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,', "It ", i,1 I" III i'" I' , <I ~J ~! ~1 <;tt I ~l . ! " " ;.I" OJ' H I" "f' " ;i " , I' ",' "; ,J' " " -I,' 'II' " " I) " 'I" " I; " " ~ o ~ ~ ~ I, d' i! ,." ;1 Ii ij' i'" 'i' " ." " " ,', I ~ " ;'\ ,\ \ \ J y [if " , " ,. " oj f,j I'; " " 'iF' ,. , "::-' jj' " ., '!dl " I" " " .' " " d' I I i ;.,j " ./ " " ,j " " " Ii ,i il ii " ' !; I, ~ \~ " " " " ,. ii ,I' " " " " , " I, ,- " Ii "i, ,. " ,. I' ., " , " " " oi 'I , , " " " " " "t, ..... , . .~ ...1 ~I I ~ ~ t'-.. "c) " I'" . ~l ~ " " " " ;1 Ii' ;,?/i~~liW" : " ,. ,;f " ,I , ,,' , / " 'i! " / ..' Ii " 'I; H " , i' " j;I','1 :1' " 'I" 1'1. .)1 ,\' 1'" 1', /, " " " I, , , ,'; q 1,,1 'II" I: IJ-'-, I~ .' ; ',' !.'", 1<(:c>.;;'{n-1i- ~I-,i} 'j {'"d.. )c) I}III lJ6'> ((<- ,~..lhi r'l R7-fJ'i(n...~~_) , ,.~ ' .1"), . I: H-y,\ G.p)-kl PI, J\; " f" l' " 'i, ,I' Iii! "I' q " " I'; I, Jil " ji Hi, ,"{."rl. '. <I " ,n h " " " /, " ;)' " j" Ii ,;-1', .. Ii It. I; II' /, v. " IIN '!'I!lQ (JOUIW Olt" POMMON PI~IW;h i OUM mml~^N P OOUN'!'Y, PI~NNflYIN ANI^ 1 I NO,' iF- .1,/ '/'1 ("/I'" (''iI'I'" I I OIVIl" AC'l'ION - OUfl'I'OPY I 1 ,HQI~I~lllqy A, lWITl'IQllflON, PlnlnUI'f fl'I'^CY A, PNI"PIUIll3oN, l)ot'llnlhmt COMPIAlNrL1lJ10l~ CUSrpODY L Ii, AND NOW (!llm(l~ PlnlntIIT"IIU11'\i'IlIUY A, PN1"I'IUIlSON, by I\nd through hl~ nt(rll'noy, NOI'I\ 11\ f31~\II', lU~qllll'o,'l'llmll,hl~ C011lplulnl, 1'(11' Ow,t,ody nnd In t!llPPOI'~ F'., 0101'001', ~\VoI'HI\~ l'ollqW~1 1, Plnlntll'l\ ,nnl~I~Hmy A, PNI"l'lUHSON,It! nn ndlllt Indlvldul\ll'ot!lctlng nt 10114 Oyatol' MIll Homl, ClIlnp HIli, Qum\Jol'lund Oounty, Ponnsylvunln, . 2, I)ol'ondnnt, S'I'ACY A, PNf'1'IUHSON, It! un ndlllt Indlvldllnll'e~ldlng ut , I" '1011 South lIlnolu Dl'lvo, lUnoln, Curnbol'l~H1d Coun,ty, Ponnaylvnnlu, " :I, Plulntll'l'soolm pl'lmlll',V phYllloulnnd lognloulltody of'iho l'ollO\Vlng minaI' ohlld: , I' NAMlil PHlUSlUN~I'.^j)f)HT11SS {)NI'EJ OF BIHtl'H ,lulltln '1', Puttol'llon tllllll OYlltol' Mill Houd Cnmp HIli, Ponnllylvnnln l~obl'.l\Ul'y 10, Willi 'l'lw ohlld WIIH llCll'll In Wodloo\~, Tho ohllcl IH Pl'oHlllll,\({ In Ow olIHI(l(I({ or 1'111.1101' who I'ollldot.llll. Illl\<l O,YHtol' lVlill Hnlld, ollnw nllI, Ol1mlHJI'lnnd OOl.\lll,y, Ponnt.lylvllnln, II. PllI'lng llw I II t.I 1. I'\vo YOlll't.I, I.hoohlld hllt.l l'oHldml wllh 1.!lol'o\lowlng plll'HonH IInd III. 1.!1Cll'ollowlng IHltll'mlHOHI t-lAMNf2 AP D H mllli.ill!;1 MTlilt! ,lol'l'l'o,vA, Pnt.t.p1'HOn HlIItt OYt.ll.ol' Mill IlmHl 1311't-h I,n SI.Ull,Y A, PnHOI'Hon Onmp HIli, Ponnll({lvunlrl '1/7/llll " ,Tol'l'I'OY A, Pnt.I.Ol'llon 1011tt OYtlt,Il1'MIII (loud 4/7/ll1l 1.0 Ollmp mil, Ponntl({lvnnlll Pl'otlonl Tho futhol' or I.ho ol1l1d Itl,)oI'I'I'O,Y A, PlIl.l.ol'tlOn, l'otllcllng nl. tlll.l." OYIlI.OI' Mill Houd, Oump Hill, CltmbOI'lllnd oOlmt({, Ponntl,ylvllnln, 1-101 i'! mUl'I'1 (J(1. I,', '1'110 ll1otl1ol' or 1.110 ohlld Ii'! St.noy A, Pnt\.ol'Hon, 0lll'1'On1.ly l'oHldlng III. 4llll tlouth lCnolu DI'lvo, E:noln, Oum\Jol'lnnd COllllty, Ponntlylvnnln, Sl1olt.lmlll'l'Iml. 5, 'rhol'olntlonf1hlpo(' Plnlntlff to tho ohlld Itl I.hnt 01' I'nl.hol', '1'\10 Plulntl fl' OI.II'l'ontly l'otlldoH with tho ('allowing pOl'i'!Ontll NAME: HlD1~NI'1 ONSH) r~ .!lltltl n 'I" PnttOl'tlOIl Son " (I, '1'\10 l'olnl.lplwlllp pI' Dol'ondnnt, I,p ~Ilo (I\llld IH t.hn~ 0(' nlllttwl', " '1'Iw Pol'ondnnl. (I\.Il'I'on~ly l'oHlcloH wl1.h ~l1o I'ollnw\ng IHJl'HPnH: , ~AMliJ ll.ml.N!' I 0 N.~l:llE , J"on~l'I(Jonnd,John ZOl'l\noo Pl1l'on~t! I), 7; Plnlnt,IIT hut! nn~ \lfH'I,\(llpn~od ut! n pnl'l,y 01' WI~llOHH, 01' In mlO~1101' (llqlf\Cll~y, , " In o~hpl.'. \I~llJll~lon CloIWCll'n\nLI LhCl Cl\.1I:1~(J(1y 0(' Lhll:1ohlld In thll:1 01' nnottllll' ClOlIl'I" Plulnt.\lT hUH no \nl'ohnul,lon 01' n ollHLoity pl'Cl(l(JodllUl Cldnllol'nlng tlllH Clhlld pondlng In 11 1I0\.Ilt 01' thlH Coqlmonwoultll 01' In l\l1oLllOl' sLuLo 01' (llllllmOnwoulth, Pllllnl,\l'l'donH nol, know 0(' n pal'son noL n ]1lll'l.y t.o tho Pl'OClClCld \ ngs who hus phyalClll1 ClllsLody of' thp ollllrt 01' olulma t.o hnvo Clllatod;v 01' vlsHnt.lon I'Ights wlLhl'ol'lpOClL t.o l,ho Clll\ld, . !l, '!'h() bosL Intol'osL und pOl'munonL woll'm'ool'Jho ohlld will bo SOl'vod by gmnUnlI tho I'ollnl' l'Olll.tnl'ltl)d boouuso Plulnt\l'l' dons nnrJ wllll>l'ovldo u mol'O Htnblo und nUl'tltl'lng onvll'onmont 1'01' hill son, 0, lDuoh pUl'ont whoso, pUl'Ontnll'hihLs to tho Clhlld huvo not boon tOl'mlnntod und Lho pOl'son who hus phYHloul oust.ody 01' tho ohlld huvo boon nnmod us PUI'UOB to this HoUon, (,' "' " l'l~ ' "1. ,1,', \"1" , "I-~'(' " .\.il "t'r-,' h' \ ~~ 1,1", I" , , I II "I' 'Li l/I \\; ~~l '" ,I, !-"). i ,-I I': "+, .Cj I () \) Lt) f :d " " " ..... ~ \~ ---.S\ " .~ ~ f() o ~ o o 1.r) ";:) c.; D :;r: "'6,- ~I ~l S rJ. ..j. ~, 1:,' ('I, Ii' l,') I I' , ~', '" ;1 ';,1 , I I"": t,' i': " ,. i' L " .. i,'\ f' " , , ;I' !I' " 'j " !' Ii " " " I' ~ 'i, i j,' " " H jf' " 'II " /, Il! " " , 1/ :1 .. " ;{ 'I ., 'I; ,/ I' " .' '" ',; .. ..' .. JI " " ,. iI ,j I,' , " " ,I ,. 1'1'1 ~ ; " 'i," " " " , ,,' I' NoRA 1", 131.^IR, ttSQUIRF. b-l~O ,IONnB rowN ROAD .,i'9r ol'l'lon hoX RalR HARI1Ib'SURO,/'1\ 1111g.0;1.1 B l'1I71U41'\4RO .JUt. (I 7 19M~tr . " I\, Mollwl' Hhllll11l\w ilw ~hl\ll U\'OI')' 1'11\111111)' ~vul1l\l1l 1'1'\l111 MIll P,I11, \111111 tv1011d1lY III 1l:(lO 11,11\, III whluh 111\1~ Hlw 11111\11 M\lI'Il Ihu uhllll,l\1 Fllllwl' \11' ilw hllhYHIIIUI', C, Mol\WI' IIhllll hll\'U Ihu ~hlld \1111111~I'II1IIII1B \WUI\~111111 1'1'\11\1 Fl'ldll)' III (uO(l P,I\1, \111111 HIII1IIIl{1I1 (uOO p,m, p, Fl1lhul' HIlIIl1 hllvu Ihu uhlllllllllll olhul' 111\1011, II' Ihu Plll'l)' III 11I\lIhlu In hu pl'ullul11 dlll'llIlIlhull' pUl'lml1l \11' ulllllmlllllllmu wllh Ilw uhlld IIl1d hllVU 10 \lHU II hllh)'HIIIUI', Iho)' IIIH\lImlll\~ Ihu ollwl' PIlI'I)' Ihu !i1'1I1 opllol1l11 hllvU Ihu uhlld d\ll'lng Ihlll pUl'lmlnl'ulllllmllll1 IlIllU, .l, Thu pIIl'lllJH 1I1II'UU 1I1II1IhlH IH II 1\ll11pol'lIl'Y onlul' IIml dnuII nn\ pl'o.l\ldlco ullllOl' PIII:I)"II l'ighlH I'I'0m 1'IIIIIIng 11Il)' IHH\II\1I111ll1Ihuy duomllppl'Oprllllolhl' dolol'lnlllll1g II olllllmllllllllTlIl1gunlUl11. , '1. Tho plIl'lIoH Hhl\\1 l'ou0l1\'OI10 Ihl' I1l1nllwl' uOl1olllllllol1 uOl1lol'ol1uo holhl'o Mluhllul \" 111I11gH,HHq\lll'u, on TI\llI'Hdlly,lJuuumh~I'IO, 11)\)H,uI4I(10 P,I\1, ;,'f " .