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Home My WebLink About98-04450 P'. ft,,' ....:::' . ,,:' ',.".' '.:,,> 1....., ::.,.;'.... ":,", ':",".'^,' ....... :'" .,,~.:' ,.,', : 4" . I.^W OJII'.cms BARBAHA SUMPI.E-SULLIVAN nolI) UHmOH STHHHT NHW GIJ~IIIBIU.ANn, PI~SNSYI.vA."I^ 17070-1001 )'1I0SH (717) 7701.-1".':1 1'.\.'1( (717) 77"-701'\11 August 5, 1998 Prothonotary's Ollicc Cumberland County Courthouse 1 Courthouse Squarc Carli sic, P A 17013 Re: Rudy v. Candioto No. 98-4450 Civil Term / Cumberland County Dear Sir/Madam: Enclosed please find EKhibit "B" of the Custody Complaint in the above captioned matter which was inadvertently omitted. Please insert this exhibit in the original Custody Complaint. Thank you for your assistance. ..7" V;ry 'Ztru y rs" / /c /''/' - -" ",-,: t- Barbara Sumple-Sullivan BSS/mts Enclosures cc: David A. Wion, Esquire (w / enc. ) Sharon L. Rudy (w / enc. ) EXHIBIT "B" ~ - , - .. ~1? ('oJ " , c:'" :'~l ..,', " > " , , ~,! . " - . " \0-. .- c:,. '.~) i'.'} '"7 I, , ,.-., I , ~l: ' s:... , j , Li L::. I )n -: i ~" ...:..:.. ~j " Co 0 (f' (.) ......, .~ ~ d C; ~ ~ ~ ~ ~ ,'" ~ vi ,- \ . .II '^ ~. It "'" ~ ~ fi= C'" ~ .' -" .e: ,..:';,: ,:' :J :) 0.1(1 r , ~":~ i: ) (1\ '.,' K: "'. l-i.,;'t":. r..., ;~~ (')1",:' , C.l (...) : (!~ G" . , I , -, (( ,~ 5'!,t:',i co , /~ " oJ ....., ~'2n.. j~: "'-t I eJ ~-;; ..~ 0 Q1 '.) ~ '" '" ~ ci Z b ot ... > ~ :i < .J Z :J ti < lfI Ul IIJ :i w J1J t: ~ ~ ..J III In Il. D.. \iJ Z 0:;; 8 Z ~ _ w ~ :J = 0. "Ul~ci <C~. z o::~:5 ot a: m w 0: m ot ::; m ::J u ~ Z ,0 . ." . . ,,/d "1:;) "'-.:I ""' . -sJ SHARON L. RUDY, PlaintiO' : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - CUSTODY RONALD L. CANDlOTO, JR., Defendant : NO. q~ - '1 'i:,1) CL~'.:.J '0..-... ORDER OF COURT AND NOW, this h day of I~~",+ , 1998, upon consideration of the attached complaint, it is hereby directed that the parties and their resoecti counsel appear before \-\ \ (\'\n c: \ L , ~ the conciliator, at "2,C'i~ :-). \R-\-n ...:')\, I CC{'f\9 I-\' \ \ ,I?I\ ~ , on the -.D.. day of 'SJ:-&r0h.'I, 1998, at ~/.1M. for a Prehearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this eannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children five or older may all be present at the conference. Failure to appear at the conferenee may provide grounds for entry of a temporary or permanent order. FOR THE COURT: BY:~OO~.~~- Custody Conciliator ("IT->, ) 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, FOURTH FLOOR CARLISLE, PA 17013 (7 I 7) 240-6200 ,'y., , ";1 ;:;~,-J'<'::.',~.'::. I...... .'-""1 (':': -,., .. ., " ,,;, , ,~ - ,." I?' "'1 r. ~I . J ." . .,~ ;j:'j. ~,,'~ - ." .., C;;; . , - .......-_.~: I ~. F :i.:\ ~:.,' ~ ~':.< \ it- .~t d~/. &;0/ M;~AJ7" .,f 4d ~~ . ,,d,a'n,,- , ; 1~..tJt" '71t,.tu~ P! a~ if. cUr' S" v IJ.r b!1 p&ct:.J ~u<-. 'JY1. 1:.-1;1,1''' ;/r-'Ij, . '.' ,'1:. '-', '". \ .'~ " ,; ',':,. ~: l ,"". ":' :,,:,,':.:' ': \',:, .11~.,', 'J'~~";' ~ "",:~...-'::\ ~",...,., :r'~',~.'" .,;' " ~, :,' ,. ...:r .;.:....~~?.::-io';!:. EXHIBIT "A" ... ~ . ..--' '",,1"; ~;i';; : ." ~.'!,',,:\, \:,' t.~,'.,'. ," ,.:'C ." ':::.".,', ~"'J' :'<_ . ,'. '.' _0.,'.,",_.,,) ...::,:.~:~:..,!.. :,"" ',.