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IHCIIARD II. III1LLEN'I',
Plaintiff
IN 'I'lli': mlJH'I' (ii- ce~'lr'I(JN PLEIIS 01"
CUMB~:H[,IIND CeXIN'I'I', 1'1':NNSYI,VIINIII
vs.
NO. 9El-1246 CIVIL 'mRM
KA'I'HI' DICK,
CIVIL IIC'I'ION - l.IIW
CUSTODY
Defendant
amF.R 01' CXXJR'1'
IINIJ~, this 7.2.,dclay of ___~("~(~~_______, 1998, upon
consideration of the at.tached Custody Conci. iation HeIX)I:I'" it is ordered
and directed ilS follows:
1. '1'he ["ather, Hichard II. l3allent, and the ~Iother, Kathy Dick,
shall have shared legal custody of Joshua II. Dick, born February 17, 1998.
Each parent shall have an equal right, to be exercised jointly with the
othElLo parent, to make all major non-emergency decisions affecting the
Child's general well-being including / but not limited to, all decisions
regarding his health, education and religIon.
2. 'l'he Mother shall have pr:imary ptlysical cLlstody of the Child.
3. The .'ather shall have periods of superviSed visitation with
the Child at an agency selected by agreement of the parties and counsel.
The part.ies agree to follow the recommendations of the supervising agency
with respect to initial and ongoing custody arrangements as well as
recommendations reg~rding the advisability of parenting classes for either
or both part.ies. The Father shall be responsible to pay 60%, and the
Mother shall be responsible to pay 40% of the costs charged by the
supervising agency. The parties shall cooperate in selecting the
supervising agency and ini. tiating contact between the Father and the Child
as soon as possible.
4. 'rhe Father may initiate telephone contact with the Mother at
reasonable times as necessary to discuss custody ar:rangernents for the
Child, selecti.on of a supervising agency under this order and other
i~rtant issues related solely to the Child's best interests.
5. 'I'his Order
Conciliation Conference.
Order by mutual consent.
this Order shall control.
is entered pursuant to an agr:eement at a Custody
'rhe parties may modify the provisions of this
In the absence of mutual consent, the terms of
BY nm COUHT,
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Gerald S. Hobinson, Esquire - Counsel for Mother
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RICHARD A. flALLENT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 98 - 1246
Vs.
KATHY DICK,
Defendant
CIVIL ACTION - AT LAW
CUS'l'ODY
I AND NOW, this _ _ll)~~DI~~,~F
I attached complaint, it is hereby
I, their respective counsel
COURT
, upon consideration of the
the conciliator, at
directed that the parties and
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appear before ..\ \'J' \ ~, " ':LL\\_I)L4"
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r, , \ \i I,. \ \,' \ Iii \ 1 I,i \ i \ '-rJL\ on
'-,'\ '\'k'\"'( 1998, at (f' II') I\.M., for
,
thp.
\ ___ day of
a Prehearing Custody Conference. At such conference, an effort
will be made to resolve the issues in dispute i 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. Either party may bring
the child who i.s the subject of this oustody action to the
I conference, but the Child/Children's attendance is not mandatory.
Failure to appear at the conference may provide grounds for entry
IOf a temporary or permanent order.
FOR THE COURT:
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, By : \ J(\ '
I Custody Conciliator i
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!/ YOU SHOULD 'l'AJ{E THIS PAPER TO YOUR LAWYER A'l' ONCE. IF YOU DO NOT
,HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TEI~PHONE THE OFFICE
I SET FORTH BELOW TO F'IND OUT WHERE YOU CAN GET LEGAL HELP.
