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1.1.11I 1M
KIMBERLY ANN RAUDABAUGH,
Plaintiff
IN THE COURT OF COMMON Pl,EAS or
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 98-1241
NEAL RAY RAUDABAUGH,
Defendant
CIVIL ACTION - DIVORCE
ORDlilR
AND NOW, this
-u
day of
\Air>
1J ~ f;,>L.-.,
, 1999, the
property settlement agreement between the parties dated May 27, 1999,
and attached hereto is hereby incorporated into the Decree in Di vor'ce.
BY THE COURT:" .'
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SAlOIS.
SHUFF &
MAS LAND
A11'OIHEYSIAT'I.AW
26 W. "ISh SIr..1
Culllle, PA
(,,) The part:!",,, are t;he O'Nners of a ~'500.00 CertifJ.cilte
of lJepos:i t. Husbarld 8grees t.o releafle any and ill. I. interest.
that he' may havE,' in any cert.:Ui<:;ates of deposit, which may be
in the names of t'h~) parti0s' children, that Upon maturity, the
money will be split nqually between the partIes' children.
(6) Each party reU nquishos any right, title and .interest
he or she may have, t.o any and aU mot.o.r vE:hicJes currently In
pOSSet's:~on (]f U'f' other party incl ucling Husband te, ke0p the
1985 CflryslEH' [,ase) and the :I yn Hitsubishi I,~cl:l ps, and wife to
keep the 1990 Chevlo1et Lumina.
I,ach party sha.l J e;<ecute nTlY
documents necessary to have said vehicles proper.ly registered
in the otht':r party's name with the Pennsylvania Department of
TranspOl'l~ation. Each party shnll aSSIHn" fulJ. responsibility of
any encumbrance on the motor vehicle receiv8d by said party,
and shalJ. ho.ld hill.lOleo:" and inclemni fy the other: party from any
loss there,i,n.
('I) .1'h,,,, pan: les hereto mutually agroe thi'lt they have
effected a satisfactory division of the furniturA, househo.ld
furnishings, appliances, tools and other household personal
property between them, and they mutually agree that each party
shall from and after the date hereof be the sole and separate
owner of all such property presently in his or her possession
whether said property was heretofore own0C! jointly or
indiVidually by tho parties hereto. Wif0 shall pay to Husband
the sum of $500.00 which repre8Bnts the value of the washer,
dryer and refrigorAtor.
(9) Each party hereby relInquishes any right, title or
at 2:00p.m. Wifo Rhall have the firot period in 1999 and
sUbsequent odd numberBd years, and Husband having the year
2000 and s'.lbsp.quent E-)V0n numbered years.
(dl 1\ nil. nim,un of two non-consecutiVe weekH
visltal:ion r.lllr:J.ng tho Sl.Imm<.'r \vHh not~Ice t.o wtfe on or
b"Jfon, Harch I,,:t~ of ,'!aoh .yoar.
(0) in the event of inclement weather Whereby theta
\vou.loj b,' no '~cll')o t, ;':"ld ell 'y :;(1)001 moa ~;IlJ.'["d 1".01.'1 days, tho
parties \vlU disCI1SS tho aval.1abil.1t:y of Hl1E.b.'lnd to haVe;
phys.lca.l CUt;t.ody at that t..lme.. and if ho Is Unc\vai.lable,
then wl.fe will be responsible tor alternat.e arrangements.
(10) Husband aqT(lBS 1:0 PilY Wife tho sum of .~;475.00 per
mont.h for the benefit of the mlaor chIldren. The parties shall
share equally .In any day care oosts. Wife wtll cover childJ.en
under he:..- ~1aJor fvk'c!:ical o.c oqui.va lent. COverage "n(1 de'nt.a1.
covr,'rage. The p,~rt:i.,=s shal I Shein, equally ally
unre:i.mbursed/uninDurea medica t and Jent'al eXpensf=S.
Partios agr(1e that J n the ewent of a mat(,rJal chan!]e of
ci.rcumstances by e.i.thex party, t.hE' amount. of child SUpport w.iJ.l
be recal.culal:ed 1:0 reflE1ct such a chanqe of cJ.rcurnstances, and
if t.hE1 parties are unablo to agreo, either part:'( will be <Ible
SAlOIS.
