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HomeMy WebLinkAbout98-02118 N 1 i i G o. , C?o O- LAUREEN M. ULRICH# 2 IN THE COURT OF COMMON PLEAS OF Plaintiff 2 CUMBERLAND CO UNTY, PENNSYLVANIA va. 2 2 NO. 98-2118 CIVIL TERM 2 KEITH P. ULRICHr CIVIL ACTION - LAW Defendant : CUSTODY ORDER OF COURT AMID NOW, this J?k day of r 1998, upon consideration of the attached Custody Conc 1 aft on Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. r of the Cumberland County Court Houser on the day of r 1998, at ?'l5 o'clock, a .m., at whl-ch t me testimony w l be taken in this case. For purposes of this Hearing, the Mother shall be deemed to be the moving party 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 will be called to testify at the Hearing, and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten (10) days prior to the Hearing date. 2. The parties shall submit themselves and their minor Children to a custody evaluation to be performed by Stanley Schneider, PhD. or another professional selected by mutual agreement of the parties and counsel. The purpose of the evaluation shall be to obtain professional, recommendations with respect to custody arrangements which will be in the best interests of the Children in light of the Mother's proposed move to New York. The parties shall equally share the cost of the evaluation. 3. Pending further Order of Court or agreement of the partiesr the Mother, Laureen M. Ulrich, and the Father, Keith P. Ulrich, shall have shared legal custody of Chad C. Ulrich, born October 17, 1990, and Chelsea M. Ulrich, born August 12, 1994. The parties shall share physical custody of the Children in accordance with the following schedule: A. The Father shall have custody of the children on the following dates and times - From June 17, 1998 through June 22, 1998 at 4:00 p.m. On June 25, 1998 from 12:00 noon until 4:00 p.m. On June 30, 1998 from 12:00 noon until 4:00 p.m. On July 2, 1998 from 12:00 noon until 4:00 p.m. From July 4, 1998 at 12:00 noon until July 6, 1998 at 4:00 p.m. On July 7, 1998 from 12:00 noon until 4:00 p.m. On July 9, 1998 from 12:00 noon until 4:00 p.m. From July 28, 1998 when the Mother returns from her trip to California until August 31 1998 at 4:00 p.m. Cn August 4, 1998 from 12300 noon until 4:00 p.m. On August fi, 1998 from 12:00 noon until 4:00 p.m. On August 12, 1998 from 12:00 noon until 4:00 p.m. On August 13, 1998 from 12:00 noon until 4:00 p.m. Fran August 15, 1998 from 12:00 noon through August 17, 1998 at 4:00 p.m. Cn August 18, 1998 from 12:00 noon until 4:00 p.m. On August 20, 1998 from 12:00 noon until 4:00 p.m. B. The Mother shall have custody of the children at all times not otherwise specified for the Father in this provision. 4. The Father shall provide transportation for all exchanges of custody under this order. 5. In the event the parties are able to resolve most of the custody issues by agreement following the custody evaluation and the parties agree that a second Custody Conciliation would be useful in resolving the remaining issues without the necessity of a Hearing, counsel for either party may contact the Custody Conciliator, Dawn S. Sunday, Esquire, to schedule an additional Conference. BY THE COORTO IA' J. cc. Jacqueline M. Verney, Esquire - Counsel for mother 9 9? Jac _hael J. Hanft, Esquire - Counsel for Father ?4d LAUREEN M. ULRICH, s IN THE COURT OF COO" PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. s NO. 98-2118 CIVIL TERM KEITH P. ULRICH, : CIVIL ACTION - LAW Defendant : CUSTODY CUSTODY CONCILI!%TION S[1R4W RB[C1RT IN ACOMBANCE WITH C[IMERLAND =MY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: Child's Name Date of Birth In Custody of Chad C. Ulrich Chelsea M. Ulrich October 17, 1990 Mother August 12, 1994 Mother 2. A Conciliation Conference was held on June 17, 1998, with the following individuals in attendance: The Mother, Laureen M. Ulrich, with her counsel, Jacqueline M. Verney, Esquirai and the Father, Keith P. Ulrich, with his counsel, Michael J. Hanft, Esquire. 3. The Mother intends to move with the Children to New York as soon as possible and filed this Petition to obtain Court approval for the move and primary physical custody of the Children. The Father, strongly objects to the Mother removing the Children from the area and also seeks primary physical custody of the Children. The parties agreed to obtain a professional custody evaluation in order to obtain recommendations with regard to primary custody and the proposed move. However, since it is close to the beginning of the 1998-1999 school year, the parties request that a Hearing be scheduled at this time in the event the parties are not able to reach an agreement following the evaluation. 4. The parties were able to agree on temporary custody arrangements pending completion of the evaluation. The Conciliator recommends an Order in the form as attached. .?tvhP ). j ? ?! `? tip" _L ;:?.-n_ ?.F?-?,,??'??s•_ Date pawn S. Sunday, Esqu re Custody Conciliator ?'t ?? rr rlri - 1 • ?? 9[ 13 ?Ih 3?A Faire -` A ?F#i ? . Y F?IYr??s _It r ii {, rt? r ! r {I ?, F ° ?, 1 f f 5 i t??fix tl ? I I € F?s4 ? 1 s i - It - ?j?ilr r t 1 1 ll 11 ,. I ( 1 I x 1 ??i jT ?j 1+ k 1. ???£+ t- 1 tl r a lj4 41 ? { S t" ( .1 ? 14 I r ll { 1 ? f ? f] 1. ?3 I t $ #F ? i "i 1 1 f fi Ir i f?? ?I j3S l 1 F ? { 3 4 1 1 "' o R, MA 41S r 4 4 € -zoo I ? xfe 1F 1 ! t 1 ?L14?'i F. +tn 1 t 1 I _ _ .. alt s WAY 0, 4 _ Fjp tl fL f 4 ' Y L F?$ r_I f Ulm e 1 k 4 1!i {S } 1 1 k A t ? r rl t it??l( - ," ^ r: . r e! 4 S 4 ? V ? . J i S1?`e 1 1 Fr + r I .Y? ! 4 C. M K"71- SAM f , } r I Y 1 :? "Fti Y s[AF?f 141 rs { I°? 4 ? ,r ? c i r 1 I !(k (r f t go 1 r ? ni, +FI C x I . r , ,741 + 7f 1 1 t fm Q o F 5 V Ir AN-x, U, 1 . . } i+ ow P Fr ! 1 ? 1. r 1 4 rrf, •. lr! r `+ I 1 t i I. r, 1 1 1 Avow, . {' I r r' 1 1 I r F," nil f All y" ."K . 11? ° r '. ins4 ? (? A r 'F ?y yyyy N? c LAUREEN M. ULRICII, Plaintiff V. KEITH P. ULRICH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTV,PENNSVLVANIA : CIVIL ACTION - LAW : NO. 98-2118 IN CUSTODY PLAINTIFF'S PRETRIAL MEMORAND 1U L FACTUAL HISTORY The children involved in this dispute are: Chad C, Ulrich (DOB 10.17-90) and Chelsea M. Ulrich (DOB 8-12-94), A Custody Complaint was flied on April 16, 1998. A Custody Conciliation was hold on June 17, 1998 before Dawn S. Sunday, An Order was entered as a result of the conciliation conference wherein the parties had shared legal and physical custody of the children. At the conciliation Conference, the parties also agreed to submit themselves and the children for a custody evaluation. The parties began the evaluation process with Stanley Schneider, however Plaintiff is without sufficient funds to proceed with a finalization of the evaluation, Plaintiff left the marital residence on January 26, 1998, On or about August 24, 1998 she returned to the marital residence, The parties are presently living separate and apart within the marital residence, The marital residence is a mobile home titled in both parties' names. Plaintiff wishes to remain in the marital home, 'rho children continue to reside in the mobile home with the parties, Plaintiff filed a Motion for Continuance on September 1, 1998. The Motion for Continuance was denied, II. WITNESSES Mother wili call the following individuals to testify at the Custody hearing: Laureen M. Ulrich-Mother will testify concerning the relationship both parties have with the children. She will present testimony regarding her role as primary caregiver to the children, and the amount, nature and quality of time and involvement that both parents have had with the children. III. RELIEF SOUGHT Plaintiff' does not believe that a custody order is necessary since both parents and the children are residing together. However, since Defendant has objected to a general continuance of the hearing, Mother seeks shared legal and primary physical custody of the children. Respectfttlly submitted, acq ellne M, Verney, EsquireU Supreme Ct, ID 23167 44 South Hanover Street Carlisle, PA 17013 Attorney for Defendant R MICA1, -Q-r SEARME I hereby certify that a true and correct copy of the foregoing Plaintiffs Pretrial Memorandum was served on the following person by first class mail, postage prepaid addressed to Michael J. Hanft, Esquire 10 East High Street Carlisle, PA 17013 LAUREEN M. ULRICH+ : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTV,PENNSVLVANIA I V. : CIVIL ACTION-LAW KEITH P. ULRICH, NO. 98- iM r,I..? Dn Defendant _ a "fit.( : IN CUSTODY ORDER OF COURT AND NOW, this day of_ ' consideration of the attached custody Complaint`'it is hereby directed that the Parties and their respective counsel shall appear before Conciliator, at the i _ of_?(1__ 1998 at 1 C?, m., fora Baring n the day 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 Couut, and to enter into a Temporary Order. All children five or older may also be present at the Conference. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, BY;, Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information 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 conference or hearing. 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 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249.3166 .?? ?.? ? ., ? ? ?? l,l ??, '?? .. ;.. ? i yds. ? Q?f ?%?. ?/.//h?.,.?r .? < ? ?? LAUREEN M. ULRICH, Plaintiff V. KEITH P. ULRICH, Defendant a IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTV,PENNSVLVANIA a : CIVIL ACTION-LAW C'? .w P l r,. a NO.98- 2111' INCUSTODV COMPLAINT FOR CUSTODV AND NOW, comes the plaintiff, Laureen M. Ulrich, by and through her attorney, Jacqueline M. Verney, Esquire and represents the following in support of her custody complaint: I, The Plaintiff is Laureen M, Ulrich, residing at 181 Cedar Lane, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Keith P, Ulrich, residing at 25 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following: NAME PRESENT ADDRESS AGE Chad C, Ulrich 181 Cedar Lane, Carlisle, PA 7 (DOA 10/17/90) Chelsea M. Ulrich 181 Cedar Lane, Carlisle, PA 3 (DOB 8/12/94) Chad C. Ulrich was born out of wedlock. Chelsea M. Ulrich was not born out of wedlock, The children are presently in the custody of Laureen M. Ulrich, Plaintiff, who resides at 181 Cedar Lane, Carlisle, Cumberland County, Pennsylvania, During the past five years, the children have resided with the following persons and at the following addresses: LIST ALL PERSONS ADDRESSES DATES Laureen M, Ulrich, Keith P. Ulrich 311 Fifth St, Aug 1992-Aug 1994 West Fairview, PA Laureen M. Ulrich, Keith P, Ulrich 25 Regency Woods N, Aug 1994-Mar 1998 Carlisle, PA Laureen M, Ulrich, Jeff Moore, Liss 181 Cedar Lane Mar 30,1998- Scott, Sara, Lana, William, Francessce Kove Carlisle, PA Present. The mother of the children is Laureen M. Ulrich, currently residing at 181 Cedar Lane, Carlisle, Cumberland County, Pennsylvania, She is married. The father of the children is Keith P. Ulrich, currently residing at 25 Regency Woods North, Carlisle, Cumberland County, Pennsylvania, He is married. 4. The relationship of Plaintiff to the children is Mother. The Plaintiff currently resides with: NAME RELATIONSHIP Chad C. Ulrich son Chelsea M. Ulrich daughter Jeff Moore Co-worker Lisa Kove Employer Scott, Sara, Lena, William, Francesscs Kove Children of Employer 5. The relationship of Defendant to the children is Father. The Defendant currently resides with: NAME RELATIONSHIP 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of these minor children in this or another court, Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff has been the primary caregiver of the children since birth, b. Plaintiff can provide a loving, nurturing home for the children. g. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests this court to grant shared legal custody and primary physical custody of the children to the Plaintiff. Respectfully submitted, r h, lx J cqu r'ine M. Verney, Esquire Supreme Ct. ID 23167 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff 6? B w l°I ? O B r ? e o a o wok "rs,, s? O o o ?o 00 o .o s o~? B _ m I y Ati- o noo oo O ??n '''? r G 2 7- C? ?o 7 v O ?? a? BOG lp 2 G oe ? 2 v' ? ?? O r1k c?'222 00 a? Oy ?f O ? ?i .y 7 B m q' 711 pi spe 7 00 R ? cc' 3 • .o :ERT1ElCATEi () SEMCE 1, Denise L. Nye, an authorized agent for Martson, Deardorff, Williams & Otto, hereby certify that a copy of the foregoing Entry of Appearance was served this date by depositing same in the Post Office at Carlisle, PA, first class trail, postage prepaid, addressed as follows: Jacqueline M.. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 MAR/TSON, DEARDORFF, WILLIAMS & OTTO Denise L. Nye Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated; April 27, 1998 .q[. tit Ci. U • ,M u 5 1 W M. yy?. 4 4 o ? ? 4F H LAUREEN M. ULRICH, PLAINTIFF V. KEITH P. ULRICH, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 982118 CIVIL TERM AND NOW, this 9th day of July, 1998, the hearing now scheduled for August 7, 1998, IS CANCELLED. The hearing is rescheduled for Thursday, September 3, 1998, at 8;45 a.m,, In Courtroom Number 2, Cumberland County Courthouse, Carlisle, By the Court Edgar B. Bay, ey, J. Jacqueline M. Verney, Esquire ' For Plaintiff Michael J, Hanft, Esquire For Defendant ;saa I,i(' E'G LAUREEN M. IILRICH, PLAINTIFF V. KEITH P. ULRICH, DEFENDANT t IN THE COURT OF COMMON PLEAS OF s CUMBERLAND COUNTV,PENNSYLVANIA t a 98-2118 CIVIL TERM z IN CUSTODY ORDER AND NOW, this day of, 1998, upon consideration of Plaintiff's Motion for Continuance, the Custody hearing scheduled for September 3, 1998 at 8:45 a.m. is hereby continued generally. By the Court, oct Jacqueline M. Verney, Esquire Attorney for Plaintiff Michael J. Hanft, Esquire Attorney for Defendant Edgar B. Bayley, J. LAUREEN M. ULRICH, PLAINTIFF V. KEITH P. ULRICH, DEFENDANT : IN THE COURT OF COMMON PLEAS OF : Cl1MBERLAND COUNTV,PENNSYI,VANIA s 98-2118 CIVIL'iTERM IN CUS'T'ODY MOTION FOR CONTINUANCE TO: the Honorable Edgar B, Bayley AND NOW, comes the plaintiff, Laureen M, Ulrich, by and through her attorney, Jacqueline M. Verney, Esquire, and presents this Motion for Continuance and represents the following in support thereof: 1. A custody hearing is scheduled for September 3, 1998 before the Honorable Edgar B. Bayley at 8:45 a.m. 2. A Custody Complaint involving two children, Chad C. Ulrich, (DOB 10/17/90 and Chelsea M, Ulrich, (DOB 8/12/94) was filed on April 16, 1998. A Custody Conciliation was held on June 17, 1998 before Dawn S. Sunday. An Order was entered as a result of the conciliation conference which included a custody evaluation to be conducted by Stanley Schneider, the cost of which was to be shared equally by the parties. 