__._______._._.._....___u. ,I, NOI'II Ii, nlll\l', lIHqnll'u( ~d~I'''~ 'Emil)' I" Ilof'l)l1l1l1, Ellq\lll'u ,),L :, ~ hl~ll rcl IG~;'tl./c;;) , -=rI'l. f,7) , ,n U;i (:;'l j"-I , ",1 I "'1 i:!:i " (j) " 1 i:l;fl, :'[!) 'f ,Jf,} "1 ,,''):d .('1 i'll'I ,":1 ' ,'t. ::~:,I , " " mill .1,'1,; ~:)I i/ : I l! F .., I.i :':..: :'1 .'~'~ I,. O~J " ,lHFFHliY 1\, IWITI\lUION, ..l'hll11\II'I' .. ) ) ) ) ) ) ) ) IN '1'111\ CO\ Jln Pi" cntvlMmfpl,liAH OF C\IMIlI\l{LI\Nil C'Cl\INTY, I~":NNHYLV A NIA NO, IlH"J7iIIJ CI VII, 'IT-:\~ M " ""i' " VN, HTN~Y ^, IWITHI{HON, PL'lul1dlll1l <WII, N"I'loN "I,I\W IN C\IHToI1Y ,I\JI)<II\ I'HIWI<l\JH1,y i\f,HIONHP: NOl1o , " Cl!.tLI1UlY_J.11N.CLI~LA11Ul'iillN l<'1;; H JJ:~C.lUillMI\1" I~" I~ L!ll!1UU. I' IN M~cuIWANCl\ WITH C\Hvllllml,AND COIINTY R\l1,IWF CIVIL , PIWCHPlJlW 11115J-H(\1), tho 11I\llorHIIJI1u<1 C\llllody COl\ollllllor HllhmllH 1\)1) 1\1lloll'll\IJ ropdr~l, I, Tho portll\ol\\ 11\1\11'1\1l\tlol\ oOl\oornlll1J tho ohlld(,l'ol\) whoIH(lIro) \ho H11\1.1oel orthlH 'I 1I\llJllllol1lH IIH 1\1IIl1\VH: t,J^MII . lill~IW.1L\lU C\lI~IWNTf,Y IN CIIH'\'OIlYJlE ,hlHtl11 '1', I'IIUOI'HOI\ Fc\1\'\IIII'Y 1 n. IlJ11H . . .2, ^ COl\elllll\lOI1 COl\lul'el\co WIIH held \1\1 Hoplcl11her 1 n. IlJlJH, IIlId tho Ihllowll1lJ " ,.. "I' Il\dlvld\llllH \V01'0 pl'OHol1l: tho PllIll1tll'l' 1I\1l1 hlH II((OI'I\U)', NOI'Il JI, Bllllr, I\sqlllro; Iho Duru\1dlll1\ "j, ,il IIppulII'ed wllh hel' IIUol'l\ey, 1111111)' I" 1.101'1\\11111, IIsql1h'u, 1 , 3. ItUl11H reHolvcd h)' IIIJI'CUI\1lJl\t: .l'iec IIl1lluhod Ul'dCI', " 4, IHHl1UH yul to hu l'uHolvud: Hou IIl1llehod Onlul', , 5, Thu PIIIll\lltrH posltlo\1 Ol1o\lHtod)' 1,111111 1\1l1oWH: Heo IItliwhcll Ordul', (l, Tho \)olul\dllhl'H pllHlllol\ 01\ U\lHtlllly Illlllllhlloll'HI l'iooll,lIIIChodOl'dul'l II, '11 i" " , " It . ro.1llS'.CKliCl.u\.lM 10, Pllrnllrnphu PI1P Ihrnllgh nll1\l111111 \)pr\lI\lI!I11\'9 r\lllpn\l9Pij (hllrp\n 111'0 l11oprpIl1'l\\Ollhy " r\lrpr\ll1\lll hpr\lII1, II, pprpl1ll!m(HPpl\u PI\9101\Y PI' Iho11111111r phllll, .1119\111 ,\" PII\\prSOI1, 12, . Tlw hou\ hl\OrpS( IIIllI pO\'l1111110111 Welrlll'O pI' \he child will ho sprVPl\ hy llnm\lng 1110 r\lllpr '1< rOH\loslolI \1001\\lHO pOrol1l1l111\ lluos 1I111\ will prllvlllo 1111101'0 s\l1hlo 1I111111\lrlmill!l ol1vlrnl1\1lOl1llhr hol' HUI1, " WIIIIHIWOHH, pol'ol)l\lIl1\ roqlloH\S 11111\ this \'\01101'111110 Com\ grlll11 prll11l1ry phY9\01l11l1)1I hilllll ol1Hlm\y llrllw oh\lll 10 porol1111ll1\ wllh vlullllllol1 \0 PIIlII1\11T liS 1119 pllrllos 11111Y lIgrOO, Houpoo\l\llIy u\lhmlUod, (, . ~ ~J~~~ \,kA___ IIl11l1y l~oll!lllorrmnn, BUCj\llrp . SliP, CI, lD 1166307 105 NOI'Ih Fl'ol1t Stroot Hnrrlshmg, PA 171 OR (717)233- 1112 A\\\1l'l1oy 1'0\' 1110 porol)dlll)t " I' I' " PII\PI L) t \ c.;. I'lr I( , , " " " '1 " " "'ii " I' \, I, , /, ',I '. YlllUillCA'I'IQN 'I Upnlll11Y pOl'ftnllnllmnwloll!lo,lllrnrl11l1llnll, IIIHllwllof', I, SillilY A, Pn\lor~nll, vorlly Ihlll Iho Ilwlft 111'01'1'01\ 1I1lt! allllOlllOlllft 1111\(10 Illlho rOl'o!loll1g Ilno\II11\ll1t 111'0 lruo 111111 onnoelln tho hoftl nf'I11Y lil1nwlol\!lo, ' , 1I11\lorftlnl1\1 tl1l1t IlI\ftO ftlntonwl1lft nr I\vo\'lnol1lft 111OI'ull1 \111\(10 will ftllh,lcOI 1110 tn tho 0\'111111111\ pOl1l1l1hm of' III PII,C,S, SootlOI1 4!l04 rollllll1!lIO IIl1ft\VO\'ll Illlftlflontlol1 to Il\lthnrllloa, PATE: 'I! I', Lil \ _--0 .....,._ --~----- 1W:~W~ " . (1''wl!J:~,-.&t(jji;\';2 -0\07 ,.'., . SlnoyrK.PIIHo\'aoll . jIc . ~.".. II. ,I I', ',I' ' " I' " d i, // ", ". d' " I' , , I' '1; I" " .. ,. " I> "1111 ')'/'/(1' "J-\," ..: OF 'II ,,' 1'1 '(,f'!i"{':OTNIY ~)n Dr:r: II, I'll (~I li2 " .. Ii (JI.lklJU :ll'i il> COI.NrY' I~ENI~SYI.\l,\N'I\ "" .' I, "'1\ 1',(; " " .,' I' " ,'''I 10 .. " 'I I, 'I, \' ;.'" l' ,; I' I" " d' " ;1 ie" I :i 1" /jll I' 1'-' " H " " , , "1" :i' !\ I' Ii 11' " <I " ii'(i" 11' 'I " " " '/1 \', /1-,':1 (1'/\ I, ii ' " 'f "0/' ,; I. ';"P;; ,..,' ",," ",',' (,' " 'I i,l " " " " ;; fi I, ;.' .. ;' " i,' " I,'; ,I; ", " " oj. " I' 'd;I,/ 1,_11\, ..\, '1\ I," I '11,111l I dr, t II i/'!I-:.. "! ',I 'I' I' " " " Ii H j' I' 1,1' ,j ,) " , " " " " ,. '; , Ii, " /! " "I, II"! " ,. " " r:XllTI1 Try' ~ " 1\, Molhel' Hhllll hllv~ thc \lhllll cvcr)' /1\11\(111)' uvclll11l! 11'11111 MIll P,I11, IIl1tll M\lmlll)' 1119:0l) 11,111, III which 111I1\l ~hu Hhllllrul\lrlllhu I1hllllll) Fnlhcr nr Ih(l hllh)'Hh\Cl', C, Mother Hhnll hllve the chilli nil IIhornlllhlll WOC1\1111(IH 1'1'0111 Frlllll)' nl Ci:()O p,ln, 1111\11 8111111n)' 11\ ,\1l1O P,lll, p, Fnlhel' Hhnll hnwlhu child III nIl nlhul' Ihl\llH, 1 l' IIIP pnl'l)' IH IIlll1blu 111 hopl'csonl dmlnu Iholr perlo,," of cIIslocllllllln1l.l 'wllh,\hu chlllllllld hnvl1 10 11NUII bnb)'Rhlul',lhu)' shnllmll~ulhe o\hol'. pllrly the Ilrsl oplloll10 hllVc Ihc phlld dnrllll1 Ihlll pcrloo of CI\SIOIIl,,1 IImu, ~, '1'11') pnrllcs ngruu \hllllhlH Is IIIUmpOI'lll')' order nnd dous IIPI pl'ujudluc cllhur Pllfty's rlghls from rlllslllg IIn)' IRRIICH Ihllllho)' deom IIPPfllprlllto for dulcrmlllllll! II cIIslmllnlllrrnnl!CmCIlI, ,. 4, Thu pnl't1es Rhnll recollvcnc for nnolher conolllllllon eonfCrellU\l heforc' Mlchncl L, ll,ml\s, Esqulrc, 011 Thllrsdn)', Deccmber 10, 19911; 1114:00 P,\11, BY THB co\.m:r; .. IsjJJLu ~.!Lc,L - p~~9du;'lr . . J, Norll J1, BIIIII', Iisqulrc Emily J" 11ufTIl1I1I1. Esqulrc IIIlh TRUEOOPY FfI,OM AI1CORD . h\ TI)f.