I
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
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I am . g in response t ' y
beg! . g from the time
total of enty-four supe s'
March ,2000. A total 0 ei
three of mch were cane
Richar s part. These visl
weekly asis. I
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The eight visits were fa' ar#ychaotic during the first fifteen minutes because
Joshua lad not yet begWlltO II!! bond witli"IUehard. .Joshua would roD into a comer
and b to Cl}' for mom. Ri 'uP, ~ot4d standardly attempt to sooth~ Joshua's crying
and he auld eventually J:le c~Ul. Mer the fifteen minutes of crymg, Josh would
begin p a~ng with the to~ cl Bup stuffed animals that he eventually grew very fond of
playing With. i I I' ' ,
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As the '. sits went on, the ~t, ' ~,fifteJn m~utes of crying slowly decreased into
wimp and then ceased~lt er tIS Joshua became more and more comfortable with
Ri . Joshua was alw~ys happy and laughed a lot during the visits, even during
~e e'er ones. ,He nevefl!'. ,h~l~nt t(jg~t into Richard's space, as long as it was
bewh chose to do it. Htfl n :ersc~ ofRichardandln fact, seemed more afraid
afme an him, At one win ,ng tije progrl'.sslon of the visits, there was a time that
Joshu would begin to wtu I r , hen his Gr~dparents left, but would immediately
stop 0 ce Rich&rd enter~, ro '
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Richar~'s behavior also ~o i s', ely b~c.ame more and more patient and
unde~dlng over the cj> , , 0 the v1~lts, He began to ask for recommendations for
books to read on the stages: ,c d deveIopement and educational games that would
help ~ teach Joshua b,si~' tha~ every child must leanl. He also became very
concerned with the fact tpat' s uaWliS nl'.arly two years old and still did not say any
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Thomas TO\lI1C. MF.d
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r : I1e8t~or a brief summary of our role In this ~e
yi8lts picked. back up in fall of 1999. 1 have done a
vi ,at.iorls be~ng on August 20, 1999 and ending on
t 't'Iltibns were cancelled during this time period,
y er Works~ Inc. due to financial difficulties on
e 'ch one hoUr in dW'lltion and were scheduled on a
PLAINTIFF'.s
EXHIBIT
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, , ,\fords Vx dearly, which IS.: w~ p. ~ptM the:requests for books on stages in child
, de\'e1ope cnt. Ii '
Problem were not scen d . e visitations, ~ut rather dwing the transitions
between oshua's Grandp , Ji(c~. The Dick family has always seemed
~mel unsuportive oft ta ~ il:I1d I111'de many accusations ofRlchard ~g
to dr , moleste, and ab , a !lPJj1ng the visitations. None of these accusations
have eve been proven to b ' . have hever jwitnessed Richard either physically or
verbally busing Joshua. e CI tion of Richard trying to drown Joshua, for
example! has to be false dub t e c\$ that Rlbhard never took Joshua out of the
visltaUoj room without mt 4, th. the~ is n~ tub In the room.
The r10nBhiP between iic,' d lndl~.S son,; ,Joshua, could easily develope into a
nonnal nd healthy one, but I' 0 dc,t ~~eve tliat it can happen in such a tense
enviro ent. Cathy and "Ie deed to hawl co-parenting coUllsellng, but as 1 recall,
we tried that the first tlme!th ,e ~eie in 1998 and it was extremely unsuccessful
-""ft p...... In""!;, eel' ed mpre in~erestcd in making the other side look bad
than act y working out th pr lems with;each other and moving forward on
Joshua' behalf. COWlBellbG x, el{ impclrtant in this case because of the level of
hosUUt' towards either side: th' eaoresolve the conflicts. r firmly believe that
supervided visitations shoUld . , expedientiy thereafter due to the fact that Richard
and Joshua have not seen lea oerfot< an extended period of time. However, there
should ~ot be fluctuations in c coining In and out of ,Joshua's life and therefore
Rlchar1needs to be a pe"fat1 t, arto~ JoshUa's life.