3. The parties have had numerous appointments with Dr. Schneider. Dr. Schneider has requested that the plaintiff return for one more appointment. The plaintiff has not scheduled the last appointment. Plaintiff is without sufficient funds to pay her share of Dr. Schneider's costs. 4. The parties separated on January 26, 1998, with plaintiff removing herself Prom the marital home. Plaintiff returned to the marital home, which is owned both parties, on or about August 24, 1998 and desires to remain there since she has no other available housing. 5. Since both parties are presently residing in the same residence with the children, a custody order is now unnecessary. 6. Counsel for the defendant, Michael J. Hanfl, Esquire has been contacted regarding this request for continuance and objects to it. WHEREFORE, Plaintiff requests that the Custody hearing scheduled for September 3, 1998 at 8:45 a.m. be continued generally. Respectfully submitted, cq line M. Vernev. Esquire 0 Was ',Vol /tile ?d dra8to : ry?on rhv ro end °°n°cr, °° //ogiuBP°ryon by ?orBBoiuB °/O&V uui/ Molion to MiOhna/ /Poi+Bo pr°l /o 9'?i/ Cnr?s/g pqe?' eef 13 44 Fo"alin° M ., ur C$yis/a PH?novB erne 9o q tom 40910 o13Srr° r plsinriq «,?..anana..=?zmmrracr?ca rse?wry+9,??«ple4fnF nf•.kr?r?Y?cr 5 f:-n.kr ?, rv,•?ri;?itil az.?Le - LAW OFFICE OF Jacqueline M. Verney MW ? $? 4 CARUJUI PA 17013 • (717) 241.9190 • FAN (717) 243.3319 LAUREEN M. ULRICH, ; Plaintiff i V. i KEITH P. ULRICH, : Defendant IN RE: CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 98-2118 CIVIL TERM AND NOW, this 3rd day of September, 1998, this matter having been called on a hearing regarding the custody of Chad C. Ulrich, born October 17, 1990, and Chelsea M. Ulrich, born August 12, 1994, and the parties representing that they are living in the same home with the children but are separated within that home, and that they have reached an agreement regarding the custody of the children given their current situation, IT IS ORDERED: 1. The custody order of July 7, 1998, is vacated and replaced with this order. 2. Legal custody of Chad and Chelsea shall be shared between the mother, Laureen M. Ulrich, and the father, Keith P. Ulrich. 3. The mother and father shall have shared physical custody of Chad and Chelsea on alternate weekends, as the parties shall agree, to coincide with the mother's anticipated every other weekend work schedule; on alternating holidays, which holidays are to alternate each year. 4. The parties acknowledge that if either or both of them were to move from their current home they would have to make an alternate arrangement for the custody of their children or seek an amendment to this court order. 5. Neither party shell disparage the other in the presence of the children. By the CoUA/ f1r; LAUREEN M, ULRIC:II t IN TILE COURTOF COMMON PLEAS OF PLAIN'T'IFF C'UMHERLAND ('011NT'Y, PENNSYLVANIA V, t 98.2118 CIVIL AC'T'ION LAW KFIT'II P, ULRICII . r DIiFIiNI)AN'I' IN CUSTODY ORDER OFCOURT AND NOW, _,_.-___, Friday, July 22, 2005 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, August 16, 2005 ut 2:00 PM l'or a Pre-licaring 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 it temporary order. All children ape five or older may also be present at the conference. Failure to appear at the conference may provide grounds I'or entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing; Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing, FOR THE COURT, By: /sl_ Dawn _S, Sunda , I Custody Conciliator The Court of Common Pleas of C'wnberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information 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 conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR A'rToRNEY ATONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, CIO TO OR TELEPIIONE THE OFFICE SET FORTH BELOW TO FIND ,OUTWHERE YOU CAN GET LEGAL fIELP, Cumberland County Har Association 32 South Bedford Sheet Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 RECEIVED JUL 18 20M 01 P 4IN1 Pokk,Vi m It kA<IanduagiiVNQJIMI mkljb eunrwy wW IN THE COURTOF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAUREEN M. ULRICH, Respondent CIVIL ACTION - LAW V. IN CUSTODY KEITH P, ULRICH, NO. 98-2118 Petitioner ORDER OF COURT AND NOW, this day 2005, upon consideration of the attached Petition to Modify Custody, it is hereby directed that the parties and their respective counsel shall appear before the Conciliator, at ?___ on the -.T.. day of _, 2005 at __ .m., 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. All children age five or older shall/may also be present at the Conference. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent Order. FOR THE COURT, Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information 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 conference or hearing. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAUREEN M, ULRICH, Respondent V. CIVIL ACTION - LAW IN CUSTODY KEITH P. ULRICH, Petitioner NO. 98-2118 NOTICE 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 attorney 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 requested 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 NCTICIA Le ban demandado a usted on la corte, Si usted quicre defWnderee de estas demandas expuestas on ]as paginas siguientes, usted tiene viente (20) dias do plazo al partir de la fecha do la demanda y la notiflcacion, Usted debo presentar una upariencia escrita o en persona o por abogado y archivar on la come on forma escrita sus defensas o sus objeciones a las demandas on contra de su persona. Sea avisado quo si usted no se defiende, la corte tomara medidas y puede entrar una ordon contra usted sin provio aviso o noti ficacion y por eualguier queja o alivio quo es pedido on la peticion de demanda. Usted puede perder dinero o sus propiendades o otros dereclios importantes para usted. LLEVEESTADEMANDAAUNABOGADOIMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONAL. 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL, Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 KNIGHT & ASSOCIATES, P.Ce- ean M. Shultz, Esquire Attorney ID No. 90946 1 I Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAUREEN M. ULRICH, Respondent V. KEITH P, ULRICH, Petitioner CIVIL ACTION - LAW IN CUSTODY NO. 98-2118 PETITION TO MODIFY CUSTODY AND NOW, this ?Jday of July, 2005, comes the Petitioner, Keith P. Ulrich, by and through his attorneys, Knight & Associates, P.C., and files the following Petition to Modify Custody and in support thereof avers as follows; 1. The Petitioner is Keith P, Ulrich, an adult individual residing at 25 Regency Woods North, Carlisle, Pennsylvania 17013. 2. The Respondent is Laurcen M. Ulrich, an adult individual residing at 737 Hummel Avenue, Lemoyne, Pennsylvania 17043. 3, Petitioner seeks amodification oftheOrder ofCourt dated September 3,1998i a copy of which is attached hereto and made a part hereof and is marked as Exhibit "A." Name 4. The Parties are the natural parents of the following minor children; P esen R sidence Ape DOB Chad C. Ulrich 25 Regency Woods North Carlisle, Pennsylvania 17013 Chelsea M, Ulrich 737 Hummel Avenue Lemoyne, Pennsylvania 17043 Chad C. Ulrich was bone out of wedlock. 14 October 17, 1990 10 August. 12, 1994 Chad C, Ulrich is presently in the physical custody of the Petitioner and Chelsea M, Ulrich is presently in the physical custody of the Respondent. In addition to Petitioner's and Respondent's present addresses, during the past five years, the children have resided with the following persons at the following addresses; a. From 2002 at Regency Woods North, Carlisle, Pennsylvania with Respondent; and b. From 2003 at Paxton Street Home, Harrisburg, Pennsylvania with the Respondent. The mother of the children is the Respondent, Laureen M. Ulrich, who resides at 737 Hummel Avenue, Lemoyne, Pennsylvania, The father of the children is the Petitioner, Keith P, Ulrich, who resides at 25 Regency Woods North, Carlisle, Pennsylvania. 5, The relationship of Petitioner to the children is that of father, He is unmarried and currently resides with Chad C. Ulrich who has resided with him since August 1, 2004. 6. The relationship of the Respondent to the children is that of mother, She is unmarried and currently resides with Chelsea M. Ulrich and a friend, Esther (last name unknown) and Esther's son, Britt. 7. The Petitioner has previously participated in litigation concerning custody of the above-named children in this Court at the above-referenced docket. An Order of Court was entered on September 3, 1998. Said Order is cited in Paragraph 3 above and is attached hereto as Exhibit "A" and by reference incorporated herein, The Petitioner has no knowledge of any custody proceedings concerning the custody of the children pending before this or any other Court. The Petitioner does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 8. Petitioner requests the following changes be made to the September 3, 1998 Custody Order; a) Petitioner requests primary physical custody of Chad C. Ulrich and Chelsea M. Ulrich; and b) Petitioner requests that Respondent be ordered not to move from the immediate area with the minor children. 9, Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action, There are no other persons who are known to have or claim a right to custody or visitation of the children. 10. The best interests and permanent welfare of the children will be met if the custody order is modified as requested because; a) The Petitioner is a fit parent who can take care of the children; b) The Petitioner can provide the children with a home with adequate moral, emotional and physical surroundings as required to meet his needs; and c) The Petitioner is, and has always been, willing to accept primary physical custody of the children. WHEREFORE, the Petitioner respectfully requests Your Honorable Court modify the Custody Order dated September 3, 1998 as requested. h t , Esquire Attomey ID No, 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Petitioner Respectfully submitted, KNICYNT-r, ASSOCIA PC, t.?Seatf' . S ul z VERIFICATION I VERIFY that the statements set forth in the attached document are true and correct to the best of my knowledge, infonnation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities, Date; I Z I DS c ? ?? K 'th P. Ulrich A1, • vlla L. - evsiw LhUREEN M. ULRICH, s Plaintiff s : V. s s KEITH P. UL,RICH, Defendant IN RE: CUSTODY Ito THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ° LAW No. 98-21.18 CIVIL TERM ORDER OF COUljT AND NOW, this 3rd clay of September, 1998, this matter having been called on a hearing regarding the custody of Chad C. Ulrich, born October 17, 1990, and Chelsea M. Ulrich, horn August 12, 1994, and the parties representing that they are living in the same home with the children but are separated within that home, and that they have reached an agreement regarding the custody of the children given their current situation, IT IS ORDERED! 1.. The custody order of July 7, 1998, is vacated and replaced with this order. 2. Legal custody of Chad and Chelsea shall be shared between the mother, Laureen M. Ulrich, and the father, Keith P. Ulrich. 3. The mother and father shall have shared physical custody of Chad and Chelsea on alternate weekends, as the parties shall agree, to coincide with the mother's anticipated every other weekend work schedule; on alternating holidays, which holidays are to alternate each year. 4. Tho parties acknowledge that if either or both of them were to move from their current home they would have to make an alternate arrangement for the custody of their children or seek an amendment to this court order. 3. Neither party shell disparage the other in the presence of the children. By the Co?i Edgar. Ba 1ey, J. Jacqueline M, Verney, Esquire For Plaintiff Michael J. Hanft, Esquire For Defendant Sheriff :prs TRUE COPY FROM RECORD In Test;mvy ' M r:.of, I here unto set my hand and the seal of siA Court at Carlisle, Pa. t9.98 ..This .,3.4 day of, .....1 rr .... fit..,.,,...w.. Protho tart' LAUREEN M. ULRICII, : IN THE COURT Of COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW t No. 48-2118 KEITH P. ULRICH, : Defendant IN CUSTODY To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the plaintiff, L,aureen M, Ulrich, in the above captioned case. Respectfully Submitted, IRWIN & McKNIGHT Douglas ) Miller, Esquire Supreme Court I,D, No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 August,,I_,, 2005 CERTIFICATE OF SERVICE 1, Douglas G. Miller, Esquire, do hereby certil'y that 1 have served a true 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; SEAN M, SHULTZ, ESQUIRE KNIGHT & ASSOCIATES, P.C. I I ROADWAY DRIVE SUITE B CARLISLE, PA 17013 Date; August , 2005 IRWIN & McKNIGHT Douglas G (Miller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 .. ..-`.??-A4 GARY MCKEE and ; IN THE COURT OF COMMON PLEAS ROXANN McKEE, OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs ; V. ; No, 98-3633 - Civil COUNTRY SIDE VILLAGE HOMES, INC., CIVIL ACTION LAW Defendant ; PRAECIPE TO WITHDRAW MOTION Please withdraw Defendant's Motion for Liquidated Damages, which was filed on March 1.6, 2005, The parties have amicably resolved the matter raised in the Defendant's Motion and no further action is required by the Court, Respectfully submitted, j J athan H, Rtidd, Esquire-- Nees Wallace & Nuri.ck LLC 00 Pine Street P.O. Box 1166 Harrisburg, PA 1.7108-1166 (717) 237-5405 Attorneys for Defendant Country Side Village Homes, Inc, Date;, July 29, 2005 CERTIFICATE OF SERVICE I, Jonathan H. Rudd, Esquire, hereby certify that on this 29`" day of July, 2005, a true and correct copy of the foregoing document was served by facsimile and first-class, United States mail, postage prepaid, upon the following: Gerald Robinson, Esquire Robinson & Geraldo 4407 North Front Street Harrisburg, PA 17110 r LAUREEN M, ULRICH Plainliff vs, KEITH P. ULRICH Defendant YRECLIVED SEP 092005 IN THE COURT OF COMMON PLEAS OF CUMBFRLAND COUNTY, PENNSYLVANIA 98-2118 CIVIL ACTION LAW IN CUSTODY ORDFR OF COURT AND NOW, this day of s: upon consideration of the attached Custody Conciliation Rcport, i As tiered and dire tad as follow2005, I. The parties shall submit themselves, their minor Children and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by a professional selected by agreement between the parties. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will host serve the needs of the parties' daughter, Chelsea, in light of the Father's request for primary physical custody of the Child, The costs of the evaluation shall be equally shared between the parties with the exception that the Mother shall be responsible to pay the costs of any individual sessions for the Mother's husband following his initial individual session with the evaluator. 2. Pending completion of the custody evaluation and further Order of Court or agreement of the parties, the Mother shall continue to have primary physical custody of Chelsea Ulrich, born August 12, 1994 and the Father shall continue to have primary physical custody of Chad Ulrich, bom October 17, 1990, with the parties having custody of both Children on alternating weekends from Friday after work until Sunday at 8:00 p.m. In addition, unless otherwise agreed between the parties, the Father shall have partial custody of Chelsea from 3:00 p.m, until 6:00 p.m, every Wednesday and the Mother shall have partial custody of Chad for a three hour period each week, with the specific weekday to be arranged by agreement between the parties. 3. Pending completion of the custody evaluation and further Order of Court or agreement of the parties, the Mother shall enroll Chelsea in either public or private school and shall not initiate a homesehooling program for the Child, 4, Within 60 days of receipt of the evaluator's written custody recommendations, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary to further review the custody arrangements, 1k c Gi a 0 0 0• a a ?a to ?? Gi Q'1 O t Gi W F ?G ?G S°i C QQ? `?G 0G p ?rG 0? Off` 5 ?C0 ? ?JO O M LAUREEN M, ULRICH Plaintiff Vs, KEITH P, ULRICH Defendant Prior Judge: Edgar B, Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98.2118 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF' CIVIL PROCEDURE 19153-8, the undersigned Custody Conciliator submits the following report: follows: 1. The pertinent information concerning the Children who are the subjects of this litigation is as NAMF. DATE OF BIRTH CURRENTLY IN CUSTODY OF Chad C, Ulrich October 17, 1990 Father Chelsea M, Ulrich August 12, 1994 Mother 2, A conciliation conference was hold on August 16, 2005, with the following individuals in attendance: The Mother, Laureen M. Ulrich, with her counsel, Douglas Miller, Esquire, and the Father, Keith P. Ulrich, with his counsel, Sean M. Shultz, Esquire, 3, A telephone conference was held on August 23, 2005 between Judge Bayley, counsel for both parties and the conciliator in order to obtain guidance on the issue of schooling for Chelsea pending completion of the custody evaluation. The conciliator received a request from counsel on August 30, 2005 to hold this matter to allow further discussion of exchange times for weekend periods of custody. Having received no further contact on that issue, recommended exchange times are included in the proposed Order, 4. The conciliator recommends an Order in the form as attached. -stiakizike4 6?L Date Dawn S, Sunday, Esquire Custody Conciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAUREEN M. ULRICH, Respondent V. KEITH P. ULRICH, Petitioner CIVIL ACTION - LAW IN CUSTODY NO. 98-2118 NOTICE 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 attorney 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 requested 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 NOTICIA Le ban demandado a usted en la Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la Corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la Corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualguier queja. o alivio que es pedido en lapeticion de demanda. Usted puede perder dinero o sus propiendades o otros derechos importantes para usted. LLEVEESTADEMANDAAUNABOGADOIMMEDIATAIVIENTE. SINOTIENEABOGADO O SI NO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONAL O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PAPA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 KNIGHT & ASSOCIATES, P. ean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAUREEN M. ULRICH, Respondent CIVIL ACTION - LAW V. IN CUSTODY KEITH P. ULRICH, Petitioner NO. 98-2118 PETITION TO MODIFY CUSTODY AND NOW, this ? day of July, 2005, comes the Petitioner, Keith P. Ulrich, by and through his attorneys, Knight & Associates, P.C., and files the following Petition to Modify Custody and in support thereof avers as follows: 1. The Petitioner is Keith P. Ulrich, an adult individual residing at 25 Regency Woods North, Carlisle, Pennsylvania 17013. 2. The Respondent is Laureen M. Ulrich, an adult individual residing at 737 Hummel Avenue, Lemoyne, Pennsylvania 17043. 3. Petitioner seeks amodification ofthe Order of Court dated September 3, 1998, a copy of which is attached hereto and made a part hereof and is marked as Exhibit "A." 4. The Parties are the natural parents of the following minor children: Name Present Residence Age DOB Chad C. Ulrich 25 Regency Woods North 14 October 17, 1990 Carlisle, Pennsylvania 17013 Chelsea M. Ulrich 737 Hummel Avenue 10 August 12, 1994 Lemoyne, Pennsylvania 17043 Chad C. Ulrich was born out of wedlock. Chad C. Ulrich is presently in the physical custody of the Petitioner and Chelsea M. Ulrich is presently in the physical custody of the Respondent. In addition to Petitioner's and Respondent's present addresses, during the past five years, the children have resided with the following persons at the following addresses: a. From 2002 at Regency Woods North, Carlisle, Pennsylvania with Respondent; and b. From 2003 at Paxton Street Home, Harrisburg, Pennsylvania with the Respondent. The mother of the children is the Respondent, Laureen M. Ulrich, who resides at 737 Hummel Avenue, Lemoyne, Pennsylvania. The father of the children is the Petitioner, Keith P. Ulrich, who resides at 25 Regency Woods North, Carlisle, Pennsylvania. 5. The relationship of Petitioner to the children is that of father. He is unmarried and currently resides with Chad C. Ulrich who has resided with him since August 1, 2004. 6. The relationship ofthe Respondent to the children is that of mother. She is unmarried and currently resides with Chelsea M. Ulrich and a friend, Esther (last name unknown) and Esther's son, Britt. 7. The Petitioner has previously participated in litigation concerning custody of the above-named children in this Court at the above-referenced docket. An Order of Court was entered on September 3, 1998. Said Order is cited in Paragraph 3 above, and is attached hereto as Exhibit "A" and by reference incorporated herein. The Petitioner has no knowledge of any custody proceedings concerning the custody of the children pending before this or any other Court. The Petitioner does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. S. Petitioner requests the following changes be made to the September 3,1998 Custody Order: a) Petitioner requests primary physical custody of Chad C. Ulrich and Chelsea M. Ulrich; and b) Petitioner requests that Respondent be ordered not to move from the immediate area with the minor children. 9. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. There are no other persons who are known to have or claim a right to custody or visitation of the children. 10. The best interests and permanent welfare of the children will be met if the custody order is modified as requested because: a) The Petitioner is a fit parent who can take care of the children; b) The Petitioner can provide the children with a home with adequate moral, emotional and physical surroundings as required to meet his needs; and c) The Petitioner is, and has always been, willing to accept primary physical custody of the children. WHEREFORE, the Petitioner respectfully requests Your Honorable Court modify the Custody Order dated September 3, 1998 as requested. Respectfully submitted, YShu SSOCIAT P. tz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Petitioner VERIFICATION I VERIFY that the statements set forth in the attached document are true and correct to the best of my knowledge, information and belief. I understand that: false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities. i Date: }I?ZI D5 K ' P. Ulrich Ole - vlncL. - e"s' LAUREEN M. ULRICH, Plaintiff V. KEITH P. ULRICH, Defendant IN RE: CUSTODY IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 98-2118 CIVIL TERM ORDER OF COURT AND NOW, this 3rd day of September, 1998, this matter having been called on a hearing regarding the custody of Chad C. Ulrich, born October 17, 1990, and Chelsea M. Ulrich, born August 12, 1994, and the parties representing that they are living in the same home with the children but are separated within that home, and that they have reached an agreement regarding the custody of the children given their current situation, IT IS ORDERED: 1. The custody order of July 7, 1998, is vacated and replaced with this order. 2. Legal custody of Chad and Chelsea shall be shared between the mother, Laureen M. Ulrich, and the father, Keith P. Ulrich. 3. The mother and father shall have shared physical custody of Chad and Chelsea on alternate weekends, as the parties shall agree, to coincide with the mother's anticipated every other weekend work schedule; on alternating holidays, which holidays are to alternate each year. 4. The parties acknowledge that if either or both of them were to move from their current home they would have to make an alternate arrangement for the custody of their children or seek an amendment to this court order. 5. Neither party shall disparage the other in the presence of the children. Jacqueline M. Verney, Esquir For Plaintiff Michael J. Hanft, Esquire For Defendant Sheriff :prs TRUE COPY FROM RECORD In Testnm ny h r-.;of, I here unto set my hand and the seal of said Court at Carlisle, Pa. This ..... . (.. day of....Z 19...Fe ?.. ^ ,u...... .. Protho tary -4Q (? crZ t =r G {IF?' LS 're.? t r_ T? LAUREEN M. ULRICH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH P. ULRICH DEFENDANT 98-2118 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, July 22, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, August 16, 2005 at 2:00 PM 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dann S. Sunday, Esq. Jy Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information 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 conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 _Ni?o ?rrlj_I LAUREEN M. ULRICH, Plaintiff V. KEITH P. ULRICH, Defendant To Curtis R. Long, Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 98-2118 IN CUSTODY Please enter my appearance on behalf of the Plaintiff, Laureen M. Ulrich, in the above captioned case. Respectfully Submitted, IRWIN & McKNIGHT f Douglas (Y Miller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 August, 2005 CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true 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: SEAN M. SHULTZ, ESQUIRE KNIGHT & ASSOCIATES, P.C. 11 ROADWAY DRIVE SUITE B CARLISLE, PA 17013 Date: August Is '2005 IRWIN & McKNIGHT Douglas Miller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 7 W W r YRECEIVED SEP 0 92995 LAUREEN M. ULRICH IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 98-2118 CIVIL ACTION LAW KEITH P. ULRICH Defendant IN CUSTODY ORDER OF COURT AND NOW, this _ 11 day of <z,, 6z , 2005, upon consideration of the attached Custody Conciliation Report, i is ck&red and dire ted as follows: 1. The parties shall submit themselves, their minor Children and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by a professional selected by agreement between the parties. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best serve the needs of the parties' daughter, Chelsea, in light of the Father's request for primary physical custody of the Child. The costs of the evaluation shall be equally shared between the parties with the exception that the Mother shall be responsible to pay the costs of any individual sessions for the Mother's husband following his initial individual session with the evaluator. 2. Pending completion of the custody evaluation and further Order of Court or agreement of the parties, the Mother shall continue to have primary physical custody of Chelsea Ulrich, born August 12, 1994 and the Father shall continue to have primary physical custody of Chad Ulrich, born October 17, 1990, with the parties having custody of both Children on alternating weekends from Friday after work until Sunday at 8:00 p.m. In addition, unless otherwise agreed between the parties, the Father shall have partial custody of Chelsea from 3:00 p.m. until 6:00 p.m. every Wednesday and the Mother shall have partial custody of Chad for a three hour period each week, with the specific weekday to be arranged by agreement between the parties. 3. Pending completion of the custody evaluation and further Order of Court or agreement of the parties, the Mother shall enroll Chelsea in either public or private school and shall not initiate a homeschooling program for the Child. 4. Within 60 days of receipt of the evaluator's written custody recommendations, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary to further review the custody arrangements. 5. 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 BURT, d Edgar B. Bayley cc: Douglas Miller, Esquire - Counsel for Mother Sean M. Shultz, Esquire - Counsel for Father ..- ?7 «_ :- ??-? "? ??,. ? -- A? ?, ?, - `? ti,; `;? L? LAUREEN M. ULRICH Plaintiff VS. KEITH P. ULRICH Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-2118 C17VIL ACTION LAW IN CUSTODY 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Chad C. Ulrich October 17, 1990 Father Chelsea M. Ulrich August 12, 1994 Mother 2. A conciliation conference was held on August 16, 2005, with the following individuals in attendance: The Mother, Laureen M. Ulrich, with her counsel, Douglas Miller, Esquire, and the Father, Keith P. Ulrich, with his counsel, Sean M. Shultz, Esquire. 3. A telephone conference was held on August 23, 2005 between Judge Bayley, counsel for both parties and the conciliator in order to obtain guidance on the issue of schooling for Chelsea pending completion of the custody evaluation. The conciliator received a request from counsel on August 30, 2005 to hold this matter to allow further discussion of exchange times for weekend periods of custody. Having received no further contact on that issue, recommended exchange times are included in the proposed Order. 4. The conciliator recommends an Order in the form as attached. 