\ltllony \'IIlOI'30f, I.hme unto IIl',t illY hand mId thO Gtlnl 01 BlIld. OOUlt lit OnHIQI~1 Pa. Thl .we: dRY. " - to' .10 . olary Iff , ., " \ . JIWFltlW A, IWrrnll/'lON, Itlnlnl\tT V~, R'I'MlY A, IWl'l'flllfjON, P~flln\lnnl ,JUPGH PHHV10\J~I,y MlRIONHDI None " ) ) ) ) ) ) ) ) IN TllI~ cotJHT OF cOMMoN PI,'~AR OF C\JMUnRl.M-lp CO\JNTY, PHNNRYI. VANIA 1'10,1)11-3749 cIVil, TliHM cIVil, ACTION. I'A W IN CUf.l'l'O\lY CllBl'.OllY CONClL.IATION CU~lillEJIlCIC Sl!MMARY.JUWOR'I' IN ACCOIlDANcn Wl'I'lI CUMUHRI,AN\l COUNTY HUW 011 cIVil, PROCHPURH 1915,3-R(b), Iho 111I11\lf~lllned CIIHlod~ Con\lllln\of slIbmlts Iho lbllowlnll repprt:. \, Tho purUnont Inf<1l1l1n\lon oonoornhlll tlw chlld(fen) whlll~(nfe) the ~lIb.lect oflhls IItlBlItlon la ua follm"a! NAMU J)IR'I'HDA'I'E CURRENTL Y IN . C\JSTODY QE JIIstln '1', PlItterson Fohnlllry 10; 199R 2. A cl1Iwlllntlon Conference wu~ held un September 10, 1998. nnd Ihe Ibllowlng IndlvldullI~ were rl'e~enll thel'luhltlffllnd hl~ nllofl\ey, Num F, \31111\', Eaqllll'e\ Ihe Dufendnnt IIprenrcd with hul' III\Ofl\e~. Enll1y I., \IofTtll[\11, Eaqull'e, 3, \lellls l'u~()lvcd hy 1I11l'eementl Seellttllehed Order, 4, I a~uea yol 10 he I'oaolved, See u\tllehed Order, 5, Thel'llIllIlltfa posltlun on euslody Is IIR ('ollowsl Seell\tllohellOl'der, Ii, The Dufendllnl'a poaltlon on o\lRI(1(I)' la liS Ihl\oWSl Scellllnohed Order, '",','..",,,.';' '" .' '. " :;'1 p " I' ,,1' " .. j; ;. " 'I, ,. " iI, Ii " " '. " ;'" 'i'''! ;II i< , " " j' " 'II .. 1/ 'j' " " d " \I {I' ,Ii I' " \; " ;; 11'11 ,1<1; " ,,' " " Exhibit F I, jll " I" . i' . . YRRllilCA11illi I, HTI\CY 1\, Pl\Tl'liHHClN, horoh)' VOI'II)' I\IHI H\III\l Ihll\ IlwllllllH Hili 1\11'\11 111 tlw Ibrl,llwll1B d\1CII11WI1\ 111'0 1\,\\0 IIml corrOIl\ \0 \lw \WIl\ 01'111)' Il1lhI'l1111\1\111lliI10wlllllgc IIml Iw\lvl'. I IIlHlorHIl\lH1 Ihlll I\\IHO H\IIloI1WI1\H horoll1 111'0 1Il1l110 HII\1.loo\ \0 Iho P0l1111\IoHnl' I H I'll, C,S,A, !l4l)()4 rollllll1g In 1111HW!)1'11 \'01'11101111011 IOIHllhol'llloH. S\;:~'f (/1\ 'J.-vrv1<<"rJ":kJ:fiI~~',,., H'\'I\C 1\, PI\TI'HI{HDN PI\'I'HI ~ I dol? .t pQ !' II . '1. ;f, "I' " ,. '" i' \ \ ,,' 1/ ',/ ,. J! . ii' " " I!' ,I, Ii " " !I i" ,. ,. ,. If 1:11\:\'\,01111(.1 ~\'11,\"\l0{1 V,I ',\,1111 'W'N:1 Vlillllu VI~\lVV'lIl:I:1 MV'! IV flA'IN\IO.\ IV ':.l'tI 'l.,11;INnn:l '" IliI'IfIV '\PlnV'!1I " ". " " ~. " pl1 ,..,.. ..,.. '1~,; r,,; 'j; M"';' '\1 "I ':1 .-t. ,; . 1'(', "''' I".J.~ Jl I,"f' .. '.J:e " ,. J, r\ r+. ") :"1 1'1'1 'J'" 11.lfi' "1'" " -\.10 .- r.: r:/~ I ' I II!;'; li)'.i! " (I,' ,": ~G }l!Jl ;;I. ull ~ I.l. C's "3 C) ',:, {.;l. '1 >; " I); ," " ,. tl ;, .1 I. Ii, "I " , I , " ,. d' " .." '-i " " I " " l,iI " I' ,. , , ,. ,. ,. <;iO " " " J! I. " Jj It I' ,i- " " Ii Ii '. I' " i' " ./i I, " " q. ,', "I' ., '11 " " " I; " /i,( ;, /' " " MA; , , 'I, " " " " ,I JEFFREY ~. PATTERSON, Plaintiff Vo STACYA. PATTERSON, Defendant :IN THE COURT OF COMMON PI,FAS, : CUMB~ COUNTY, PENNSYLVANIA _- : NO. ~£- 3'? ¢¢ ~ '1~-~ .. : CMLACTION- CUSTODY . COMPLAINT FOR CUSTODY AND NOW comes Plaintiff, JEFFREYA. PATTERSON, by and through his attorney, Nora F. Blair, Esquire, files this Complaint for Custody and in support thereof, avers as follows: 1. Plaintiff, JEFFREY A. PATTERSON, is an adult individual residing at 1084 Oyster Mill Road, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant, STACY A. PATTERSON, is an adult individual residing at 408 South Enola Drive, Enola, Cumberland County, Pennsylvania. 3. Plaintiff seeks primary physical and legal custody of the following minor child: NAME Justin T. Patterson PRESENT ADDRESS 1084 Oyster Mill Road Camp Hill, Pennsylvania DATE OF BIRTH February 10, 1998 The child was born in wedlock. The child is presently in the custody of father who resides at 1084 Oyster Mill Road, Camp Hill, Cumberland county, Pennsylvania. 4. During the last five years, the child has resided with the following persons and at the following addresses: NAMES Jeffrey A. Patterson Stacy A. Patterson Jeffrey A. Patterson ADDRESSES DATES 1084 Oyster Mill Road Birth to Camp Hill, Pennsylvania 4/7/98 1084 Oyster Mill Road Camp Hill, Pennsylvania 4/7/98 to Present The father of the child is Jeffrey A. Patterson, residing at 1084 Oyster Mill Road, Camp Hill, Cumberland county, Pennsylvania. He is married. The mother of the child is Stacy A. Patterson, currently residing at 408 south Enola Drive, Enola, Cumberland County, Pennsylvania. She is married. NAME Justin T. Patterson 5. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: RELATIONSHIP Son 6. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: NAME Leatrice and John Zerance RELATIONSHIP Parents 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of this child in this or another court. Plaintiff has no information of a custody proceeding concerning this child pending in a court of this Commonwealth or in another state or commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff does and will provide a more stable and nurturing environment for his son. 9. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHERgl~'ORE, Plaintiff requests that Your Honorable Court grant primary physical and legal custody of the child to Plaintiff with visitation to Defendant as the parties may agree. Dated: Respectfully submitted, Post Office Box 6216 Harrisburg, PA 17112-0216 (717) 541-1428 VE, RIFICATION I verify that the statement made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. JEFFRE~ A. PATI~,RSON, Plaintiff STACY A. PATYERSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMB~ COUNTY, PENNSYLVANI : : : CML ACTION - CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before ~)(K.~'~-\ ~-,4~.~_~ , , Esquire, the Conciliator, at ~. ~ \~ (~,~ ~ ~\\ , Pennsylvania, on'~3C~)C,~the ~--~) day of f-~c~ , 19°~, at ~(~ o'clock C~ .m. for a lbre- Hearing Conference. At such~Conference, an effort will be made to resolve the issues in dispute; or, if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary Order. Either party may bring the child who is subject of this custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. For the Court: Dated: '"] iq IC~) Custody Conciliator 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 BEllOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 JEFFREY A. PA'I'FERSON, Plaintiff STACY A. PATTERSON, Defendant : IN THE COURT OF COMMON pI,F, AS : CUMBERLAND COUNTY, PF_,NNSYLVANIA : : NO. 98-~?