SHUFF &
MAS LAND
^1TORNP."'AT'LA~
26 W. IIISh Sir..,
Carll.I" PA
to have an order enforced through the Dff.lne of the Domestic
Relations 1n and for: Cumb(-!I'lclnd or any other COunty of
appropriate j~J.l.sdict.lon.
(11) The pd.rUes agnoe thai' WUe shall be .:1l1owed to tilk0
out a life Insurance policy on HUSband, and Hl\~hand agrel'ls (:,)
cooperate with v:t'Jdl.8V("rIS nOC',oJsary .in order to ('[fect.Ili1t;1
SAlOIS.
SHUFF &
MASLAND
ATTOItNltYSt,\,TfLAW
16 W. IIISh SIr..1
Cull.I" P^
or)liqatlonB fletCh pltt'ty IIOW 1\r.l~1, or m~IY hfl['OClftet hav~'1
agidflst or with re;JpecL to l ho other.
(20) Th:!s Agrooment shall be construed under the law of
the Commoml€1alth of Pennsylvilniil. l( any p.rov:IEdo,", of thif~
AgreBmont is detarm:!ned to bBinv~lid or unenfOrceable, al.l
oLhf;r' provis.lon,' iJhd'l..l conUnue lit full (orce and'effect.
(2 \ I ] II l.l", ovnr,t thilt '.,.1 thr"r of the partiefl shc"ll recovpr
il fine,] :iudqment :)1 Ck'LT"'O of' ak,e;,.llll.(' dl.vOl'ce ,.qCl.ln~.t the
ether: in 2\ c()urt \)1: l:'ornp(;teTlt ','!ur1.:::;dicti')n, the ~)ro'JisLoI15 of
this Aqra'Jln8nt may bo incorporat.od by referenco or in subEltance
but sha.Ll. not be merged Into sllch 'judgment or docree and t.his
lICjrc,...'wenl iJh,'lll survive any ;;lIch final judqment. e>r decree of
absolutE: divorce and shall be r,nUrE:] y :!ndropendent. therer)f.
(?d In the event. t\1at eit.her par.ty b1'E,achofj any provision
of this l\iJu,ument., and th8 othr~.r part.y teta:lns counsel to
as.s.1.st. in enforcing the t.erms t~ereof, the parti~s hereby agrEe
that the breaching party will pay ail attorney's fees, cault
cost.s and eKpenses incurred by t.he other party in enforcing the
Aej reemc.n t .
(231 This Agreement constit.utes the entire understanding
betW0en the parties and t.here are no covenants, conditions,
repnosent.a\ .ions, c,r agreements, oral or wr:!t.t.en, of any net t,lll,'
whatsoever, other than those herein contained.
(24) '['hi" J\greuw('nt shall bind the parties hereto, their
reSr)8(~t:j.ve heJ.'rs, 8Xe(:\lt:ors and assigns.
IN WI'l'NI':~';S WIIl~[\E:(lF', the parties hereto Lntending to be
leqaIly bo\1i',cI halle! hereunt..o set. their h<'lndr; i'\nd seals the day
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KIMBERLY ANN RAUDABAUGH,
Plaintif f
I IN THE COURT OF COI1MON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 98 - \dLI\
CIVIL TERM
NEAL RAY RAUDABAUGH,
Defendant
I CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHT~
You have been sued in court. If you wish to defend against the
claim!;; set forth in the following pages, you must take prompt action.
You are warned that if you fail to do so, the case may proceed without
you and a Decree of Divorce or annulment may be entered against you by
the Court. A judgment may alBo be entered against you for any other
claim or relief requested in these papers by the plaintiff. You may
lose money or property or other rights important to you, including
custody or visitation of your children.