6 ,-)Cos Date Dawn S. Sunday, Esquire Custody Conciliator LAUREEN M. ULRICH, : IN THE COURT OF COMMON PLEAS OF PlaintiffRRespondent : CUMBERLAND COUNTY, PENNSYLVANIA VS. : 98-2118 CIVIL ACTION LAW KEITH P. ULRICH, Defendant/Petitioner : IN CUSTODY TO THE HONORABLE EDGAR B. BAYLEY, JUDGE OF SAID COURT: EMERGENCY PETITION FOR SPECIAL RELIEF AND NOW, this da of August, 2008, comes Petitioner, Keith P. Ulrich, by and through his attorney, Wendy J. F. Grella, Esquire, and petitions the Court as follows: 1. Defendant/Petitioner is Keith P. Ulrich, an adult individual currently residing at 25 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. 2. PlaintiffRRespondent is Laureen M. Ulrich-Baltaeff, an adult individual currently residing at 70 Barre Drive, Lancaster, Lancaster County, Pennsylvania. 3. The parties are the natural parents of two (2) children, namely, Chad C. Ulrich, bom October 17, 1990, and Chelsea M. Ulrich, born August 12, 1994. 4. Petitioner has exercised primary physical custody of Chad C. Ulrich since approximately August, 2004. 5. On August 16, 2005, the parties appeared before Dawn S. Sunday, Esquire, for the purpose of a Custody Conciliation. 6. As a result of the Conciliation an Order of Court was entered directing the parties to submit themselves, the minor children and any other individuals deemed necessary by the evaluator to a custody evaluation. 7. Additionally, the Order granted Mother primary physical custody of Chelsea, granted Father primary physical custody of Chad and ordered the parties having custody of both children on alternating weekends from Friday after work until Sunday at 8:00 p.m. and granting Father partial custody of Chelsea from 3:00 p.m. until 6:00 p.m. every Wednesday and Mother to have partial custody of Chad for a three hours period each week, with the specific weekday to be arranged by agreement of the parties. (See Order of Court dated September 13, 2005, attached hereto as Exhibit "A"). 8. Additionally, Your Honorable Court directed Mother to enroll Chelsea in either public or private school and not to initiate a homeschooling program for the child. (See paragraph 3 of the attached Order of Court). 9. Petitioner feels there are emergency circumstances necessitating that a hearing be conducted and that the Order of Court currently in effect be modified to allow him to have primary physical custody of both children. 10. Petitioner alleges that it is in the minor children' best interest that he be granted primary physical custody of both children for the following reasons: A. Mother recently informed Petitioner that she plans on enrolling Chelsea in a homeschooling program for the 2008-2009 school year in direct violation of Your Honorable Court's Order of September 13, 2005; B. The minor child, Chelsea, has informed Petitioner that Mother may be moving to Delaware County sometime in the near future; when questioned about this issue, Mother has refused to either confirm or deny this allegation; It should be noted that Mother previously relocated the minor child, Chelsea, to Lancaster, Pennsylvania without father's consent; C. Since relocating and being in Mother's care, Chelsea has attempted to commit suicide; D. Mother ceased Chelsea's counseling sessions with Ms. Nancy Rogers, licensed psychologist, even though Chelsea has requested to continue with the sessions; Father feels it would be in Chelsea's best interests for her to immediately recommence her counseling sessions with Ms. Nancy Rogers; E. It is believed and therefore averred that Chelsea is suffering extreme emotional and mental anguish while residing with her Mother and counsel is suggesting that Chelsea undergo a psychological evaluation and recommence her counseling sessions as soon as possible with Ms. Rogers; F. In the past, Chelsea has attempted to run away from her mother's home but her brother stopped her; G. Chelsea struggles with the atmosphere at Mother's house i.e. her relationship with her stepfather and his harsh forms of discipline; H. Since relocating Chelsea has failed a school grade; I. Chelsea has expressed a desire for her Father to have primary, physical custody of her; and J. Chelsea is desirous of spending more time with her brother Chad. 11. Counsel for Respondent, Douglas Miller, Esquire, has been provided with a copy of this Petition by facsimile correspondence prior to filing. WHEREFORE, Defendant/Petitioner respectfully requests Your Honorable Court to enter an Order of Court providing him with primary physical and legal custody of the children and allowing Respondent periods of custody of Chelsea on alternating weekends pending further Order of Court. Respectfully submitted, KAO? Wendy J. F. Grell Attorney for Defe 3618 N. Sixth Str t P.O. Box 5292 Harrisburg, PA 17110 (717) 234-6001 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsifications to authorities. DATE:--1ST - H P. ULRICH EXHIBIT "A" LAUREEN M. ULRICH Plaintiff VS. KEITH P. ULRICH Defendant RECEIVED 5EP 0 9 2005 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-2118 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this day of 6 b -e 2005, upon consideration of the attached Custody Conciliation Report, f is ordered and directed as follows: 1. The parties shall submit themselves, their minor Children and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by a professional selected by agreement between the parties. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best serve the needs of the parties' daughter, Chelsea, in light of the Father's request for primary physical custody of the Child. The costs of the evaluation shall be equally shared between the parties with the exception that the Mother shall be responsible to pay the costs of any individual sessions for the Mother's husband following his initial individual session with the evaluator. 2. Pending completion of the custody evaluation and further Order of Court or agreement of the parties, the Mother shall continue to have primary physical custody of Chelsea Ulrich, born August 12, 1994 and the Father shall continue to have primary physical custody of Chad Ulrich, born October 17, 1990, with the parties having custody of both Children on alternating weekends from Friday after work until Sunday at 8:00 p.m. In addition, unless otherwise agreed between the parties, the Father shall have partial custody of Chelsea from 3:00 p.m. until 6:00 p.m. every Wednesday and the Mother shall have partial custody of Chad for a three hour period each week, with the specific weekday to be arranged by agreement between the parties. 3. Pending completion of the custody evaluation and further Order of Court or agreement of the parties, the Mother shall enroll Chelsea in either public or private school and shall not initiate a homeschooling program for the Child. 4. Within 60 days of receipt of the evaluator's written custody recommendations, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary to further review the custody arrangements. 5. 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, l J, Edgar . yley J. / cc: Douglas Miller, Esquire - Counsel for Mother Sean M. Shultz, Esquire - Counsel for Father TR'E'E '..s0 -Y FRO !" RECORD -10 qal my tod ?e .,Vier 4Zv •:'?i •.. ,. .. .. ?i%ti! at ?V,C 1151e. P'& LAUREEN M. ULRICH Plaintiff vs. KEITH P. ULRICH Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-2118 CIVIL ACTION LAW IN CUSTODY 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Chad C. Ulrich October 17, 1990 Father Chelsea M. Ulrich August 12, 1994 Mother 2. A conciliation conference was held on August 16, 2005, with the following individuals in attendance: The Mother, Laureen M. Ulrich, with her counsel, Douglas Miller, Esquire, and the Father, Keith P. Ulrich, with his counsel, Sean M. Shultz, Esquire. 3. A telephone conference was held on August 23, 2005 between Judge Bayley, counsel for both parties and the conciliator in order to obtain guidance on the issue of schooling for Chelsea pending completion of the custody evaluation. The conciliator received a request from counsel on August 30, 2005 to hold this matter to allow further discussion of exchange times for weekend periods of custody. Having received no further contact on that issue, recommended exchange times are included in the proposed Order. 4. The conciliator recommends an Order in the form as attached. 51-4k!nj? ?G S Date Dawn S. Sunday, Esquire Custody Conciliator E li G7 1ka S+? ILI d LAUREEN M. ULRICH, PLAINTIFF/RESPONDENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH P. ULRICH, DEFENDANT/PETITIONER : 98-2118 CIVIL TERM ORDER OF COURT AND NOW, this day of August, 2008, the petition of Keith Ulrich to handle this custody case on an emergency basis, IS DENIED. The within petition shall be treated as a petition to modify a custody order. The Court Administrator shall assign the case to a custody conciliator who shall schedule a hearing. The provisions of the order of September 13, 2005, shall remain in effect pending further order of court. ouglas Miller, Esquire For Plaintiff/Respondent .>Ode dy J.F. Grella, Esquire For Defend ant/Petitioner .06urt Administrator CI'na:Nkroory1) :sal CYN Ll- x -l LL. C= :2 Q o C14 0 C , - LAUREEN M. ULRICH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH P. ULRICH DEFENDANT 1998-2118 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Thursday, August 14, 2008 , upon consideration of the attached Complaint, it is herebyAirected that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, September 18, 2008 at 10:30 AM 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/, Dawn S. Sunda Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information 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 conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 VINIVA? ASNN3d '. woo z Z •Zf Wd S i 9nv 8002 AUV! UNk--?,A i.i ?U'ci 3Hi 30 ?-01440-031U LAUREEN M. ULRICH, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA vs. : 98-2118 CIVIL ACTION LAW KEITH P. ULRICH, Defendant/Petitioner : IN CUSTODY TO THE HONORABLE EDGAR B. BAYLEY, JUDGE OF SAID COURT: PETITION FOR CIVIL, CONTEMPT FOR DISOBEDIENCE OF COURT ORDERS AND REQUEST FOR ATTORNEY'S FEES AND NOW, this ?qQy of September, 2008, comes Defendant/Petitioner Keith P. Ulrich by and through his counsel of record, Wendy J. F. Grella, Esquire, and represents as follows: 1. Petitioner is the above named Defendant, Keith P. Ulrich, an adult individual currently residing at 25 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. 2. Respondent is the above named Plaintiff, Laureen M. Ulrich, an adult individual currently being represented by Douglas Miller, Esquire and currently residing at 70 Barre Drive, Lancaster, Lancaster County, Pennsylvania. 3. The parties are the natural parents of two (2) children, namely, Chad C. Ulrich, born October 17, 1990, and Chelsea M. Ulrich, born August 12, 1994. 4. Petitioner has exercised primary physical custody of the parties' minor son, Chad C. Ulrich since approximately August, 2004. 5. On August 16, 2005, the parties appeared before Dawn S. Sunday, Esquire, for the purpose of a Custody Conciliation. 6. As a result of the Conciliation an Order of Court was entered directing the parties to submit themselves, the minor children and any other individuals deemed necessary by the evaluator to a custody evaluation. 7. Additionally, the Order granted Mother primary physical custody of Chelsea, granted Father primary physical custody of Chad and ordered the parties having custody of both children on alternating weekends from Friday after work until Sunday at 8:00 p.m. and granting Father partial custody of Chelsea from 3:00 p.m. until 6:00 p.m. every Wednesday and Mother to have partial custody of Chad for a three hours period each week, with the specific weekday to be arranged by agreement of the parties. (See Order of Court dated September 13, 2005, attached hereto as Exhibit "A"). 8. Additionally, Your Honorable Court directed Mother to enroll Chelsea in either public or private school and not to initiate a homeschooling program for the child. (See paragraph 3 of the attached Order of Court). 9. On or about August 7, 2008, Defendant/Petitioner filed an Emergency Petition for Special Relief requesting primary physical custody of both children citing several reasons for the request including Mother's intention to enroll Chelsea in a homeschooling program for the 2008-2009 school year in direct violation of Your Honorable Court's Order of September 13, 2005. 10. Your Honorable Court issued an Order of Court dated August 11, 2008, denying the petition to handle the custody case on an emergency basis and indicating that the petition shall be treated as a petition to modify a custody order and directed the Court Administrator to assign the case to a custody conciliator to schedule a hearing. 11. The August 11, 2008 Order of Court also indicated, "The provisions of the order of September 13, 2005, shall remain in effect pending further order of court." (See Order of Court dated August 11, 2008, attached hereto as Exhibit `B"). 12. Since entry of the August 11, 2008 Order of Court, Plaintiff/Respondent Mother has willfully failed to abide by Your Honorable Courts' two (2) previous Orders and has enrolled Chelsea in a homeschooling program for the 2008-2009 school year. 13. Mother has done so without filing a Petition to Modify the existing Order of Court. 14. Undersigned counsel believes it is in the best interests of the minor child that Your Honorable Court immediately order that Chelsea Ulrich be enrolled in either public or private school as the Orders indicate. 15. It is assumed Respondent Mother does not concur in the request for contempt. 16. Counsel for Respondent, Douglas Miller, Esquire, has been provided with a copy of this Petition by facsimile correspondence prior to filing. WHEREFORE, Petitioner respectfully requests Your Honorable Court hold Respondent, Laureen M. Ulrich, in Contempt of Court, Order that Chelsea Ulrich be enrolled in either private or public school, and Order payment of Defendant/Petitioner's attorney's fees. Respectfully Wendy J. F. Counsel for P.O. Box 4? Harrisburg, PA 17111 (717) 576-0549 Fax: (717) 558-8439 EXHIBIT ``A" RECEIVED SEP 0 92005 LAUREEN M. ULRICH Plaintiff VS. KEITH P. ULRICH Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-2118 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this I? day of " , 2005, upon consideration of the: attached Custody Conciliation Report, f is ordered and directed as follows: 1. The parties shall submit themselves, their minor Children and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by a professional selected by agreement between the parties. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best serve the needs of the parties' daughter, Chelsea, in light of the Father's request for primary physical custody of the Child. The costs of the evaluation shall be equally shared between the parties with the exception that the Mother shall be responsible to pay the costs of any individual sessions for the Mother's husband following his initial individual session with the- evaluator. 2. Pending completion of the custody evaluation and further Order of Court or agreement of the parties, the Mother shall continue to have primary physical custody of Chelsea Ulrich, born August 12, 1994 and the Father shall continue to have primary physical custody of Chad Ulrich, born October 17, 1990, with the parties having custody of both Children on alternating weekends from Friday after work until Sunday at 8:00 p.m. In addition, unless otherwise agreed between the parties, the Father shall have partial custody of Chelsea from 3:00 p.m. until 6:00 p.m. every Wednesday and the Mother shall have partial custody of Chad for a three hour period each week, with the specific weekday to be arranged by agreement between the parties. 3. Pending completion of the custody evaluation and further Order of Court or agreement of the parties, the Mother shall enroll Chelsea in either public or private school and shall not initiate a homeschooling program for the Child. 4. Within 60 days of receipt of the evaluator's written custody recommendations, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary to further review the custody arrangements. 5. 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, t. O-A'k4 - 6, , Edgar yley J. j cc: Douglas Miller, Esquire - Counsel for Mother Sean M.'Shultz, Esquire - Counsel for Father TRUE f-,011"Y FROM RECORD LAUREEN M. ULRICH Plaintiff vs. KEITH P. ULRICH Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 98-2118 CIVIL ACTION LAW IN CUSTODY C_ UST.ODY CONCILIATION SUMIVIARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody. Conciliator submits the following report: The pertinent information concerning the Children who are the subjects of this litigation is as follows: NA DATE OF BIRTH CURRENTLY IN CUSTODY OF Chad C. Ulrich October 17, 1990' Father Chelsea M. Ulrich August 12; 1994 Mother 2. A conciliation conference was held on August 16, 2005, with the following individuals in attendance: The Mother, Laureen M. Ulrich, with her counsel, Douglas Miller, Esquire, and the Father, Keith P. Ulrich, with his counsel, Sean M. Shultz, Esquire. 3. A telephone conference was held on August 23, 2005 between Judge Bayley, counsel for both parties and the conciliator. in order to obtain guidance on the issue of schooling for Chelsea pending completion of the custody evaluation. The conciliator received a request from counsel on August 30, 2005 to hold this matter to allow further discussion of exchange times for weekend periods of custody. Having received no further contact on that issue, recommended exchange times are included in the proposed Order. 4. The conciliator recommends an Order in the form as attached. fif Date Dawn S. Sunday, Esquire Custody Conciliator EXHIBIT "B" LAUREEN M. ULRICH, PLAINTIFF/RESPONDENT V. KEITH P. ULRICH, DEFENDANT/PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-2118 CIVIL TERM ORDER OF COURT AND NOW, this day of August, 2008, the petition of Keith Ulrich to handle this custody case on an emergency basis, IS DENIED. The within petition shall be treated as a petition to modify a custody order. The Court Administrator shall assign the case to a custody conciliator who shall schedule a hearing. The provisions of the order of September 13, 2005, shall remain in effect pending further order of court. Douglas Miller, Esquire For Plaintiff/Respondent Wendy J.F. Grella, Esquire For Defendant/Petitioner Court Administrator :sal By th Edgar B. Bayley, J. TRUE "COPY MOM RECORD In Ta ttony-wherrr f, I ht.TS "-lo s€t my hand and 0 sue} of said Coo - arlisle;-Pa. f VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsifications to authorities. O p- DATE: gl ZZ Keith P. Ulrich, Defendant/Petitioner CERTIFICATE OF SERVICE AND NOW, this Lk' " `day of September 2008, I, Wendy J. F. Grella, Esquire hereby certify that on the date listed below, I did serve a copy of the foregoing upon the following persons at the following addresses by sending same in the United States mail, first-class, postage-paid: Douglas Miller, Esquire Irwin & McKnight West Pomfret Professional Building 60 West Pomfret Street Carlisle, PA 17013-3222 r '?' ? ? ?-I ? ?}? f it ?,:. ?' 8 r' ?? ., , .- CJ , . r- - , - ` :, ?., n °^. '?. ? ? r.,? ; LAUREEN M. ULRICH k/n/a LAUREEN M. BALTAEFF, Plaintiff / Respondent V. KEITH P. ULRICH, Defendant / Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 1998 - 2118 IN CUSTODY ANSWER TO DEFENDANT'S EMERGENCY PETITION FOR SPECIAL RELIEF AND NOW this 8th day of September, 2008, comes the Respondent, Laureen M. Ulrich k/n/a Laureen M. Baltaeff, by and through her attorneys, Irwin & McKnight, and respectfully files this Answer to the Defendant's Petition for Special Relief, and in support thereof avers as follows: 1. The averments of fact contained in paragraph one (1) of the Petition for Special Relief are admitted. 2. The averments of fact contained in paragraph two (2) are denied as stated. Respondent has remarried and is now known as Laureen M. Baltaeff. 3. The averments of fact contained in paragraph three (3) are admitted. 4. The averments of fact contained in paragraph four (4) are admitted. By way of further answer, Respondent has exercised primary physical custody of Chelsea M. Ulrich for her entire life. 5. The averments of fact contained in paragraph five (5) are admitted. 6. The Order of Court dated September 13, 2005, and referenced in paragraph six (6) speaks for itself and therefore no response is required. To the extent that a response is required, Petitioner's counsel of record at the time was to provide a list of possible custody evaluators. No such list was ever provided and no further contact regarding an evaluation was made by said prior legal counsel. In March of 2007, the undersigned sent correspondence to Petitioner's current legal counsel listing three (3) possible professionals who could perform a custody evaluation. In the eighteen (18) months since that correspondence, absolutely no response was provided by Petitioner or his legal counsel. A true and correct copy of the correspondence to Attorney Grella dated March 1, 2007, is attached hereto and incorporated herein as Exhibit "A." 7. The Order of Court dated September 13, 2005, and referenced in paragraph seven (7) speaks for itself and therefore no response is required. 8. The Order of Court dated September 13, 2005, and referenced in paragraph eight (8) speaks for itself and therefore no response is required. To the extent that a response is required, the relevant portion of the Order of Court reads as follows: "Pending completion of the custody evaluation and further Order of Court or agreement of the parties, the Mother shall enroll Chelsea in either public or private school and shall not initiate a homeschooling program for the Child" (emphasis added). Petitioner did not cooperate with or respond to the Respondent's requests to agree to the selection of a custody evaluator. Instead, Petitioner initially agreed to his daughter being homeschooled in 2007, and she was in fact homeschooled for the entire 2007-08 school year. 9. The averments contained in paragraph nine (9) are conclusions of law to which no response is required. To the extent that a response is required, the averments are specifically denied and strict proof thereof is demanded at trial. 10. The averments contained in the beginning of paragraph ten (10) are conclusions of law to which no response is required. To the extent that a response is required, the averments are specifically denied and strict proof thereof is demanded at trial. A. The averments contained in subparagraph A. are denied as stated. It is admitted that after a successful year of homeschooling in 2007, with which Petitioner initially agreed, Chelsea was reenrolled in the homeschooling program in 2008. The 2 remaining averments of subparagraph A, including any assertion that a violation of the Order of Court has occurred, are specifically denied and strict proof thereof demanded at trial. By way of further answer, Chelsea herself did not wish to return to public or private school, but instead desires to continue her improved academic performance through the homeschooling program. B. The averments contained in subparagraph B. are denied as stated. While Respondent's husband currently works in Delaware County, he is currently in a probationary period and does not know where his future employment will be. Petitioner and his prior legal counsel also knew that Respondent was relocating to Lancaster County with Chelsea at the time of the Custody Conciliation. Petitioner did not object to the relocation and agreed to a location on the eastern side of Harrisburg for custody transfers. The remaining averments of subparagraph B. are specifically denied and strict proof thereof demanded at trial. C. The averments contained in subparagraph C. are specifically denied and strict proof thereof demanded at trial D. The averments contained in subparagraph D. are denied as stated. While Chelsea did treat with Dr. Rogers in the past, Respondent enrolled her with a closer therapist. Upon information and belief, Petitioner informed Chelsea that she should not talk to any therapist in an apparent continuing attempt to disrupt Respondent's primary custody. Petitioner has also intentionally interfered with the insurance reimbursement of the counseling sessions as set forth in the March 2007 letter attached as Exhibit "A." The remaining averments of subparagraph D. are specifically denied and strict proof thereof demanded at trial. E. The averments contained in subparagraph E. are denied as stated. To the extent that Chelsea is suffering emotional and mental anguish, Respondent submits it is due almost exclusively to the constant hostility, interference, and behavior of Petitioner. 3 Said behavior and activity is further identified in the March 2007 letter attached as Exhibit "A." The remaining averments of subparagraph E. are specifically denied and strict proof thereof demanded at trial. F. The averments of subparagraph F. are specifically denied and strict proof thereof demanded at trial. G. The averments contained in subparagraph G. are specifically denied and strict proof thereof demanded at trial. By way of further answer, it is Respondent, and not her husband, that disciplines Chelsea. H. The averments contained in subparagraph H. are denied as stated. Chelsea was previously held back a grade by Respondent because of poor academic performance. Chelsea later admitted that Petitioner previously told her that if she did poorly in school, that it would reflect poorly upon Respondent, and that Chelsea could then live with her brother and Petitioner. The remaining averments of subparagraph H. are specifically denied and strict proof thereof demanded at trial. 1. The averments of subparagraph 1. are specifically denied and strict proof thereof demanded at trial. By way of further answer, Chelsea is in fact often left alone when visiting with Petitioner, as her brother is often out with friends and Petitioner is also often either gone or sleeping. J. The averments of subparagraph J. are denied as stated. While Chelsea is desirous of spending more time with her brother, he is almost 18 and is often away from the home with friends. This desire is not a justification for primary custody to be switched to Petitioner. 11. The averments contained in paragraph eleven (11) are specifically denied and strict proof thereof is demanded at trial. By way of further answer, counsel for Respondent was provided with a copy of the Petition contemporaneously with its filing. Legal counsel for 4 Petitioner did not, however, inform the undersigned in advance that the Petition was to be filed, and did not seek the concurrence of the undersigned as required by Cumberland County Rule of Procedure 208.2(d). In fact, Petitioner's legal counsel has made no attempt to contact the undersigned to discuss the issues raised in either the letter of March 2007 attached as Exhibit "A," or in the instant Petition. WHEREFORE, Respondent, Laureen M. Baltaeff, respectfully requests that this Honorable Court dismiss the Emergency Petition for Special Relief. Respectfully Submitted, IRWIN & McKNIGHT By: A / lil- I & Do as 450. Miller, Esquire Supreme Court ID # 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Attorney for Respondent, Dated: September 8, 2008 Laureen M. Baltaeff 5 VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unworn falsification to authorities. 