~9 .- : CML ACTION - CUSTODY AFFIDAVIT OF SERVICE I, Nora F. Blair, Esquire, hereby certify that a true and correct copy of the COMPLAINT FOR CUSTODY and ORDER OF COURT was served on the Defendant by certified mail, restricted delivery, return receipt requested, on July 17, 1998, at the Defendant's last known address of: Stacy A. l~.tterson 408 South Enola Drive Enola, PA 17025 The return receipt card is attached hereto as Exhibit "A". Dated: Respectfully submitted, 5440 Jonestown Road P.O. Box 621~ Harrisburg, PA 1711g-021~ (71'7) §41-1428 EXHIBIT "A" JEFFREY A. PATTERSON, Plaintiff VS. STACY A. PATTERSON, Defendant JUDGE PREVIOUSLY ASSIGNED: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-3749 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(ten) who is(are) the subject of this litigation is as follows: NAME Justin T. Patterson BLRTHDAT]5 February 10, 1998 CURRENTLY IN CUSTODY OF 2. A Conciliation Conference was held on September 10, 1998, and the following individuals were present: the Plaintiffand his attorney, Nora F. Blair, Esquire; the Defendant appeared with her attorney, Emily L. Hoffman, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintiffs position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent child(mn): Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. 9. Other matters or comments: The parties shall reconvene for another custody conciliation conference on Thursday, December I0, 1998, at 4:00 p.m. Date: September 29, 1998 Michael L. Bangs Custody Conciliator JEFFREY A. PATTERSON, Plaintiff VS. STACY A. PATTERSON, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-3749 CIVIL TERM CIVIL ACTION - LAW 1N CUSTODY ORDER AND NOW, this ,1998, upon receipt of the Conciliator's Report, it appearing that the parties have agreed to the terms and provisions of this temporary Order which was dictated in their presence and approved by them and their counsel, it is hereby ordered and directed as follows: 1. The parties agree to have an independent custody evaluation completed. The parties shall agree upon an independent custody evaluator within ten days of the date of this Order. Mother shall pay for the evaluation. Both parties shall cooperate in getting the evaluation completed in a timely fashion. 2. Pending completion of the evaluation, the parties shall share legal custody of their minor child, Justin T. Patterson, d.o.b. February 10, 1998, and shall operate under a custodial arrangement in accordance with the following: A. Mother shall have the child every Thursday evening from 6:00 p.m. until Friday at 6:00 p.m. B. Mother shall have the child every Sunday evening from 6:00 p.m. until Monday at 9:00 a.m. at which time she shall return the child to Father or the babysitter. C. Mother shall have the child on alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. D. Father shall have the child at all other times. If the party is unable to be present during their periods of custodial time with the child and have to use a babysitter, they shall make the other party the first option to have the child during that period of custodial time. 3. The parties agree that this is a temporary order and does not prejudice either party's rights from raising any issues that they deem appropriate for determining a custodial arrangement. 4. The parties shall reconvene for another conciliation conference before Michael L. Bangs, Esquire, on Thursday, December 10, 1998, at 4:00 p.m. Nora F. Blair, Esquire Emily L. Hoffman, Esquire mlb JEFFREY A. PATTERSON, : Plaintiff : v. : NO. 98-3749 : : CIVIL ACTION - LAW : CHILD CUSTODY STACY A. PATTERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DEFENDANT'S RESPONSE TO PLAINTIFF'S CUSTODY COMPLAINT AND NOW comes Defendant, Stacy A. Patterson, by and through her attorney, Emily Long Hoffman, Esquire, and in support of her Response and Counterclaim to Plaintiff's Complaint avers as follows: 1. Admitted. 2. Admitted. 3. Denied. The child is in the custody of the mother and father. 4. Admitted in part, denied in part. The child has also lived with his mother Stacy A. Patterson at 408 South Enola Drive, Enola, Cumberland County, Pennsylvania. 5. Admitted. 6. Admitted. Defendant also resides with her son. 7. Admitted. 8. Denied. It is denied that the best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff.does and will provide a more stable and nurturing environment for his son. 9. Admitted. WHEREFORE, Defendant requests that this Court deny Plaintiff's request for physical and primary custody of the minor child. COUNTERCLAIM 10. Paragraphs one through nine and Defendant's responses thereto are incorporated by reference herein. 1 l. Defendant seeks custody of the minor child, Justin T. Patterson. 12. The best interest and permanent welfare of the child will be served by granting the relief requested because Defendant does and will provide a more stable and nurturing environment for her son. WHEREFORE, Defendant requests that this Honorable Court grant primary physical and legal custody of the child to Defendant with visitation to Plaintiff as the parties may agree. Respectfully submitted, Sup. Ct. ID # 66307 105 North Front Street Harrisburg, PA 17108 (717)233-1112 Attorney for the Defendant Date: VERIFICATION Upon my personal knowledge, information, and belief, I, Stacy A. Patterson, verify that the facts averred and statements made in the foregoing document are true and correct to the best of my knowledge. I understand that false statements or Averments therein made will subject me to the criminal penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Stacy~. JEFFREY A. PATTERSON, Plaintiff VS. STACY A. PATTERSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-3749 CIVIL TERM CIVIL ACTION - CUSTODY ANDNOWthis ]0~ dayof ~ ,1998, it being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, cMulsCt odI~y~nL:i~iaAtt oN? Sff Nora F. Blair, Esquire Emily Long Hoffman, Esquire JEFFREY A. PATTERSON, Plaintiff STACY A. PATTERSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 98-3749 CIVIL TERM : : CIVIL-ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Petition for Modification of Custody Order, it is hereby directed that the parties and their respective counsel appear before [_~ ,~C~. c:~ , Esquire, Conciliator, at the ,~ ,~ \~M%..