When t.he ground for the divorce is indi.gnities or irretrievable
breakdown of the marriage, you may request marriage counseling. A
list of marriage counselors is available in the Office of the
Prothonotary at the Cun~erland County Courthouse, Carlisle, PA 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
Cumberland County Bar Association
2 Libertv Avenue
Carlisle, PA 17013
Telephone: (717\ 249-316~
tl \div\3lQ 1 (0) . Clom
KIMBERLY ANN RAUDABAUGH,
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. q ~'- I d lj \
NEAL RAY RAUDABAUGH,
Defendant
CIVIL ACTION LAW
IN DIVORCE
COMPLA~NT UNDER S3301(c) OR S3301(dl
OF TilE DIVORCE CODE
1. The Plaintiff in this action is KIMBERLY ANN RAUDABAUGH, an
adult individual, who currently resides at 1105 Coppercreek Drive,
Mechanicsburg, Pennsylvania 17055.
2. The Defendant. in this action is NEAL RAY RArJDABAUGH, an adult
individual, who currently resides at 1105 Coppercreek Dri.ve,
Mechanicsburg, Pennsylvania 17055.
3. Both the Plaint.iff and the Defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this complaint.
4. The Plaintiff and Defendant were lawfully joined in marriage
on October 17, 1987, in Carlisle, Pennsylvania.
5. There have been no prio,: actions of divorce or for annulment
between the parties hereto in this or any other jurisdiction.
6. The Plaintiff avers as the grounds upon which this aotion is
based is that the marriage between the parties hereto is irretrievably
broken and/or the parties have been separated for a period of two
years.
-1-
7. Neither party is in the Armed Services of the united States,
or its allies.
a. The Plaintiff avers that two children have been born of this
marriage.
9. The Plaintiff has been advised that counseling is available
and that the Plaintiff may have the right to request that the court
require the parties to participate in counseling.
WHEREFORE, Plaintiff prays that a Decree be entered divorc-
ing the said Plaintiff, Kimberly Ann Raudabaugh, and the Defendant,
Neal Ray Raudabaugh, from the bounds of matrimony heretofore contract-
ed between them.
COUNT I - ALIMONY AND ALIMONY PENDENTE LITE
10. The prior paragraphs of this complaint are incorporated
herein by reference thereto.
11. The plaintiff, Kimberly A. Raudabaugh, date of birth May 14,
1966, currently lives at 1105 Coppercreek Drive, Cumberland County,
Mechanicsburg, Pennsylvania 17055. ~he defendant, Neal R.
Raudabaugh, date of birth February a, 1964, currently resides at 1105
Coppercreek Drive, Cumberland County, Mechanicsburg, Cumberland
County, Pennsylvania 17055.
12. The plaintiff, Kimberly A. Raudabaugh, requires reasonable
support and alimony to adequately maintain herself in accordance with
the standard of living established during the marriage.
WHEREFORE, the plaintiff, Kimberly A. Raudabaugh, requests
the Court to allow alimony and alimony pendente lite as it deems
-2-
reasonable pursuant to Sections 3701 and 3702 of the Pennsylvania
Divorce Act.
COUNT II - REQUEST FOR EQUITABLE DISTRI8UTION
OF MARITAL PROPERTY UNDER
SECTION 3502(a) OF THE DIVORCE CODE
13. The prior paragraphs of this complaint are incorporated
herein by reference thereto.
14. The plaintiff and defendant have acquired property both real
and personal during their marriage until the date of their aeparation.
15. The plaintiff and defendant have been unable to agree as to
an equitable distribution of said property.
WHEREFORE, plaintiff prays for the entry of an order dis-
tributing all the aforementioned property real and personal as the
Court may deem equitable and just plus costs.
-3-
"'W'(1iillill"~.' ~l/m,Iji<w>Y~*\~'tjfll~"'W'I\!i ilKf'~"\\
;'~, ". 't"., ',:,~2l)l~~:~'l'~~j~~!;'I';:VqiM::~wEt:~t?~;~L.}Ji:(~~ ',.
KIMBERLY ANN RAUDABAUGH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 98-1241
CIVIL TERM
NEAL RAY RAUDABAUGH,
Defendant
I CIVIL ACTION - IN DIVORCE
AFFIDA vrr OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
) SS:
COUNTY OF CUMBERLAND )
I, ELIZABETH B. STONE, of Stone LaFaver & Stone, attorneys for
the plaintiff hereby certify that I served the Complaint in Divoroe in
the above captioned matter on the defendant, Neal Ray Raudabaugh, at
1105 Copperoreek Drive, Mechanicsburg, PA 17055, by united States
Certified Mail, postage prepaid, restricted delivery, on Maroh 11,
1998, as evidenoed by the attached Certified Mail return'receipts.