nle visllaUons were ended,', " af'" 2~OO dl1e to Richard's move to South Carolina
and thelscheduling probl~ t ensu~ fro~ it. No attempts have been made by
either ~d~ to schedule anr a nnlpce ~Y. 2000, which is also the last time that I
spoke ti eIther party. ,: I : · ': ,
Please e advised that OW;l , e ~as m~ed. lhe new address is 4335A North Front
Street HtJM<isburg,17IUO Hyou have any more questions or need further
explain Uon of any porti$ 0 it'SIiD1.thary, 1 can be contacted at the number provided
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TOTAL P, 133
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Richard Ballent,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION- LAW
IN CUSTODY
Kathy Dick,
Defendant/Respondent
NO, 98-l24b
O;RTIFICATE OF S~:RVICE
J, Andrew 1. Morrow, Certified Legallnlern, Family Law Clinic, hereby eeliify that 1 am
serving a true and eoneel copy of the Return of Service of lhe Subpoena on Gerald Robinson,
Esquire, of Robinson and Gemldo, located at 1',0, Box 5320, Harrisburg, Dauphin Counly,
Pennsylvania, 17110, by dropping a copy of the same this 15th day of November 2000, by
United States, first class mai I.
Date -Ll/J.sftD
__Clh ,~. ill i ) l'IA~ I !(~
Andrew j, onow
Celii fied Legal !tHelll
THE FAMILY LAW CLINIC
45 N0I1h Pill Street
Carlisle,PA 17013
(717) 243-2968
Fax: 243-3639
Counsel for Plaintiff/Petitioner
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JUN 2 1 200011)
RICHARD A, BALLANT,
Plaintiff, Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
IN CUSTODY
KATHY DICK,
Defendant, Respondent
NO, 98-1246
CIVIL TERM
ORDER OF COURT
AND NOW, this day of , 2000, upon considerat.ion
of the attached complaint, it is hereby directed that the parties
and their respective counsel appear before,
the conciliator, at on the
day of , 2000, at __ ' for a Pre.-Hearing
Custody Conference, At such conference, an effort will be made
to 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, Either party may
bring the child who is the subject of this custody action to the
conference, but the child/children'S attendance is not mandatory.
Failure to appear at the conference may provide grounds for entry
of a temporary or permanent order,
FOR THE COURT:
By:
-Custody'Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU
DO NOT HAVE A LAWYER OR C,~OT 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 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required
by law to comply with the Americans with Disabilities Act of
1990, For informat.ion about accessible facilities and reasonable
accommodations available to disabled individuals having business
before the court, please contact our office, All arrangements
must be made at least 72 hours prior to any hearing or business
before the court. You must attend the scheduled confer~nce or
hearing,
RICHARD A. 8ALLEN'l',
Plaintiff
: IN THE CXXlRT OF CXXolMCtl PLEAS OF
CUMBERLAND COONTY, PENNSYLVANIA
vs.
NO. 98-1246 CIVIL TERM
Defendant
: CIVIL ACTIOO - LAW
c.'US'IODY
KATHY DICK,
ClUlER OF cnlIl!l'
AND tuf, this .;l.;/,,,,l day of kAl.-t"..wv
consideration of the attachecr-custody ConcrrratioilRepc,rt,
and di!:'ecteC a!! follO'Nll:
, 1998, upon
it is ordered
1. The Father, Richard A. Sallent, and the Mother, Kathy Dick,
shall have shared legal CUBtody of Joshua A. Dick, born February 17, 1998.
Each parent shall have an equal right, to be exerois<<J jointly with the
other parent, to make all major non-emergenO'j decisions affeoting the
Child's general well-being including, but not limited to, all decisions
regarding his health, education and religion.
2. 'llle Mother shall have primary physical custody of the Child.
3. The Father shall haw periods of ,9upervised visitation with
the Child at an agency selected by lIgreetoent of the parties and counsel.
The parties agree to follCI'N the recomnendations ,of the supervising agency
with respect to initial and ongoing custody arrangements as well as
recOIlIlIElndations regarding the advisability of parenting cla!lses for either
or both parties. 'llle Father shall be responsible to pay 60%, and the
Mother shall be responsible to pay 40% of the costs charged by the
supervisifl9 agency. 'llle parties shall cooperate in selecting the
supervising agency and initiating oontact between the Father and the Child
as soon as possible.