~Iv, ~ (*CFOI~ U~ , Pennsylvania, on the /(o day of__ ~)~'Q.. , 1999, at ,~',(~Q) ~) .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. Either party may bring the child who is the subject of this custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. FOR'THE COURT DATED: \C~( \~qq BY: 0 , , CustodY Conciliator (~ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 JEFFREY A. PATTERSON, Plaintiff Vo STACY A. PATTERSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 98-3749 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW, comes the Petitioner, Stacy A. Patterson, by and through her attorney, Maria P. Cognetti, Esquire, and files the following Petition for Modification of Custody Order and in support thereof, avers as follows: 1. Petitioner is Stacy A. Patterson, who currently resides at 408 South Enola Drive, Enola, Cumberland County, Pennsylvania. 2. Respondent is Jeffrey A. Patterson, who currently resides at 1084 Oystermill Road, Camp Hill, Cumberland County, Pennsylvania. 3. On or about October 1, 1998, a Custody Order was entered with regard to the parties' minor child, Justin T. Patterson, born February 10, 1998. Said Order is attached hereto and marked as Exhibit "A." 4. Pursuant to said Order the parties have shared legal and physical custody of their minor child. 5. Petitioner believes it is in the best interest of the child that their present custody schedule be modified to allow each parent to spend an extended period of time with the child. 6. Petitioner believes and therefore avers that the best interest of the parties' minor child will be served by modifying the current Order to the following rotating schedule: a. Monday mornings through Wednesday mornings b. Wednesday mornings through Friday mornings c. Friday mornings through Monday mornings 7, Petitioner believes and therefore avers that it is in the child's best interest that the present Order be modified. WHEREFORE, Petitioner respectfully prays this Honorable Court enter an Order modifying the current custodial arrangement. Respectfully Submitted, Dated: September 30, 1999 Maria P. ~~ Sup. Ct. I.D. #27914 200 North Third Street Twelfth Floor P.O. Box 689 Harrisburg, PA 17108-0689 (717) 232~2103 VERIFICATION I, Stacy A. Patterson, hereby verify and state that the facts set forth in the foregoing document are true and correct to fl~e best oFmy information, knowieage and belief: I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom verification to authorities. DATE: A. PATTERSON JEFFREY A. PATTERSON, Plaintiff VS. STACY A. PATTERSON, Defendant ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-3749 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ANDNOW, this /~../t_ dayof t~C..;~c~g'/~ , 1998, upenreceiptofthe Conciliator's Report, it appearing that the parties have agreed to the terms and provisions of this temporary Order which was dictated in their presence and approved by them and their counsel, it is hereby ordered and directed as follows: 1. The parties agree to have an independent custody evaluation completed. The parties shall agree upon an independent custody evaluator within ten days of the date of this Order. Mother shall pay for the evaluation. Both parties shall cooperate in getting the evaluation completed in a timely fashion. 2. Pending completion of the evaluation, the parties shall share legal custody of their minor child, Justin T. Patterson, d.o.b. February 10, 1998, and shall operate under a custodial arrangement in accordance with the following: A. Mother shall have the child every Thursday evening from 6:00 p.m. until Friday at 6:00 p.m. B. Mother shall have the child every Sunday evening from 6:00 p.m. until Monday at 9:00 a.m. at which time she shall return the child to Father or thc babysitter. C. Mother shall have the child on alternating weekends fi.om Friday at 6:00 p.m. until Sunday at 6:00 p,m. D. Father shall have the child at all other times. If the party is unable to be present during their periods of custodial time with the child and have to use a babysitter, they shall make thc other party the first option to have the child during that period of custodial time. 3. The parties agree that this is a temporary order and does not prejudice either party's rights fi.om raising any issues that they deem appropriate for determining a custodial arrangement. 4. The parties shall reconvene for another conciliation conference before Michael L. Bangs, Esquire, on Thursday, December 10, 1998, at 4:00 p.m. BY THE COURT, Nora F. Blair, Esquire Emily L. Hoffi.nan, Esquire mlb TRUE .COPY FROM RECORD Iv T~imo~y wh~r3of, I ~re ,,..to o,,, my hand aad the ~at. of said C~ at~ ~fli~o. ~) JEFFREY A. PATTERSON, Plaintiff VS. STACY A. PATI~ERSON, Defendant JUDGE PREVIOUSLY ASSIGNED: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-3749 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCH,IATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8Co), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(ren) who is(are) the subject of this litigation is as follows: NAME Justin T. Patterson BIRTHDATE February 10, 1998 CURRENTLY IN CUSTODY OF 2. A Conciliation Conference was held on September 10, 1998, and the following individuals were present: the Plainfiffand his attorney, Nora F. Blair, Esquire; the Defendant appeared with her attorney, Emily L. Hoffman, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintiff's position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent child(ren): Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. 