\'. ,:'\ "". r' \ ,..... I 1 \ SHJI.RON L, CANDIOTO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW RONALD L. CANDIOTO, JR., Defendant NO. 585 CIVIL 1989 IN DIVORCE SUPPLEMENTAL DIVORCE DECREE AND NOW, this 'yl... C2& "'clay of , 1989, it is (It'(j atcached Marital ordered and directed that the Agreement dated April 26, 1989 by and b6~ween the parties hereto be incorporated into this separate court order, and the parties are directed to comply therewith. By the Court, J ~) 0y.~ 4- HMl-6 , I J. 12:_';: c:~'( ..;~~:~: Rr:CCRD IfJ ":"i ..'7'j 'i.",:~: .!1:; 3e! m)' ham, 'n '.' ..', . "'"''J'~' '" -JO- Ill.. \....I ,U;;, '<1, "-_"._~':"___._~'.._'_----:_'~.~"~~_~~7"_"'.'_M~__".'. _ _,","~'___n._......",:._, '. -. I' (- MAJU'I'AI, AGlillI':MI-:fI'I' THIS AGREEf1ENT, made this .)(, p, day uf a~l.. 1,989, by and bet'..Jeen SHARON L. CANDIOTO, of 516 Kevin Court, Camp Hill, Pennsylvania, party of the first part, hereinafter referred to as "Wife", and RONALD L. CANDIOTO, JR., of 524 poplar Church Road, Camp Hill, Pennsylvania, parey of the second part, he!:"cinattcr referred to as "Husband". \HTNESSETH: WHEREAS, the parties hereto are husband and wife, having been married June 21, 1981; and WHEREAS, there has been issue of that marriage, to wit: RYAN S. CANDIOTO, born July 10, 1983; and NICOLE M. CANDIOTO, born October 22, 1985; and WHEREAS, certain differences have arisen by and between the parties as a result of which they have now separated or now live separate and apart from one another, or contemplate living separate and apart from one another, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support and/or maintenance of the children; the implementa- tion of custody/visitation arrangements for the minor children of the JAMES O. BOGAR. ATTORNEY AT LAW. 5WEST MAIN STREET. SHIREMANSTOWN, PENNA. 17011 ,'Jr:. , ~'" _:. :" ..;" ':- ~':.., ':." ~+:: ,'.,_ ',',:",\ ,I,,:,:, '.,'",'.: ~:': _: ,:<<, ,0',. <~T, .,....-' '\.;~_r':;"~ :', '\ .\:: ':',:~.,'>"~,' Husband represents and warrants to Wife that from the signing of this Agreement and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. Wife represents and warrants to Husband that from the signing of this Agreement and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. 10. CUSTODY Husband and Wife acknowledge that legal custody of Ryan S. Candioto, born July 10, 1983 and Nicole M. Candioto, born october 22, 1985, will be shared. Legal custody is defined as follows: the right to participate in making major decisions touching upon the child's welfare including, but not necessarily being limited to, decisions involving education, medical care and religious training. The parties hereto agree that physical custody of Ryan S. Candioto and Nicole M. Candioto, will be shared with Husband and Wife alternating as the primary custodial parent on three (3) month inter- vals. Said physical custodial arrangement will commence March 1, 1989 10 ,.,.,......,.. .! ( with the children staying with Wife for a three (3) month period. Thereafter, Husband shall have the children on a three (3) month basis and continuing on a three (3) month cycle. The non-custodial parent shall be entitled to have the children for one (1) weekend per month, said weekend commencing at 6:00 p.m. on Friday and ending 7:00 p.m. on sunday. Said weekend shall be mutually agreeable by and between the parties hereto and in the best interests of the children. In addition, the