4. 'llle Fathor may initiate telephone contact with the Mother at
re&3onllble t:.mas 1UI necessary to discuss custody arrangements for the
Child, selection of a supervising agency under this Order and other
inplrtant issues related solely to the Child's best interests.
5 . 'lllis Order
Conciliation Conference.
Order by fm.Itual consent.
this Order shall oontrol.
is entered pursuant to an agreement at a custody
The parties may modify the provisions of this
In the absence of mutual consent, the terms of
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In Tes!i:,', , , - , ' , ,::t my hand
and tile SS3i .::" ~,~ ',: .:,~ j~, :~ ~:::i.)i~, Pa.
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Gerald S. Robinson, Esquire - Counsel for Mother
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RICHARD A. BALLENT , IN THE CXlURT OF (..'C(01MCN PLEAS OF
plaintiff CllMBERLAND CXXJNTl{, PENNSYLVANIA
.
.
vs. . NO. 98-1246 CIVIL TERM
.
.
.
KATHY DICK, . CIVIL ACTIctl - LAW
.
Defendant : CUSTODY
PRICR JUDGE: George E. Soffer
ammY aH:ILIATIctl S(HIIARX' REPCR1'
IN ACXXJll)ANCE wrm aJoIBBRLAND cxumc ROLE C'6 CIVIL ~
1915.3-8, the undersigned CUstody COnciliator subnits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
tWlE
-
pATE r:e B~
February 17, 1998
alRRMLY IN cmlWY OF
Joshua A. Dick
Mother
2. A conciliation Conference was held on September 15, 1998, with the
following individuals in attendance: The Father,' Richard A. Ballent, with
his counsel, Matthew Eshelman, Esquire, and the Mother, Kathy Dick, with
her counsel, Gerald S. Robinson, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
~fk~
Date
I)" /79L
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Dawn . sunday, Esquire
custody Conciliator
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RICHARD A. BAl,LENT,
Plaintiff
IN ~'IJE COl1!\1' OF COMMON PLEAS OF
I CUMBEnLNID (X){ncl~r\', PENNSYL VANIA
.
.
vs.
NO. 98-1246 CIVIL TF.RM
KATHY DICK,
Defendant
CIVIL IIC'l'ICo.\1 - I~I\W
IN cusroDY
~ OF CXXJRT
AND OCW, this I S: I-~day of $c1ft ...... ~ t 1
consideration of the attached Custody Concllicl't, on Report,
and directed as follows:
1. A Hearing is scheduled in Court Room # / , of the Cumberland
co~ty Court House, on the oJ? 'HL day of )T,i-!leA-'LI~A..J , 2000, at
-.-::!.i.~ o'clock .-'L..m., at which time testimony wlll be taken. For
purposes of the Hearing, the Father, Richard A. Ballent, shall be deemed to
be the roving par:-ty and shall proceed initially with testimony. Counsel
for the parties shall file with the Court and opposing counsel a Memorandum
setting forth each party's position on custody, a list of witnesses who are
expected to testify at the Hearing and a SUlMlary of the anticipated
testimony of each witness. These Memoranda shall be filed at least 10 days
prior to the Hearing date.
, 2000, upon
it is ordered
2. Pending further Order of Court or agreement of the parties, the
prior Order of this Court dated September 22, 1998 shall continue in effect
as modified by this Order.
3. The Father shall have custody of the Child on Friday, September 1,
2000 and on Monday, September 4, 2000 from 12:00 noon until 5:00 p.m.
supervised by the Father's mother, Velma Ballent, at her residence. The
Mother shall provide transportation of the Child to and frcm the rosidence
of the Father's mother. Thereafter, unless otherwise agreed between the
parties, until t.he date of the Hearing, the Father shall have regular
ongoing periods of supervised visitatIon at Inner Works or othor
supervising agency or individual as arranged by the parties through
counsel. The parties shall continue to share any costs of the supervised
visitation as provided in the September 22, 1998 Order.