6 - atkfu-e?? V? - LAUREEN M. BALTAEFF Date: EXHIBIT "A" LAW OFFICES IR WIN & McKNI GHT WEST POMFRET PROFESSIONAL BUILDING 60 WEST POMFRET STREET HAROLD .S IRWIN (1925-1977) ROGER B. IRWIN CARLISLE, PENNSYLVANIA 17013-3222 HAROLD S. IRWIN. JR. t1954-1986) MARCUS A. McKNIGHT, III IRWIN, IRWIN & IRWIN (1956-1986) DOUGLAS G. MILLER (717) 249-2353 IRWIN, IRWIN & MCKNIGHT (19X6-1994) MATTHEW A. McKNIGHT FAX (717) 249-6354 IRWIN, McKNIGHT & HUGHES (1994.2003) WWW IMHLAW.COM IRWIN & McKNIGHT (2003- March 1, 2007 WENDY J. F. GRELLA, ESQUIRE 3618 NORTH 61" STREET P.O. BOX 5292 HARRISBURG, PA 17110 &jPj, _ RE: ULRICH (BALTAEFF) v. ULRICH No. 98 - 2118, In Custody Dear Attorney Grella: Although I have not received any entry of appearance from you, it is my understanding that you are now representing Mr. Ulrich in the above-referenced matter. After the last conciliation conference in this case, I had requested that Mr. Ulrich, through his prior legal counsel, provide me with a list of possible evaluators. I received no further response or contact from Mr. Ulrich or his prior attorney. Per your request, I have discussed with my client a list of possible professionals to perform a custody evaluation in this matter. In no particular order, the individuals are as follows: 1. Deborah Salem, Interworks, 4335 North Front Street, Harrisburg; 2. Eugene Stecher, 473 Lincoln Way East, Chambersburg; and 3. Stanley E. Schneider, Guidance Associates of Pennsylvania, 412 Erford Road, Camp Hill. In addition, my client has asked me to address two additional issues. First, Mr. Ulrich has apparently been extremely hostile in his conversations with my client. Any time there is a need to adjust custody times, whether because of a change in schedules, weather, holidays, or some other unforeseen issue, Mr. Ulrich simply refuses to cooperate to find a mutually agreeable solution. Instead, his response is apparently to yell and swear, and then to further berate Mrs. Ulrich to the children. Such behavior is simply unacceptable and will obviously be raised as part of any custody evaluation. Second, a primary concern with the counseling treatments for Chelsea, as well as other medical treatments for her, is that insurance reimbursements are sent directly to Mr. Ulrich. He has cashed at least $200.00 in such reimbursements for bills that were paid by my client. I am enclosing copies of two (2) invoices paid by Mrs. Ulrich, for which your client cashed the subsequent insurance reimbursements. Because of his actions, Mrs. Ulrich is unable to continue to expend significant sums of money that is not reimbursed to her as it should be. In the event that your client does reimburse Mrs. Ulrich for these funds, I am going to recommend to my WENDY J. F. GRELLA, ESQUIRE RE: ULRICH (BALTAEFF) v. ULRICH March 1, 2007 Page 2 of 2 client that she proceed with obtaining the funds through the legal system. This recommendation will likely start with raising the matter as part of a modification of child support. In addition, I have enclosed an insurance form that Mr. Ulrich needs to sign where indicated in order to permit Chelsea's dentist to be paid directly by the Teamsters. Because of his prior actions in keeping the insurance payments, my client will not be able to obtain dental services for Chelsea without the enclosed form being sign. I would prefer not to have to file a Petition for Special Relief on this issue. I trust that you will be advising your client appropriately on these issues. Thank you for your anticipated assistance and I shall await your response. Very truly yours, IRWIN & McKNIGHT Y AA Douglas G. Miller DGM:tds Enclosures cc: Laureen Baltaeff CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the person indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: Wendy J. F. Grella, Esquire 3618 North Sixth Street P.O. Box 5292 Harrisburg, PA 17110 (Attorney for Petitioner) Date: September 8, 2008 IRWIN & McKNIGHT 9?4)0-Ajk Douglas G(Niller, Esquire Supreme Court ID # 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Attorney for Respondent, Laureen M. Baltaeff LAUREEN M. ULRICH k/n/a LAUREEN M. BALTAEFF, Plaintiff / Respondent V. KEITH P. ULRICH, Defendant / Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 1998 - 2118 IN CUSTODY ANSWER TO DEFENDANT'S PETITION FOR CIVIL CONTEMPT AND REQUEST FOR ATTORNEY'S FEES AND NOW this 8 h day of September, 2008, comes the Respondent, Laureen M. Ulrich k/n/a Laureen M. Baltaeff, by and through her attorneys, Irwin & McKnight, and respectfully files this Answer to the Defendant's Petition for Civil Contempt and Request for Attorney's Fees, and in support thereof avers as follows: 1. The averments of fact contained in paragraph one (1) of the Petition for Special Relief are admitted. 2. The averments of fact contained in paragraph two (2) are denied as stated. Respondent has remarried and is now known as Laureen M. Baltaeff. 3. The averments of fact contained in paragraph three (3) are admitted. 4. The averments of fact contained in paragraph four (4) are admitted. By way of further answer, Respondent has exercised primary physical custody of Chelsea M. Ulrich for her entire life. 5. The averments of fact contained in paragraph five (5) are admitted. 6. The Order of Court dated September 13, 2005, and referenced in paragraph six (6) speaks for itself and therefore no response is required. To the extent that a response is required, Petitioner's counsel of record at the time was to provide a list of possible custody evaluators. No such list was ever provided and no further contact regarding an evaluation was made by said prior legal counsel. In March of 2007, the undersigned sent correspondence to Petitioner's current legal counsel listing three (3) possible professionals who could perform a custody evaluation. In the eighteen (18) months since that correspondence, absolutely no response was provided by Petitioner or his legal counsel. A true and correct copy of the correspondence to Attorney Grella dated March 1, 2007, is attached hereto and incorporated herein as Exhibit "A." 7. The Order of Court dated September 13, 2005, and referenced in paragraph seven (7) speaks for itself and therefore no response is required. 8. The Order of Court dated September 13, 2005, and referenced in paragraph eight (8) speaks for itself and therefore no response is required. To the extent that a response is required, the relevant portion of the Order of Court reads as follows: "Pending completion of the custody evaluation and further Order of Court or agreement of the parties, the Mother shall enroll Chelsea in either public or private school and shall not initiate a homeschooling program for the Child" (emphasis added). Petitioner did not cooperate with or respond to the Respondent's requests to agree to the selection of a custody evaluator. Instead, Petitioner initially agreed to his daughter being homeschooled in 2007, and she was in fact homeschooled for the entire 2007-08 school year. 9. The averments contained in paragraph nine (9) are conclusions of law to which no response is required. To the extent that a response is required, the averments are specifically denied and strict proof thereof is demanded at trial. By way of further answer, Respondent is concurrently filing an Answer to that prior Emergency Petition in order to correct the assertions set forth by the Petitioner. 10. The averments contained in paragraph ten (10) are admitted. 11. The Order of Court dated August 11, 2008, and referenced in paragraph eleven (11) speaks for itself and therefore no response is required. To the extent a response is required, 2 Respondent specifically denies any implication that she has failed to abide by any Orders of this Court, and demands strict proof thereof at trial. 12. The averments contained in paragraph twelve (12) are conclusions of law to which no response is required. To the extent that a response is required, it is admitted that after a successful year of homeschooling in 2007, with which Petitioner initially agreed, Chelsea was reenrolled in the homeschooling program in 2008. The remaining averments of paragraph twelve (12), including any assertion that a violation of the Order of Court has occurred, are specifically denied and strict proof thereof demanded at trial. By way of further answer, Chelsea herself did not wish to return to public or private school, but instead desires to continue her improved academic performance through the homeschooling program. 13. The averments contained in paragraph thirteen (13) are denied as stated. It is admitted that after a successful year of homeschooling in 2007, with which Petitioner initially agreed, Chelsea was reenrolled in the homeschooling program in 2008. The remaining averments of paragraph thirteen (13), including any assertion that a violation of the Order of Court has occurred, are specifically denied and strict proof thereof demanded at trial. 14. The averments in paragraph fourteen (14) are conclusions of law to which no response is required. To the extent that a response is required, the averments are specifically denied and strict proof thereof is demanded at trial. By way of further answer, Petitioner has not seen fit to respond to Respondent and her legal counsel for some eighteen (18) months regarding a custody evaluator, and initially agreed to allow Chelsea to begin a homeschooling program in 2007. Petitioner therefore asserts that she is not in violation of any Orders of this Court. 15. The averments in paragraph fifteen (15) are conclusions of law to which no response is required. 16. The averments contained in paragraph sixteen (16) are specifically denied and strict proof thereof is demanded at trial. By way of further answer, counsel for Respondent was again provided with a copy of this second Petition contemporaneously with its filing. Legal 3 counsel for Petitioner did not, however, inform the undersigned in advance that the Petition was to be filed, and did not seek the concurrence of the undersigned as required by Cumberland County Rule of Procedure 208.2(d). In fact, Petitioner's legal counsel has made no attempt to contact the undersigned to discuss the issues raised in either the letter of March 2007 attached as Exhibit "A," or in the instant Petition. WHEREFORE, Respondent, Laureen M. Baltaeff, respectfully requests that this Honorable Court dismiss the Petition for Civil Contempt and Request for Attorney's Fees. Respectfully Submitted, IRWIN & McKNIGHT i 6.4, By: "-4k= Douglas . M' er, Esquire Supreme Court ID # 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Attorney for Respondent, Dated: September 8, 2008 Laureen M. Baltaeff 4 The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. LAUREEN M. BALTAEFF Date: qlglo;vl EXHIBIT "A" LAW OFFICES IRWIN & McKNIGHT WEST POMFRET PROFESSIONAL BUILDING 60 WEST POMFRET STREET HAROLD S. IRWIN (1925.1977) ROGER B. IRWIN CARLISLE, PENNSYLVANIA 17013-3222 HAROLD S. IRWIN. !R. (/954-/986) MARCUS A. McKNIGHT, III IRWIN. IRWIN & IRWIN (1956-1986) DOUGLAS G. MILLER (717) 249-2353 IRWIN. IRWIN & McKNIGHT (1986-1994) MATTHEW A. McKNIGHT FAX (717) 249-6354 IRWIN. McKNIGHT & HUGHES (1994-2003) WWW IMHL4W.COM IRWIN & McKNIGHT (2003- ) March 1, 2007 WENDY J. F. GRELLA, ESQUIRE 3618 NORTH 6TH STREET P.O. BOX 5292 HARRISBURG, PA 17110 skill '%r RE: ULRICH (BALTAEFF) v. ULRICH No. 98 - 2118, In Custody Dear Attorney Grella: Although I have not received any entry of appearance from you, it is my understanding that you are now representing Mr. Ulrich in the above-referenced matter. After the last conciliation conference in this case, I had requested that Mr. Ulrich, through his prior legal counsel, provide me with a list of possible evaluators. I received no further response or contact from Mr. Ulrich or his prior attorney. Per your request, I have discussed with my client a list of possible professionals to perform a custody evaluation in this matter. In no particular order, the individuals are as follows: 1. Deborah Salem, Interworks, 4335 North Front Street, Harrisburg; 2. Eugene Stecher, 473 Lincoln Way East, Chambersburg; and 3. Stanley E. Schneider, Guidance Associates of Pennsylvania, 412 Erford Road, Camp Hill. In addition, my client has asked me to address two additional issues. First, Mr. Ulrich has apparently been extremely hostile in his conversations with my client. Any time there is a need to adjust custody times, whether because of a change in schedules, weather, holidays, or some other unforeseen issue, Mr. Ulrich simply refuses to cooperate to find a mutually agreeable solution. Instead, his response is apparently to yell and swear, and then to further berate Mrs. Ulrich to the children. Such behavior is simply unacceptable and will obviously be raised as part of any custody evaluation. Second, a primary concern with the counseling treatments for Chelsea, as well as other medical treatments for her, is that insurance reimbursements are sent directly to Mr. Ulrich. He has cashed at least $200.00 in such reimbursements for bills that were paid by my client. I am enclosing copies of two (2) invoices paid by Mrs. Ulrich, for which your client cashed the subsequent insurance reimbursements. Because of his actions, Mrs. Ulrich is unable to continue to expend significant sums of money that is not reimbursed to her as it should be. In the event that your client does reimburse Mrs. Ulrich for these funds, I am going to recommend to my WENDY J. F. GRELLA, ESQUIRE RE: ULRICH (BALTAEFF) v. ULRICH March 1, 2007 Page 2 of 2 client that she proceed with obtaining the funds through the legal system. This recommendation will likely start with raising the matter as part of a modification of child support. In addition, I have enclosed an insurance form that Mr. Ulrich needs to sign where indicated in order to permit Chelsea's dentist to be paid directly by the Teamsters. Because of his prior actions in keeping the insurance payments, my client will not be able to obtain dental services for Chelsea without the enclosed form being sign. I would prefer not to have to file a Petition for Special Relief on this issue. I trust that you will be advising your client appropriately on these issues. Thank you for your anticipated assistance and I shall await your response. Very truly yours, IRWIN & McKNIGHT ? AA Douglas G. Miller DGM:tds Enclosures cc: Laureen Baltaeff CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the person indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: Wendy J. F. Grella, Esquire 3618 North Sixth Street P.O. Box 5292 Harrisburg, PA 17110 (Attorney for Petitioner) Date: September 8, 2008 IRWIN & McKNIGHT ?jk , A i , dl 114 Douglas . Miller, Esquire Supreme Court ID # 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Attorney for Respondent, Laureen M. Baltaeff J T_: y r rw3 =TJ ll'J .. LAUREEN M. ULRICH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 1998-2118 CIVIL ACTION LAW KEITH P. ULRICH IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, September 08, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, September 18, 2008 at 10:30 AM 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information 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 conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 V7.w- ?p 'A? -7??w 3(2,,$. s d.,s , 6 .A ,? 1 :1 Ij;-j 8- 83S BUZ ;? _ 3lHi LAUREEN M. ULRICH Plaintiff vs. KEITH P. ULRICH Defendant OCT 0 3 2008 (? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1998-2118 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ICJ day of 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court dated September 13, 2005 and August 11, 2008 shall continue in effect as modified by this Order. 2. The parties shall initiate and participate in co-parenting counseling with a professional to be selected by agreement between the parties. The purpose of the counseling shall be to assist the parents in establishing sufficient communication and cooperation to enable them to effectively co-parent their Child. The parties shall comply with the recommendations of the counselor as to the frequency and duration of the counseling sessions. 