)
SWORN TO AND SUBSCRIBED
bef~re me thls /:~'if) day
of !J1/>M'~ , 1998.
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RICHARD A. BALLENT,
Plaintiff
vs.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 18 /,2L/{" (h tiLr__,
KATHY DICK,
Defendant
CIVIL ACTION - AT LAW
CUSTODY
ORDER OF COURT
AND NOW, t hi s -.-.;.:..;Jill (F';
, upon oonsideL'ation of the
attaohed oomplaint, it is hereby directed that the parties and
'their respective oounsel appear beforel-1\v...J\.~) \. "I f\~4,
the oonciliator, at -:"] ~, \'\(\\i\ \\, Hn \'inl\.\hlCjJ1\ , on
the _\ S day of ~(\ \ 199B, at q DD-A...M., for
a Prehearing Custody Conferenoe. At suoh oonferenoe, an effort
will be made to resolve the issues in dispute; or if this oannot be
acoomplished, to define and narrow the issues to be heard by the
court, and to enter into a temporary order. Either party may bring
the ohild who is the subjeot of this oustody action t.o the
conferenoe, but the ohild/chi.ldren's attendanoe is not mandatory.
Failure to appear at the oonferenoe may provide grounds for entry
of a temporary or permanent order.
FOR THE COURT:
By I d\~~\'iR sllllJ.rv\(Jp).. ItN~_
Custody Conciliator ,_ (\b~
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A lAWYER OR CJ\NNOT AFFORD ONE, GO TO OR 'l'ELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE, PA 17013
(717)249-3166
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RICHARD A. BALLENT,
Plaintiff
IN 'l'HE COURT O[~ COMMON PLEAS OF'
CUMBERLAND COUN'I'Y, I'ENNSYI,vANIA
vs.
No. /11:' '1,/", ('f(i~ (It', to<
KATHY DICK,
Defendant
CIVIl, AC'I'ION - A'l' I,AW
CUS'f'ODY
!;OMPLAIN'f FOR CI1STOPV
The Plaintiff, RICHARD A. BAI.L~iN'f, through hill attorneys, The
Law Offices of Patrick F. Lauer, Jr., files this Complaint for
Custody against the Defendant, KA'I'HY DICK, and in support thereof,
avers the following:
1. The Plaintiff is RICHARD A. BAI.LENT, an adult individual
and the natural Father, who currently resi.des at 82 Linda Drive,
Lot 54, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant is KATHY DICK, an adult individual and the
natural Mother, who currently resides at 50 F'airview Street,
Carlisle, Cumberland County, Pennsylvania 17013.
J. The Plaintiff seeks custody, partial custody, and/or
visitation of the following child I
fu\!n.fl
~llent AdiU:.~
~
Joehua A. Dick
50 Fairview Street
CarHslo, PA 17013
The child was born out of wedlock.
1 month
(DOB 02117/98)
4.
The child is presently in tho custody of KATHY DICK, who
currently resides at 50 Fllirviow Street, Carlisle, Cumberland
County, Pennsylvania 17013.
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11. The bent intet'fl8ty I.nd flUIIIIIlIlt3nt. welfllre of the ohild
will be served by gnlntl.rl(j UIU rflll~1f' (fHllleot.lId beoauaer
a). The Pl.'lillt.l "f Olin pl"vl(li~ UIfl ohUd with a home
with adequat.e mond, fllllot i.OIlIlI, IUIl.1 pl!yaIol.\.l Yllrroundings
liS required to meet tho Ilh 11 II' n noulln I
b). The PlaintIff 10 wIllIng to oont.Inue ountody of
the ohild I
c). '1'he PlalntJfI' tlontInnon to exeroiae parental
duties and enjoys tho love /llld /lffeation of the ohild.
12. Eaoh pat'ent WhoDe pat'Olltll] IIghto to the child have not
been terminated and tho Plll'OOIl who haa physical custody of the
ohildren havo beell naffiod 110 partioD to this aotion. All other
persons, named below, who a'co known to have or claim a right to
custody or vls1.lation of' t.he ohUdr'en will be given notice of the
pendenoy of th1.o aoHon and the right to intervene: NONE.