BY THE COURT,
J.
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cc: Andrew J. Morrow, Legal Intern and
Robert E. Rains, F8quire - Counsel for Father
Timothy T. Engler, Esquire - Counsel for Mother
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RICHARD A. BALLEN'r, IN THE COURT OF COMMON PLEIIS O~
Plaintiff CUMBERLAND COUN~'Y, pgNNSy[,vANIA
va. NO. 98-1246 CIVIL TERM
KATHY DICK, CIVIL ACI'ION - LAW
Defendant IN CUSTODY
CUSTOOY ~ILIATIGl SlftWlY RFJ?(Rl'
PRIOO JUDGE: J. Wesley Oler, Jr.
IN AccamANCE WITII aJoIBERLAND cx:.un'Y RULE OF CIVIL PRCCEDURE
1915.3-8, the undersigned CUstody Conciliator submits the following I:eport:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
DATE OF BIRTlI
ClJRRfNl'LY IN ClJSTOOY OF
Joshua A. Dick
FebruaL~ 17, 1998
Mother
2. A Conciliation Conference was held on August 31, 2000, with the
following individuals in attendance: The Father, Richard A. Ballent, with
his counsel, Andrew J. Morrow, Legal Intern, and Robert E. Rains, Esquire,
and the Mother, Kathy Dick, with her counsel, TiIOC>thy T. Engler, Esquire.
3. This Court previously entered an Order on September 22, 1998 under
which the Mother had primar:y physical custody and the ['ather had supervIsed
visitation. 'rhe F'ather filed this petition for Modifi-::ation seeking
unsupervised partial physical custody. The parties were not able to r.each
an agreement at the Conference and it will be necessary to schedule a
Hearing .
4. The ~ather's position on custody is as follows: The Father stated
that he had participated in supervised visits with the Child at Inne~ Works
from the date of entry of the prior Order in September 1998 through March
2000, at which time the ~ather moved to South Carolina in order to obtain
employment. The ['ather stated that there were no problell'oS during t.he
supervised visitations but that he could not continue the schedule due to
his relocation. The ~ather believes that supervision is not necessary and
that he should be permitted to have full part.ial custody of the Child
without restrictions. The ~ather offered to travel to CUmberland County,
where his Mother resides, on an alternating weekly basis to exercise
periodS of partial custody with the Child. The Father denied the Mother's
allegl.\tions with respect to the Child's safety and care while in his
custody. The ~ather believes it would be in the Child's best interest to
RICHARD A. BALLENT,
Plaintiff
IN THE COUR'I' OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
va.
NO. 9El-1246 CIVIL l'ERM
KATHY DICK,
CIVIL A~'ION - LAW
CUSTODY
Defendant
~ OF CUJR'I'
AND tOI, this '2. 2.., J. day of ~ iil: .... ~GI
consideration of the attached CUstody Conci iation Report,
and directed as follows:
, 1998, Upon
it is ordered
1. The Father, Richard A. SalIent, and the Mother, Kathy DiCk,
shall have Shal'ed legal custody of Joshua A. DiCk, born Februaty 17, 1998.
F..ach parent shall have an equal right, to be eKercised jointly wi th 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 !lis health, education and religion.
2. The Mother shall have primary physical custody of the Child.
3. The Father shall have pedods of supervised visitation with
the Child at an agency selected by agreement. of the parties and counsel.
The parties agree to follow the recommendations of the supervising agency
with respect to initial and ongoing custody arrangements as well as
recommendations regarding the advisability of parenting classes for either
Or both parties. The Father shall be r'esponsible to pay 60%, and the
Mother shall be responsible to pay 40% 01: the costs charged by the
super.vising agency. The parties shall cooperate in selecting the
supervising agency and initiating contact between the Father and the Child
as soon as possible.