3. The Father's alternating weekend periods of partial custody with Chelsea shall run from Friday at 5:30 p.m. through Sunday at 6:00 p.m., for which the parties shall exchange custody at a mutually acceptable meeting point in Middletown. 4. Neither party shall record the telephone calls of the other party with the Child or interfere with the private telephone conversations between the Child and the other parent. The parties shall cooperate in establishing the timing of the telephone calls with the Child at mutually convenient times which are also not disruptive to the Child's schedule. 5. In the event either party intends to relocate from his or her current residence, that parent shall provide at least sixty (60) days advance notice to the other parent to ensure sufficient opportunity for the parties to make any necessary adjustments to the custodial arrangements due to the relocation or to obtain the assistance of the Court for resolution. 6. Recognizing that the Mother has enrolled the Child in home schooling for the 2008-2009 school year and desiring to minimize disruptions for the Child, the parties agree to temporarily suspend the prior Court ordered enrollment in public or private school and agree that the Child may continue in go. home schooling pending a follow-up custody conciliation conference which may be scheduled pursuant to this Order and further Order of Court or agreement of the parties. 7. This Order is entered without prejudice to the Father's position on the school issue as raised in his Petition for Contempt and Modification. 8. Within ninety (90) days of the date of this Order, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference to further address the school issue, if necessary, following co-parenting counseling. 9. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control cc: ?uglas Miller, Esquire - Counsel for Mother Grella, Esquire - Counsel for Father t?", rndt LCL /0/Z/OS 1 co ? ? N is ? ? 11 Cry ^ y ?r,.+ t ! L'4 LAUREEN M. ULRICH Plaintiff vs. KEITH P. ULRICH Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1998-2118 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Chelsea M. Ulrich August 12, 1994 Mother 2. A custody conciliation conference was held on September 18, 2008, with the following individuals in attendance: the Mother, Laureen M. Baltaeff, formerly Ulrich, with her counsel, Douglas Miller, Esquire, and the Father, Keith P. Ulrich, with his counsel, Wendy Grella, Esquire. 3. The submission of this Report and Order was placed on hold at the request of the Father's counsel to enable the Father to review the Child's grades and obtain additional information prior to confirming agreement on the home schooling issue. The prior Order of this Court dated September 13, 2005 provided that pending the ordered custody evaluation, the Mother was directed to enroll the Child in public or private school rather than home schooling. The custody evaluation was never obtained by the parties and the Mother enrolled the Child in home schooling beginning in the 2007 and 2008 year as well as the current year. The Father believes that the Mother violated the Court's Order by enrolling the Child in home schooling. The Mother denies that she is in violation of the Order as the custody evaluation is not pending and the Father had given his permission, through the Child, to enroll the Child in home schooling. At the time of the conciliation conference, a conference call with counsel was scheduled for September 30, 2008 to discuss the school issue following the Father's receipt of the information he requested. However, at the time of the conference call, the Father's counsel had not been able to contact the Father to determine his response. It was agreed that this matter would be placed on hold further pending contact from the Father's counsel. Having received further information as to the Father's position on the home schooling issue, the conciliator recommends an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator LAUREEN M. ULRICH, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. 98-2118 CIVIL ACTION LAW KEITH P. ULRICH, Defendant/Petitioner IN CUSTODY PETITION FOR EMERGENCY CUSTODY AND IN CAMERA CONFERENCE AND NOW, thisR 'day of August, 2009, comes Petitioner, Keith P. Ulrich, by and through his attorney, Wendy J. F Grella, Esquire, and petitions the Court as follows: 1. Your Petitioner is the above-named Defendant, Keith P. Ulrich, an adult individual currently residing at 25 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. 2. Your Respondent is the above-named Plaintiff, Laureen M. Ulrich, an adult individual currently residing at 70 Barre Drive, Lancaster, Lancaster County, Pennsylvania. 3. The parties are the natural parents of two (2) children, namely, Chad C. Ulrich, born October 17, 1990, (18 years of age) and Chelsea M. Ulrich, born August 12, 1994 (15 years of age). 4. The parties are subject to an Order of Court dated October 6, 2008 which was entered by agreement; a copy of the Order is attached hereto and incorporated herein by reference as Exhibit "A." 5. Since entry of the Order of October 6, 2008, Respondent and Petitioner came to an agreement whereby Father would have primary physical custody of Chelsea from July 2, 2009 until September 8, 2009. 6. For the past several years, and against Petitioner's wishes, Respondent has enrolled Chelsea in homeschooling. 7. Chelsea has now informed Father and undersigned counsel she is desirous of continuing to reside with Father and would like to attend public school for the 2009- 2010 school year. 8. Cumberland Valley School District starts its school year on Wednesday, August 26, 2009. 9. It is in the best interest and permanent welfare of the parties' daughter, Chelsea, to provide father with primary physical or residential custody of her for the following reasons: A. Chelsea has and continues to be in counseling with Nancy Rogers, Licensed Psychologist; B. It is believed and therefore averred that Chelsea suffers extreme emotional and mental anguish when she resides with her Mother; C. Chelsea struggles with the atmosphere at Mother's house i.e. her relationship with her stepfather and his harsh forms of discipline; D. Chelsea has expressed a desire for her Father to have primary, physical custody of her; E. Chelsea is 15 years old and has indicated she would like to remain in Father's custody and attend public school for the beginning of the 2009-2010 school year; and F. Chelsea is desirous of spending more time with her brother Chad who resides with Father. 10. It is believed and therefore averred that to express her true thoughts and wishes an In Camera Conference should be held with Your Honorable Court, Chelsea, Attorney Miller and undersigned counsel to determine what is in Chelsea's best interests. 11. Counsel for Respondent, Douglas Miller, Esquire, has been provided with a copy of this Petition by facsimile correspondence prior to filing. WHEREFORE, Petitioner respectfully requests Your Honorable Court immediately conduct an In Camera Conference and/or schedule a custody hearing at which time an order should be entered providing him with primary physical or residential custody of the Child and allowing the Child to attend public school. Respectfully submitted, wc" (7"(e-flo Wendy J. F. lla, Esquire Attorney for Defendant/Petitioner 3618 N. Sixth Street P.O. Box 5292 Harrisburg, PA 17110 (717) 234-6001 RUC 20 09 08:22a Wendy J.F. Grella, Esq. 717-558-8439 p.2 OCT 0 -108 6% LAUREEN M. ULRICH IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA vs. ; 1998-2118 CIVIL ACTION LAW KEITH P. ULRICH Defendant IN CUSTODY ORDER OF COURT AND NOW. this ? day of 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court dated September 13, 2005 and August 11. 2008 shall continue in effect as modified by this Order. 2. The parties shall initiate and participate in co-parenting counseling with a professional to be selected by agreement between the parties. The purpose of the counseling shall be to assist the parents in establishing sufficient communication and cooperation to enable them to effectively co-parent their Child. The parties shall comply with the recommendations of the counselor as to the frequency and duration of the counseling sessions. 3. The Father's alternating weekend periods of partial custody with Chelsea shall run from Friday at 5:30 p.m. through Sunday at 6:00 p.m.. for which the parties shall exchange custody at a mutually acceptable meeting point in Middletown. 4. Neither pam- shall record the telephone calls of the other party with the Child or interfere with the private telephone conversations between the Child and the other parent. The parties shall cooperate in establishing the timing of the telephone calls with the Child at mutually convenient times which are also not disruptive to the Child's schedule. 5. In the event either party intends to relocate from his or her current residence, that parent shall provide at least sixty (60) days advance notice to the other parent to ensure sufficient opportunity for the parties to make any necessary adjustments to the custodial arrangements due to the relocation or to obtain:the assistance of the Court for resolution. 6`. Recognizing that the Mother has enrolled the Child in home schooling for the 2008-2009 school year and desiring to minimize disruptions for the Child. the parties agree to temporarily suspend the prior Court ordered enrollment in public or private school and agree that the Child may continue in Exhibit A Aug 20' 09 08:22a Wendy J.F. Grella, Esq. 717-558-8439 p.3 home schooling pending a follow-up custody conciliation conference which may be scheduled pursuant to? this Order and further Order of Court or agreement of the parties. 7. This Order is entered without prejudice to the Father's position on the school issue as raised in his Petition for Contempt and Modification. 8. Within ninety (90) days of the date of this Order, counsel for either party may contact the conciliatory to schedule an additional custody conciliation conference to further address the school issue. if necessary, following co-parenting counseling. 9. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent. the terms of this Order shall control. BY THE COURT, -dgar B. yley J. ' a3f cc: Douglas Miller. Esquire - Counsel for Mother Wendy Grella, Esquire - Counsel for Father c'k AL' Exhibit A Aug 20 09 08:23a Wendy J.F. Grella, Esq. 717-558-8439 p.4 LAUREEN M. ULRICH IN THE COURT OF COMN40N PLEAS OF Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA vs. 1998-2118 CIVIL ACTION LAW KEITH P. ULRICH Defendant IN CUSTODY Prior Judee: Edgar B. Bayley CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 191-5.3-8. 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 Chelsea M. Ulrich August 12. 1994 Mother ?. ' A custody conciliation conference was held on September 18. 2008, with the following individuals in attendance: the Mother. Laureen 1\4. Baltaeff. formerly Ulrich. with her counsel. Douglas Miller. Esquire. and the Father. Keith P. Ulrich. with his counsel. Wendy Grella. Esquire. 3. The submission of this Report and Order was placed on hold at the request of the Father's counsel to enable the Father to review the Child's tirades and obtain additional information prior to confirmin' agreement on the home schooling issue. The prior Order of this Court dated September 13. 2005 provided that pending the ordered custody evaluation. the N1 4other was directed to enroll the Child in public or private school rather than home schooling. The custody evaluation was never obtained by the parties and the Mother enrolled the Child in home schooling beginning in the 2007 and 2008 year as well as' the current vear. The Father believes that the tilother violated the Court's Order by enrolling the Child'in home schoolima. The ;Mother denies that she is in violation of the Order as the custody evaluation is not pending and the Father had `iven his permission. through the Child. to enroll the Child in home schooline. At the time of the conciliation conference. a conference call with counsel was scheduled for September 30.:008 to discuss the school issue I-fliowinu the l'ather's receipt of the information he requested. However, at the time of the conference tail. the Father's counsel had not been able to contact the Father to determine his response. It vas agreed that this matter would be Exhibit A Rug 20 09 08:23a Wendy J.F. Grella, Esq. 717-558-8439 p.5 placed on hold further pending contact from the Father's counsel. Having received further information as to the Father's position on the home schooling issue, the conciliator recommends an Order in the form as attached. d cam, .2, s400 ? Date Dawn S. Sunday, Esquire Custody Conciliator Exhibit A VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. ^ l DATE: P2C' ITH P. ULRICH, Petitioner/Plaintiff VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. kb= ltd DATE: ()q CHELSEA ULRICH, Child at Issue CERTIFICATE OF SERVICE AND NOW, this day of August, 2009, I, Wendy J. F. Grella, Esquire hereby certify that I have served the within document upon the person(s) and in the manner indicated below: Service via Facsimile and regular mail Douglas Miller, Esquire Irwin & McKnight West Pomfret Professional Building 60 West Pomfret Street Carlisle, PA 17013-3222 Fax: (717) 249-6354 Wendy J. F. rella, Esquire 2009 AU5i, 20 PN I : 29 CU v. y PE, dCE'i?4'r± `'I' LAUREEN M. ULRICH, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH P. ULRICH, Defendant/Petitioner: 98-2118 CIVIL TERM ORDER OF COURT AND NOW, this 20th day of August, 2009, the petition for emergency custody and in camera conference, IS DENIED.' By the, Edgar B. Bayley, J. ? Douglas Miller, Esquire For Plaintiff/Respondent Wendy J.F. Grella, Esquire For Defendant/Petitioner prs t 'Petitioner, Keith P. Ulrich, has not filed an underlying complaint to modify the existing custody order. He should and the matter will be referred to conciliation. On the facts alleged in the within petition, we will not deal on an emergency basis with a change of custody that will affect schooling that is brought to us at the last minute. HLEL) OF TH`.?,;' 2009 AUG 20 PH 2* 36 cum- , " 't i tz- I: ,.-i at PE{\t' 3 LVANi1:t LAUREEN M. ULRICH, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA vs. 98-2118 CIVIL ACTION LAW KEITH P. ULRICH, Defendant/Petitioner : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW, this Aday of September, 2009, comes Petitioner, Keith P. Ulrich by and through his attorney, Wendy J. F Grella, Esquire, and petitions the Court as follows: 1. Your Petitioner is the above-named Defendant, Keith P. Ulrich, an adult individual currently residing at 25 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. 