WHEREFORE, the Plaint1.f'f respectfully requeots that this
Honorable Court enter an Order granting custody, partial custody,
or visitation of the ohild to the Petitioner and natural Father,
RICHARD A. BALI,ENT, in aooordanoe with any Stipulation of the
partieo, or in the event the parties are unable to execute such a
Stipulat~on, to enter an Order granting oustody, partial oustody,
or visitation of the ohild to the Petitioner.
Respeotfully SUbmitted,
Date I ~31/~/ct()
1 !) . , "
/ }l11 i (.)\ ( l'L_~----.
--...,-------
M4ttheW(I. EShelman, Esquire
~108 Market Street, Azteo Building
Camp Hill, Pennsylvania 17011-4706
10' 72655 Tel. (717) 763-1800
Lauren Raudabaugh, (hereinafter referred to as "Paige"), born on .July 15, 1992, Joint
legal custody means the right of both parents to control and to share in making decisions
of importance of the lives of their children, including educational. medical and religious
decisions, Each parent shall have afl equal right, to be exercised jointly with the other
parent, to make all major non-emergency decisions affecting the children's general well-
beillg, including, but not limited to, all decisions regarding their health, education and
religious training, Each parent shall be entitled to access to all records and information
pertaining to the children, including, but not limited to, medical, dental, religious or school
records, To the extent that 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. Each parent shall be responsible to inform the other on a timely basis of
any information relating to the children which could reasonably be expected to be of
interest to a parent, including information relating to illness of a child rendering them
unable to attend school or other planned activities and notice of any medical, dental,
optical, counseling or other appointments for a child with healthcare providers, sufficiently
in advance thereof so that the other party can attend if he or she so chooses, Non-major
decisions involving a child's day-to-day living shall be made by the parent then having
custody, consistent with the other provisions of this Order,
B. Emergency medical decisions regarding the children shall be made by the
parent then having physical custody, but that parent shall communicate to the other parent
the nature and extent of the emergency and will provide that other parent with all
-2-
Information pertaining to the treatment so that the other parent may be involved in the
decision-making process at the earliest possible time,
C. In the event that a significant matter arises with respect to the medical care,
education or financial care of the children such as a change in occupation, health
insurance, educational expenses or residence of a party, such matters will be discussed
by both parties before either party makes any change,
D. Each party will confer with the other on all matters of importance relating to the
children's health, maintenance and education with a view towards obtaining and following
a harmonious policy in the children's education and social adjustments, Each party
agrees to keep the other informed of his or her residence and telephone number to
facilitate communication concerning the welfare of the children and the custodial
arrangements, Each party shall provide the name, address and phone numbers of any
persons of whose care the children will be for a period in excess of 72 hours and for each
person or entity which may provide daycare for the children, excluding current daycare
providers, relatives or public school institutions,
E. The welfare and convenience of the children shall be the prime consideration of
the parties in any application of the provisions of this Order, Both parents are directed to
listen carefully and consider the wishes of the childr3n in addressing the custodial
sohedule, any changes to the schedule and any other parenting issues,
-3-
'.
JLe!:IY.SICAL CUS1'ODY
A. Primary Custody: Father shall have primary physical custody of Neal, subject
to the Mother's periods of partial physical custody as agrC:led by the parties hereto or at
such times as requested by Neal, Commencing August 1, 2005, Mother shall have
primary physical custody of Paige, subject to Father's schedule of partial physical custody
as agreed by the parties hereto or at sllch times as requested by Paige,
a. Notification of Travel Plans: In the event that either party is planning to take
one or both of the children out of this Court's jurisdiction and more specifically out of the
Commonwealth of Pennsylvania, that party must provide at least 10 days' advance notice
to the other parent, including contact information for the locations at which the
child/children will be staying,
C. TransDortation: Transportation for custody purposes shall be divided by the
parties as equally as possible, In the event that there Is no specific provision or
agreement governing custody exchanges, the parent who is to receive custody at the time
of the exchange shall provide for transportation from the residence of the other parent. At
all times, the children shall be secured In appropriate passenger restraints, No person
transporting the children shall consume alcoholic beverages prior to transporting them or
be under the influence of any alcoholic beverages while transporting them, Neither shall
drink alcoholic beverages to the point of intoxication when either or both of the children are
in their custody,
.4.