4. The Father may initiate telephone contact with the Mother at
reasonable times as necessary to discuss custody arrangements for the
Child, selection of a supervising agency under this Order and other
important issues related solely to the Child's best interests.
5. This Order
ConCiliation Conference.
Order by mutual consent.
this Order shall control.
is entered pursuant to an agreement at a Custody
The parties ma~' mcdify the provisions of this
In the absence of mut.ual consent, the terms of
BY THE COURT,
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Gerald S. Robinson, Esquire - Counsel for Mother
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RICHARD A. BALLENT,
Plaintiff
IN THE COURT OF mMMON PLF~S OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 98-1246 CIVIL TERM
KATHY DICK,
CIVIL ACTION - LAW
CUSTODY
Defendant
PRI~ JllDGE: George E. Hoffer
CUS'roOY <X.NCILIATIOO SlI9IARY REPOOT
IN A<XnmANcE WITH CU>IBERlJIND COI:Nl'Y 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 DE' BIRTH
aJRRl.Wl'Ly IN CUS'lOOY OF
Joshua il. Dicl{
February 17, 1998
Mother
2. A Conciliation Conference was held on September 15, 1998, with the
following individuals in attendance: 'rhe Father, Richard A. Ballent, with
his counsel, Matthew Eshelman, Esquire, and the Mother, Kathy Dick, with
her counsel, Gerald S. Robinson, Esquire.
3. The parties agreed to entry of an Or.der in the form as attached,
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Date
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Dawn- . Sunday, Esqulre
Custody Conciliator
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RI CHARD BAL!I.,I':NT,
plaintiU
IN TIlE COURT OF COMMON PLf!:AS OF
CUMBlcRLAND COUNTY, pr~NNSYLVANIA
v,
NO, 98-1246 CIVIL TERM
KATHY DICK,
Defendant:
CIVIL ACTION - CUSTODY
ORDER OF COURT
AND NOW, l',his 30th day of November, 2000, upon
oonsideration of plaintiff's Petition for Modification of
Custody with respect to the parties' child, Joshua A. Dick (date
of birth February 17, 1998), and following a hearing held on
November 27, 2000, it is ordered and directed as follows:
1, The father, Richard A, Ballent, and the mother,
Kathy Dick, shall have shared legal custody of the child. 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 his health, education and
religion,
2,
primary physical custody of the child'shall be in
the mother,
--
3,
Temporary or partial physical custody of the
child shall be in the father at the following times:
a. Prior to January 1, 2001, the father shall
have partial or temporary physical custody of the child on
Saturdays from 8:30 a,m, until 8:30 p.m,
b, Commencing January 1, 2001, the father shall
have temporary or partial physical custody of the child at the
following times:
(1) On alternate woekenda from Saturday at
8:30 a,m, until Sunday at 7:00 p,m.
(2) One evening pm: weAk on alternating weeks
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(rom 5 :00 P,n\, until 8 :00 p,m, i in the event that the parties
are unable to agree on the evening, it shall be on a Wednesday
evening.
4, The parties shall alt.ernate cust.odi,d periods on
the following holidays, from B:30 a.m. until 7:00 p.m.: Easter,
Memorial Day, Independence Day, Labor Day and Thanksgiving,
5, The parties shall alternate custodial periods
with respect to Christmas, frOM Christmas Eve at noon until
Christmas Day at noon and from Christmas Day at noon until
December 26 at noon,
6. Notwithstanding the foregoing, each party shall
be entitled to two nonconsecutive weeks of uninterrupted custody
of the child, subject to thirty days notice to the other party,
during the summer,
7. Each party shall be entitled to reasonable
telephone contact with the child while he is in the custody of
the other party,
In the event that the parties are unable to
agree on a schedule, they shall permit at least one telephone
contact every three weeks.
~
8, Pursuant to an agreement of the parties, both
shall engage in co-parenting counseling, with each party to bear
his or her own expense
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associated with the counseling.
By the Court,
Gerald S. Robinson, Esquire
Counsel for Defendi.tnL
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Andrew J. Morrow, CerLifie
Robert E, Rain8/ Esquire
Thc Family l,aw Clinic
Courwel (or Plaintitt
sheriff
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Ptl'Ii'J:NIVANI.^
RICHARD BALLENT, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
KATHY DICK, :
Defendant NO. 98-1246 CIVIL TERM
IN RE: PETITION FOR SPECIAL RELIEF
ORDER OF COURT
AND NOW, this 16'h day of May, 2011, upon consideration of Defendant's
Petition for Special Relief, this matter is referred to the custody conciliation process, and
the Court Administrator is requested to facilitate this referral.
Richard Ballent
9351 Route 35
Apt. 6
Mount Pleasant Mills, PA 17853-8461
Plaintiff, pro Se
Matthew A. McKnight, Esq.
60 West Pomfret Street
Carlisle, PA 17013-3222
Attorney for Defendant
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BY THE COURT,
RICHARD BALLENT IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 1998-1246 CIVIL ACTION LAW
KATHY DICK
Defendant : IN CUSTODY
ORDER OF COURT
AND NOW, this 13_'' day of j ? cl , 2011, upon
consideration of the attached Custody Conciliation Report, it is orde •ed and directed as follows:
1. The prior Order of this Court dated November 30, 2000 shall continue in effect as modified
by this Order.
2. The Father and Child shall participate in at least three reunification counseling sessions at
CRC at Pinnacle Health in Harrisburg or other provider as arranged by agreement between the parties.
The purpose of the sessions shall be to reinitiate contact between the Father and the Child in a way that
is most conducive to the Child's emotional well-being. The Mother shall be responsible to pay the
costs of these sessions.
3. If the three or more reunification counseling sessions between the Father and Son are
completed sooner than three months, for the remainder of the three month initial period, the Father
may have periods of supervised custody with the Child with the paternal grandmother present and with
the specific times to be arranged by agreement between the parties.
4. After the first three month period during which the Father and Child complete reunification
counseling and any additional supervised periods of custody, the Father shall have partial physical
custody of the Child for one weekend each month from Friday through Sunday for an additional three
month period.
5. After the Father has completed both three month phases of increasing contact with the Child
as provided in the prior provisions of this Order, the Father shall resume having partial physical
custody of the Child on an ongoing basis on alternating weekends from Friday after school through
Sunday as provided in the November 30, 2000 Order.
6. The parties shall resume alternating holiday custody under the prior Order of this Court with
the Mother having custody of the Child for Thanksgiving in 2011 and for the first part of the Christmas
holiday in 2011 and the Father having custody for the second part of the Christmas holiday in 2011.
7. The Mother shall provide information pertaining to the Child's medications to the Father for
his periods of custody.
8. Both parties shall ensure that the Child is transported in motor vehicles only by individuals
with valid current drivers' licenses.
9. Neither party shall do or say anything which 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. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
10. This Order is entered pursuant to an agreement of the parties at 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 COURT,
J. esrey Oler, J- J"
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cc: Matthew A. McKnight, Esquire -Counsel for Mother
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Gregory S. Hazlett, Esquire - Counsel for Father ..-
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RICHARD BALLENT IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
KATHY DICK
Defendant
1998-1246 CIVIL ACTION LAW
IN CUSTODY
Prior Judge: J. Wesley Oler, Jr.
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 CUSTODY OF
Joshua A. Dick February 17, 1998 Mother
2. A custody conciliation conference was held on July 7, 2011, with the following individuals
in attendance: the Father, Richard Ballent, with his counsel, Gregory S. Hazlett, Esquire, and the
Mother, Kathy Dick, with her counsel, Matthew A. McKnight, Esquire.
3. The parties agreed to entry of any Order in the form as attached.
Date Dawn S. Sunday, Esquire
Custody Conciliator