2. Your Respondent is the above-named Plaintiff, Laureen M. Ulrich, an adult individual currently residing at 70 Barre Drive, Lancaster, Lancaster County, Pennsylvania. 3. The parties are the natural parents of two (2) children, namely, Chad C. Ulrich, born October 17, 1990, (18 years of age) and Chelsea M. Ulrich, born August 12, 1994 (15 years of age). 4. The parties are subject to an Order of Court dated October 6, 2008 which was entered by agreement, a copy of the Order is attached hereto and incorporated herein by reference as Exhibit "A." 5. The October 6, 2008 order specifically states that the parties shall initiate and participate in co-parenting counseling with a professional to assist the parents in establishing sufficient communication and cooperation to enable them to effectively co-parent their Child. (See Paragraph 2 of the October 6, 2008 Order). 6. Father has attended all but one (1) counseling sessions and has attempted to abide by the recommendations of the counselor. 7. Since entry of the Order of October 6, 2008, Respondent and Petitioner came to an agreement through Chelsea's counselor whereby Father would have primary physical custody of Chelsea from July 2, 2009 until September 8, 2009, a copy of the Agreement is attached hereto and incorporated herein by reference as Exhibit "B". 8. However, Respondent/Mother has repeatedly failed to honor her word regarding issues small or large in: (1) Father previously filed a Contempt Petition which Dawn M. Sunday has reserved decision on; (2) Mother has failed to abide by the July 2, 2009 agreement reached with the counselor in that Mother, during the first month of the agreement, failed to bring Chelsea to any of the agreed upon appointments; (3) Mother refused to bring Chelsea to future appointments; (4) Mother has only seen Chelsea on one of the available Wednesday visits; (5) Mother has taken Chelsea home for the weekend without providing her with the cell phone; and (6) On Sunday, August 30, 2009, Mother refused to return Chelsea to Father's care (under the July 2, 2009 agreement Father's custody was to conclude September 8, 2009). 9. For the past several years, and against Petitioner's wishes, Respondent has enrolled Chelsea in homeschooling. 10. Chelsea has now informed Father and undersigned counsel she is desirous of continuing to reside with Father and would like to attend public school for the 2009- 2010 school year. 11. Cumberland Valley School District starts its school year on Wednesday, August 26, 2009. 12. It is in the best interest and permanent welfare of the parties' daughter, Chelsea, to provide father with primary physical or residential custody of her for the following reasons: A. Chelsea has and continues to be in counseling with Nancy Rogers, Licensed Psychologist; B. It is believed and therefore averred that Chelsea suffers extreme emotional and mental anguish when she resides with her Mother; C. Chelsea struggles with the atmosphere at Mother's house i.e. her relationship with her stepfather and his harsh forms of discipline; D. Chelsea has expressed a desire for her Father to have primary, physical custody of her; E. Chelsea is 15 years old and has indicated she would like to remain in Father's custody and attend public school for the beginning of the 2009-2010 school year; and F. Chelsea is desirous of spending more time with her brother Chad who resides with Father. 13. It is believed and therefore averred that to express her true thoughts and wishes an In Camera Conference should be held with the Custody Conciliator, Chelsea, Attorney Miller and undersigned counsel to determine what is in Chelsea's best interests. WHEREFORE, Petitioner requests Your Honorable Court to schedule a conciliation conference at which time an Order should be entered providing him with primary physical or residential custody of the Child. Respectfully submitted, Wendy J. F. Grell & Attorney for De n 3618 N. Sixth P.O. Box 5292 Harrisburg, PA 17110 (717) 234-6001 EXHIBIT "A„ OC 0 v 6?V1: Cn LAUREEN M. ULRICH Plaintiff vs. KEITH P. ULRICH Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1998-2118 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this day of ?.?n 2008, upon consideration of the attached Custody Conciliation Report. it is ordered and directed as follows: 1. The prior Orders of this Court dated September 13, 2005 and August 11, 2008 shall continue in effect as;modified by this Order. 2. The parties shall initiate and participate in co-parenting counseling with a professional to be selected by agreement between the parties. The purpose of the counseling shall be to assist the parents in establishing sufficient communication and cooperation to enable them to effectively co-parent their Child. Th parties shall comply with the recommendations of the counselor as to the frequency and duration of the counseling sessions. ?. The Father's alternating weekend periods of partial custody with Chelsea shall run from Friday at :30 p.m. through Sunday at 6:00 p.m., for which the parties shall exchange custody at a mutually acceptable meeting point in Middletown. 4. Neither party shall record the telephone calls of the other party with the Child or interfere with the private telephone conversations between the C111ild and the other parent. The parties shall cooperate in establishing the timing of the telephone calls with the Child at mutually convenient times which are also not disruptive to the Child's schedule. 5. In the event either party intends to relocate from his or her current residence, that parent shall provide at least sixty (60) days advance notice to the other parent to ensure sufficient opportunity for the parties to make any necessary adjustments to the custodial arrangements due to the relocation or to obtain the assistance of the Court for resolution. 6. Recognizing that the Mother has enrolled the Child in home schooling for the 2008-2009 school year and desiring to minimize disruptions for the Child. the parties agree to temporarily suspend the prior Court ordered enrollment in public or private school and agree that the Child may continue in home schooling pending a follow-up custody conciliation conference which may be scheduled pursuant to this Order and further Order of Court or agreement of the parties. 7. `This Order is entered without prejudice to the Father's position on the school issue as raised in his Petition for Contempt and Modification. 8. ;Within ninety (90) days of the date of this Order, counsel for either party may contact the conciliator! to schedule an additional custody conciliation conference to further address the school issue, if necessary, following co-parenting counseling. 9. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference;. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, dgar +B.vylevy J. cc: Douglas Miller, Esquire - Counsel for Mother Wendy Grella, Esquire - Counsel for Father _,m.. E . t77 LAUREEN M. ULRICH Plaintiff vs. KEITH P. ULRICH Defendant Prior Judge': Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1998-2118 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8. the undersigned Custody Conciliator submits the folio firing 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 Chelsea M. Ulrich August 12. 1994 Mother 2. A custody conciliation conference was held on September 18. 2008. with the following individuals '-n attendance: the Mother. Laureen M. Baltaeff. formerly Ulrich. with her counsel. Douglas Miller. Esquire. and the Father. Keith P. Ulrich. with his counsel. Wendy Grella. Esquire. The submission of this Report and Order was placed on hold at the request of the Fathers counsel to enable the Father to review the Child's grades and obtain additional information prior to confirming agreement on the home schooling issue. The prior Order of this Court dated September 13. 200 provided that pending the ordered custody evaluation. the Mother was directed to enroll the Child in public or, private school rather than home schooling (l. The custody evaluation was never obtained by the parties and the Mother enrolled the Child in home schooling beginning in the 2007 and 2008 year as well as tli?e current vear. The Father believes that the Mother violated the Court's Order by enrolling the Child it home schooling. The Mother denies that she is in violation of the Order as the custody evaluation is not pending and the Father had given his permission. through the Child. to enroll the Child in home schooling. At the time of the conciliation conference. a conference call with counsel was scheduled for September 30. 2008 to discuss the school issue followinu the Father's receipt of the information she requested. However, at the time of the conference call, the I= Ither's counsel had not been able to contact the Father to determine his response. It was agreed that this matter would be placed on bold further pending contact from the Father's counsel. Having received further information as to the Father's position on the home schooling issue, the conciliator recommends an Order in the form as attached. Z4008 Date Dawn S. Sunday, Esquire Custody Conciliator EXHIBIT "B" Nancy L. Rogers, M.S. Hershey Psychglogical Services July 2, 2669- 441 East Chocolate Avenue, Hershey, PA 17033 • (717) 533-5311 bear Laurie & Keith, Pursuant to our agreement today: - Keith will have primary custody of Chelsea during the rest of the summer, commencing July 2nd and concluding September 8th; - Chelsea 'wi11 continue with weekly appointments, and the transportation and payment plan wiil continue STS it currently stands. - Father will not owe child support during these summer weeks and agrees to provide for all of Chelsea's food, clothing and shelter needs during this time. Child support will resume when the Fall schedule resumes. _ <. ?e.lsLai,wil! r4 sume spending every other weekend with Mother, utilizing the current drop off and _ . -- i Sys rt 5-.30 s ch that is agreed upon by both parents PRIOR to the pick/drop ;off, - 3 - e -?.+m.mar st6edTilz, Chelsea wdl visit with Mother every Wednesday, utilizing the same = ched;£ie as during the school year schedule. The above agreement does NO T superceae Sur"7me4- `ic_La ;ion sdh-?-'-UI t agreed upon. -- -. -..-- - _-._ ---- -: .- - .-- _-: Lryid veil phone on the market, for Chelsea rarent or this Psychologist. - The cost of renewal minutes will be shared by both pare; tts egt4l 7. - This phone carevt be used by any one other than Chelsea. - The bill, containing the complete czi>`c this Psychologist on a monthly bc; his nhol+g yr+ny not ! a rart3r?v?rR tr- s rl ai5?j'S 'SeSS+G't? !'!!less agreed upon d`-Tr' a ?o!nt ?n°- Y.! ses--ior'. .•lSC4L+1 G1??• lincy L Rogers, AA-S. t L L-'Certseu I VC$ tvia"ir:#.:P I Individual, Marital and Family Therapy 9 Psychoeducational Assessments 9 Children, Adolescents and Adults VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsifications to authorities. DATE:- Z-ZJ MTH P. ULRICH, Petitioner/Defendant CERTIFICATE OF SERVICE AND NOW, this 1 1?4-" day of September, 2009, I, Wendy J. F. Grella, Esquire hereby certify that I have served the within document upon the person(s) and in the manner indicated below: Service via regular mail Douglas Miller, Esquire Irwin & McKnight West Pomfret Professional Building 60 West Pomfret Street Carlisle, PA 17013-3222 Fax: (717) 249-6354 0, -7 THE 2811'9 S L P -'2 F Nl-y *qp. ©C Pia Ar" 00 1405 M' o?30(5 LAUREEN M. ULRICH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH P. ULRICH 1998-2118 CIVIL ACTION LAW IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, September 11, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, October 01, 2009 at 12:00 PM 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information 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 conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 FfLFi;?);=4,E ?JF THE PPO-?,ni; k.)TAAY 7009 SEP 14 AH 9: 58 CIJll q ; u 9/1 LA). 00p, fi"?a- • FEB. 19 2010 ~ LAUREEN M. ULRICH IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 1998-2118 CIVIL ACTION LAW KEITH P. ULRICH Defendant IN CUSTODY ORDER OF COURT AND NOW, this u I~ day of ~ ~ 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father's Petition for Modification is dismissed based upon the Father's failure to respond and proceed following the custody conciliation conference on October 1, 2009. 2. Pending further Order of Court or agreement of the parties, the prior Order of this Court dated October 6, 2008 shall continue in effect. cc " D~ glas Miller, Esquire -Counsel for Mother /Wendy Grella, Esquire -Counsel for Father CO { ~£S ,~,~ l a f a ~,~ rv ~r~ ~ ~ ~ . ~ ~ Q n ~ ~ ~ BY THE COURT, LAUREEN M. ULRICH Plaintiff vs. KEITH P. ULRICH Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1998-2118 CIVIL ACTION LAW IN CUSTODY 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 Chelsea M. Ulrich August 12, 1994 Mother 2. A custody conciliation conference was held on October 1, 2009, with the following individuals in attendance: the Mother, Laureen M. Ulrich, with her counsel, Douglas Miller, Esquire, and the Father, Keith P. Ulrich, with his counsel, Wendy Grella, Esquire. 3. The custody conciliation conference was held on the Father's Petition for Modification. At the end of the conference, it was agreed that the conciliator would hold the matter open so that the conciliator and counsel could have a telephone conference with the Child's counselor, Nancy Rogers before reconvening the conference. Although the conciliator completed the scheduled contacts with Nancy Rogers, the matter was continued to await the Father's input as to how he wished to proceed. The conciliator, having determined from the Father's counsel that she has not received a response from her communications by mail and is unable to reach the Father by telephone, the conciliator recommends an Order in the form as attached based upon the Father's apparent lack of intention to proceed at this time. -G~JN~~ ~ 7, a2d ~l~ Date Dawn S. Sunday, Esquire Custody Conciliator 15, LAUREEN M. ULRICH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 98-2118 CIVIL ACTION LAW MC vs -xi r . :zm z? C= r i -u m KEITH P. ULRICH. .? ? S Defendant IN CUSTODY '- cy c s ORDER OF COURT Jun C AND NOW this day of May 2011, the attached Custody Stipulation and L.$. Agreement is hereby made an Order of Court. UV BY THE COURT. U, CL J. 0o OP6 ? ,? Cry t? cc: Laureen M. Ulrich, Plaintiff ,,, 1w boa Wendy J. F. Grella, Esquire '" Attorney for Defendant