9. Other matters or comments: The parties shall reconvene for another custody conciliation conference on Thursday, December 10, 1998, at 4:00 p.m. Date: September 29, 1998 Custody Conciliator JEFFREY A. vs. STACY A. PATTERSON, Plaintiff PATTERSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-3749 CIVIL TERM CIVIL ACTION - LAW CUSTODY AND NOW, this ~ ~ day of , 2000, upon review of the Conciliator's Report, it appearing that the parties have agreed to the terms and provisions of this Order which was dictated in their presence and approved by them and their it is hereby ordered and directed as follows: All prior Orders in this case are VACATED. counsel, 1. 2. The parties shall share legal custody of child, Justin T. Patterson, d.o.b. February 10, 1998. 3. The parties shall share physical custody their minor with the following rotating schedule: A. Monday morning no later Co in accordance through than 8:00 a.m. Wednesday morning no later than 8:00 a.m.; Wednesday morning no later than 8:00 a.m. through Friday morning no later than 8:00 a.m.; and Friday morning no later than 8:00 a.m. through Monday morning no later than 8:00 a.m. This is an ongoing rotating schedule such that the parties shall end their periods of partial custody with the child by dropping the child off at the appropriate daycare provider at the end of their period at the times indicated. This schedule shall commence with Mother having the child from Friday, January 14, 2000, through Monday January 17, 2000, and then the schedule, as indicated, shall rotate thereafter. 4. The parties shall alternate the major holidays. Those holidays are being defined as Easter, Memorial Day, Fourth of July, Labor Day and Thanksgiving. These periods of partial custody shall be from 9:00 a.m. to 7:00 p.m. This alternating schedule shall commence with Father having Easter in the year 2000 and then shall alternate thereafter. 5. Christmas shall be divided into two segments. Segment A is December 24t~ at noon until December 25~n at noon. Segment B is from December 25th at noon until December 26tn at noon. Mother shall have Segment A in the year 2000 and all even years thereafter and Segment B in the year 2001 and all odd years thereafter. Father shall have Segment B in the year 2000 and all even years thereafter and Segment A in the year 2001 and all odd years thereafter. 6. Mother shall Father's Day every year. from 9:00 a.m. to have Mother's Day and Father shall have These periods of partial custody shall be 7:00 p.m. 7. Each party is entitled to two (2) non-consecutive uninterrupted weeks of vacation with the child which should coincide with a weekend custodial schedule. The parties shall provide each other with thirty (30} days advance notice as to when they intend to exercise these periods. 8. Such other times as the parties may agree. Maria P. Cognetti, Esquire Attorney for Petitioner Jeffrey A. Patterson, pro se mlb BY THE EDWARD E. GUIDO, J. JEFFREY A. PATTERSON, Plaintiff VS. STACY A. PATTERSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-3749 CIVIL TERM CIVIL ACTION - LAW CUSTODY JUDGE PREVIOUSLY ASSIGNED: The Honorable Edward E. Guido CUSTODY CONCILIATION CONFEreNCE SUMMARY RE~ORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this NAME litigation is as follows: BIRTHDATE Justin T. Patterson February 10, 1998 CURRENTLY IN CUSTODY OF 2. A Conciliation Conference was held on January 14, 2000, and the following individuals were present: the Petitioner and her attorney, Maria P. Cognetti, Esquire; 3. Items resolved by agreement: 4. Issues yet to be resolved: 5. The Plaintiff's position on attached Order. the Respondent appeared pro See attached Order. See attached Order. custody is as follows: See 6. The Defendant's position on custody is attached Order. 7. Need for separate counsel to represent party requested. 8. Need for independent psychological counseling: None any is necessary. as follows: See child: Neither evaluation or requested and the Conciliator does not believe Date: Februaryl7, 2000 REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attorney for Plaintiff STACYPATTERSON, Plaintiff JEFFREY PATTERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-3749 CIVIL CIVIL ACTION - LAW IN CUSTODY AND NOW, upon consideration of the attached Motion for Custody Conference, it is hereby directed that the parties and their respective counsel appear before Michael L. Bangs, Esquire, Conciliator, at 302 South 18t~ Street, Camp Hill, Pennsylvania, on the \~x~' day of '~'~VC XC"x ,2000, at [©',O O (h .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. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for the entry ora temporary or permanent Order. FOR THE COURT DATED: Custody Conciliator [.J (-].~>.'-) YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA'vVYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No, (717) 763-1383 Attorney for Plaintiff STACYPATTERSON, Plaintiff JEFFREY PATTERSON, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-3749 CIVIL CIVIL ACTION - LAW IN CUSTODY MOTION FOR CUSTODY CONFERENCE AND NOW, comes Plaintiff, Stacy Patterson, by and through her attorneys, Reager, Adler and Cognetti, P.C., and requests that a Custody Conference be scheduled in this matter and in support thereof avers as follows: 1. The parties recently appeared in front of the Custody Conciliator on Jantlary 14, 2000. At that time, an agreement was reached as to pending issues. 2. One of the issues discussed at that time was the continuing daycare arrangements for the minor child, Justin T. Patterson, date of birth February 10, 1998. 3. Subsequent to the aforementioned Custody Conference, there became an opening in the daycare center in which Pla'mtiffhas been attempting to enroll the child. When she discussed this matter with Defendant, his response was that she could put the child in any daycare she chose dt~ring her time and that he would do the same. This is not acceptable to the Plaintiff: 4. Defendant has recently informed Plaintiffthat the daycare in which the child had been enrolled has been terminated and that there are currently no firm arrangements for the daycare of the child. 5. At the January 14, 2000, Conference Defendant stated that he was not represented by counsel and that Plaintiffs counsel should deal directly with Defendant. Plaintiff's counsel contacted Defendant mad asked that he confirm in writing that he is pro se. At that time Defendant stated that he would not do so and that Plaintiff's counsel should "attempt" to contact his attorney, Nora Blair. Plaintiff's counsel then left a message for Ms. Blair which has not been returned. 6. Since the parties have shared custody of this child, Plaintiff believes that it is imperative that they roach some agreement as to daycare and that they use only one daycare provider for the child. -2- WHEREFORE, Plaintiff respectfully requests that this matter be scheduled for a custody conference on an emergency basis so that daycare arrangements can be made promptly for this child. Date: March 1, 2000 By: Respectfully Submitted: REAGER, ADLER & COGNETTI, PC -3- VERIFICATION I, STACY A. PATTERSON, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. .PATTERSON DATE: CERTIFICATE OF SERVICE ANI~ NOW, this _~_~day of /~~ , 2000, I hereby verify that l have caused a tree and correct copy of the foregoing Motion for Custody Conference to be placed in the U.S. mail, first class, postage prepaid and addressed as follows: Jeffrey A. Patterson 1084 Oyster Mill Road Camp Hill, PA 17011 Date: March 1, 2000 By: REAGER, ADLER & COGNETTI, PC UIRE Attorney I.D. Nb. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763 - 1383 Attorney for Plaintiff/Petitioner REAGER, ADLER & COGNE~I'I, P.C. ATTORNEYS AT LAW 2331 MARKET STREET CAMP HILL, PA 17011-4642 (717) 763-1383 JEFFREY A. PATTERSON, Plaintiff VS. STACY A. PATTERSON, Defendant ) IN THE COURT OF COMMON PLEAS ) OF CUMBERLAND COUNTY, ) PENNSYLVANIA ) ) NO. 98-3749 CIVIL TERM ) ) CIVIL ACTION - LAW ) CUSTODY ORDER AND NOW, this //~X day of ~ ,2000, upon receipt of the Conciliator's Report, it appearing that a hearing is necessary on the sole issue of the appropriate daycare arrangement for the minor child, and also to consider Father's request to have the child on occasions when the child is in Mother's custody but while the child is in daycare, it is hereby ordered and directed as follows: A hearing is scheduled for the ~ day of ~/'l t/t , 2000, at /: .~t~ o'clock ~ .M., in Court Room Number .ff" ofthe Cumberland County Court House, Carlisle, Pennsylvania. Both parties, through counsel, will provide each other and the court with a memorandum outlining their specific position on these issues as well as a list of the potential witnesses they intend to call at the hearing. Otherwise, it appearing that the parties have agreed to the terms and provisions of a custodial order, which was dictated in their presence and approved by them and their counsel, it is hereby ordered and directed as follows: 1. All prior Custodial Orders entered in this case are VACATED. 2. The parties shall share legal custody of their minor child, Justin T. Patterson, d.o.b. February 10, 1998. 3. The parties shall share physical custody of their minor child in accordance with the following rotating schedule: A. Monday morning, no later than 8:00 a.m., through Wednesday morning, no later than 8:00 a.m.; B. Wednesday morning no later than 8:00 a.m., through Friday morning, no later than 8:00 a.m.; and C. Friday morning, no later than 8:00 a.m., through Monday morning, no later than 8:00 a.m. This is an on-going rotating schedule such that the parties shall end their periods of partial custody with the child by dropping the child off at the appropriate daycare provider at the end of their period at the times indicated. This schedule shall commence with Mother having the child from Friday, January 14, 2000, through Monday, January 17, 2000, and then the schedule, as indicated, shall alternate thereafter. 4. The parties shall alternate the major holidays. Those holidays are defined as Easter, Memorial Day, Fourth of July, Labor Day and Thanksgiving. These periods of partial custody shall be from 9:00 a.m. to 7:00 p.m. This alternating schedule shall commence with Father having Easter in 2000 and then shall alternate thereafter. 5. Christmas shall be divided into two segments. Segment A shall be from December 24t~ at noon until December 25t~ at noon; Segment B shall be from December 25th at noon until December 26th at noon. Mother shall have Segment A in 2000 and 'all even years thereafter and Segment B in 2001 and all odd years thereafter. Father shall have Segment A in 2001 and all odd years thereafter and Segment B in 2000 and all even years thereafter. 6. Mother shall have the child on Mother's Day and Father shall have the child on Father's Day. These periods of partial custody shall be from 9:00 a.m. until 7:00 p.m. 7. Each party shall be entitled to two non-consecutive uninterrupted weeks of vacation with the child which should coincide with a weekend custodial schedule. The parties shall provide each other with thirty (30) days advance notice as to when they intend to exercise these periods. ~ 8. Such other times as the parties may agree. BY THE EDWARD E, GUIDO, J. Maria P. Cognetti, Esquire 7~: ;' ~ ' Nora F. Blair, Esquire _ ; -t'/' ./. ~ ~' mlb JEFFREY A. PATTERSON, Plaintiff VS. STACY A. PATTERSON, Defendant ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-3749 CIVIL TERM CIVIL ACTION - LAW CUSTODY JUDGE PREVIOUSLY ASSIGNED: The Honorable Edward E. Guido CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(ren) who is(are) the subject of this litigation is as follows: NAME Justin T. Patterson BIRTHDATE Febmary10,1998 CURRENTLYIN CUSTODY OF Plaintiff and Defendant 2. A Conciliation Conference was held on April 3, 2000, and the following individuals were present: the Plaintiff and his attorney, Nora F. Blair, Esquire; the Defendant and her attorney, Maria P. Cognetti, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintiff's position on custody is as follows: Father's position is that Mother's daycare is not accessible for him because of the traffic patterns. He indicates that the Mother should use his daycare provider which is located on Center Street, Camp Hill, He also indicated that he does not believe that Mother's daycare provider is adequate. Father also wants the ability to extend his periods of time on occasions when he is not required to be at work until after the drop offtime. The drop offtime currently is 8:00 a.m. Occasionally he does not have to go to work until 10:00 a.m. so he believes that he should be able to take the child to daycare after 8:00 a.m. 6. The Defendant's position on custody is as follows: Mother's position on the daycare arrangement is that she has a daycare provider that is adequate and is near her home. Mother has some significant disabilities that occurred as a result of a motor vehicle accident. The existing daycare is on a bus route that she can use since she is unable to drive. The maternal grandmother does assist her with her transportation, but Mother cannot commit her mother to provide transportation for the custodial arrangement and therefore she needs to have a daycare provider in place that is on her bus route so that she can pick up the child. 7. Need for separate counsel to represent child(ren): Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. 9. A hearing in this matter will take one-half day. 10. Other matters or comments: There are some significant issues in this case that, through two separate conciliations, were able to be resolved. The parties did agree to an overall custodial arrangement. The problem occurred when they lost their daycare provider. After they lost their daycare provider, the parties were unable to agree on an appropriate daycare arrangement for the child. There is much more that is going on than the daycare provider, from the Conciliator's perspective. The parties live approximately within a five mile radius of the other, both in East Pennsboro Township. Mother has some significant disabilities and is unable to drive and naturally is dependent, to a great extent, on her mother for transportation. Mother found a daycare that was convenient to her home and is available by the bus line in case her mother cannot assist her. Apparently the Mother did not discuss the choice of the daycare with the Father. Likewise, Father never discussed his choice of the daycare with Mother. Father chose a daycare that is located on Center Street in East Pennsboro Township. Father maintains that because of the traffic patterns in the morning it is very difficult for him to get the child to the Mother's daycare. The maternal grandmother, who assists Mother with the transportation, has a similar complaint to Father as it relates to Father's daycare. Since Mother cannot drive, then she has to make sure that there is a daycare that is located on a bus line in the event her mother cannot help her with the transportation. The issue of the daycare is more ora control issue than anything. The one significant factor that exists, however, is that Mother does have disabilities and if she is unable to get assistance with transportation from her mother, she is dependent upon the bus line. Consequently, unless the maternal grandmother is willing to acquiesce to Father's demands (which apparently she is not), then Mother has little choice but to have a daycare that is on a bus route that is situated close to her house. Frankly, the arguments by both parties that it is "inconvenient" to transport the child to any of the daycare providers listed is merit less. There are numerous ways to drive to these various daycare providers and as indicated, the daycare providers and the parties' houses are within a five mile radius of each other. These daycare providers are "inconvenient" only because of the rigidness that has set in on this one issue. The second issue involves Father's ability to take the child out of Mother's daycare when the Mother is working. As the Conciliator noted to the parties previously, if the Father is off from work and is otherwise available, there is really no reason why he should not be able to take the child out of daycare as long as he notifies Mother and has the child back available to Mother so as to not interrupt the scheduling. However, what Father wants in this case is to have a flexible return time. Unfortunately, given the acrimony that exists, it is vitally important that a fixed time be in place and while it may make sense in the overall picture to ailow Father to have some flexible drop off time, the realities of the case are that the flexibility will not occur because of the rigidness of the parties. The Court should not take much time in resolving this issue. The issue really is one that the parties should resolve without court intervention. If not for Mother's disability, which is a factor the Court will have to consider in resolving this issue, the resolution of the daycare problem could be achieved by a flip of the coin. Date: April 12, 2000 Michael L Bangs Custody Conciliator