"
D. Forfeiture of Partial Custody: In the event that a party who is scheduled to
have a period of partial custody with the child in the other parent's primary physical
custody is more than 30 minutes late for a custody exchange, in the absence of a
telephone call or other communication from that party, the party with primary custody of
that child may assume that the parent who is late has chosen not to exercise that period of
partial custody, the period will be forfeited, and the party with primary custody of that child
will be free to make other plans with the child,
E. Children's Activities:
1. To the extent possible, each party shall provide the other with at least
48 hours' advance notice of school, sporting or extra-curricular
activities, Both parties shall honor and participate in the activities in
which the children wish to engage, The parent having custody of a
child at the time of any scheduled extra-curricular activities will make
certain that the child attends those activities in timely fashion, The
parties will be supportive of <'II activities and will transport the children
to and from such activities and the preparation and practices as are
scheduled in sufficient time so that the children are able to participate
In those events,
2. Neither parent shall commit the children to any activity unless the
children definitely desire to attend that activity, Participation in activities
.5.
that take place during the school year is contingent upon that child
maintaining passing grades in school,
3. Neither parent shall commit the children to activities requiring
participation during the other parent's periods of custody without the
consent of the other parent, which consent shall not be unreasonably
withheld, If either of the children is Involved in an activity which occurs
during both parent's periods of custody, both parents shall cooperate in
providing transportation to the activity, Notwithstanding, the parent
then having custody shall not be required to make the child or children
available to participate in that activity if that parent and the child or
children are out of town at that time for a previously-scheduled
vacation,
4. In the event the parent then having custody Is unable to deliver the
child or children to a particular activity, the parent who has custody
shall notify the other parent, who shall be entitled to pick up and deliver
the child or children to the deSignated activity, The parent having
custody at that time shall make certain that the children are ready for
pick up in time sufficient to enable them to timely attend the activity,
6. In the event that a parent elects not to take a child or children to a
defined activity period occurring during his/her custody period on two
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'.
occasions, the other parent shall have the right to assume that he or
she will be responsible for transporting the child or children to that
activity until appropriate transportation Is provided,
F. Teleph.one Contact: Both parties will use common sense in scheduling
. telephone calls to talk to the children, Neither the parties nor their spouses/significant
others will prevent the parent who is calling from talking to the children or prevent the
children from calling the other parent, provided that the phone calls are not excessively
frequent or too long in duration as to disrupt the children's schedule or interfere with the
period of custody then baing exercised,
G. Mutual ResDepj: Each of the parties and any third party in the presence of the
children shall take all reasonable measures to foster a feeling of affection between the
children and the other parent. Neither party shall do nor permit any third person to do or
say anything which may estrange the children from the other parent, their
spouse/significant other, or relatives, or which may injure the children's opinion of the
other party, or which may hamper the free and natural development of the children's love,
affection and respect for the other parent. The parties shall not use the children to convey
verbal messages to the other parent about the custody situation or changes in the custody
schedule,
H. ~flcatlo.n: The parties shall be at liberty to modify the custodial schedule
herein provided to accommodate their respective schedules and special events, provided
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"
that any such modifications are made by mutual agreement of the parties, Any major
long-term modifications of this Order must be In writing agreed to by both parties, and
executed with the same formality as the Stipulation of the Parties filed herein agreeing to
the entry of this Order, Minor or short-term change!> can be made orally if agreed upon by
both parties, In the event that either party is not in agreement with a proposed change,
this Order shall control the custodial arrangement until such time the parties are able to
agree or this Order Is modified by the Court following hearing './ ',.. /
// /
//'
J,
Distribution To:
TTORNEY FOR PLAINTIFF:
Constance p, Brunt, Esquire
Beaufort Professional Center
1820 Llnglestown Road
Harrisburg, PA 17110-3339
FENDANT PRO SE:
NealR,Raudabaugh
2 Jenny Drive
Boiling Springs, PA 17007
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