non-custodial parent shall be entitled to additional visitation, including visitation on holidays and birthdays as is mutually agreeable and in the best interests of the children. Finally, the parties hereto agree that the within custody arrangement be subject to review after the expiration of the initial year of said agreement by the parties hereto and further, that the custody arrangement be subject to review at any given time according to the applicable changed circumstances, guidelines. Each party hereto agrees to give the other ninety (90) days advanced written notice of any intention to change or move from their existing residence as set forth in this agreement. In addition, if either or both of the minor children will be inaccessible for any reason to either Husband or Wife for a period of time exceeding forty- eight (48) hours, then the party having custody of said child or children shall promptly notify the other party of the proposed where- abouts of the child or children and provide a phone number or other 11 ..,...... ,l'.':'7,'7:""':.~;';:;:';;':;'~ . <', ,',~ ,.~... 't,,.' ,~, "","': ': ". . ',.':" ': ;""",,,'~ .__,_~'~ ,.,;." '.. :"~"". .......~~~ ........~---_._... .,,,.,.....;,,......~,.- ( method of contact to be used in case of an emergency or the like. 11 . SUPPORT FOR CHI LDREN The parties hereto agree that neither will request from the other a contribution or contributions on account of support for the minor children. It is understood that circumstances may necessitate a request by one (1) party to the other for a contribution of support on account of the minor children, depending upon the circumstances and the respective incomes of the parties hereto. Husband agrees to maintain and retain the present level of medical and hospitalization coverage that is currently available through his present employment for the benefit of the parties' minor children. The parties further agree to evenly divide the costs of all medical expenses incurred for or on behalf of the minor children to the extent that said medical expenses exceed the current medical and hospitalization insurance available. 12. ALIMONY, SUPPORT AND MAINTENANCE Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to seek from the other 12 . 'J'.:, "1' ..::' ~ ... ',' '^ '::~.' ,~.. 't~:,~ ,~' ,:, :.-:. ~i:. ',',~ ~ '".::: \ ".... ,.' .I~\ ,. ,:",,' . ,:L. .:~ ' ,. . . ,. . -. ~ "'. ">; .,:'L...,;",...... ,.,....- and seals the day and year first above written. WITNESS: , .........J , I l' L...H.{WU /) t'76l.-'1.J1 I I ~ ,~o , ]'\1\ ^'ktcl, r.M o-~ , Nil 1('/ IIC~~' Ca ioto ~; r h;;;;:~ Candiotol (SEAL) (SE,\L) , 9 ~ <...... , ...." '.. 'J '.' " :":.' ,'" ','.', ~,~' ." "'. "'~" ~ ,':"_' ~ _' w:....' \ ~.~.'.. I" . - .' SHARON L. RUDY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,I'ENNSYLVANIA PlnintiO' v. : CIVIL ACTION - CUSTODY RONALD L. CANDJOTO. JR., Dcfcndant NO, VERI FICA TJON J. SHARON L. RUDY, hereby certify thntthe facts sct forth in the foregoing CUSTODY COMPLAINT are truc and correct to the bcst of my knowledgc, information and bclief. J understand that any false statements made hcrcin are subject to pcnaltics of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. ~h[LLLf't ~ jfL/ilr SHARON L. RU I " ,.,' 1 "." . ."1 ~"',' "." ,\ :. : ' :,~, ,~..,\_ . ,'~',' '" ~. !',", