events or other changes in their schedule. If the parties cannot agree on any such changes, the tenns and provisions of this Order shall control. 19. Any pennanent modification or waiver of the provisions of this agreement must be in writing and shall be effective only ifmade in writing and executed with the same fonnality as this Stipulation and Agreement. 20. The parties acknowledge that entering into this Stipulation and Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of either party. 4 '- \ll f::; .)- f~ - :<. t.l.l ( (~ ).'~' " .. J."::'! fi~ '. '.' ~1. ,. L... " ::J " C' I:', ,'- , II) U <" . h' , . u..: (.... '~.i "' .n I . :.1:. ;J.. IJ. U ''''J :.:J (.:.J C)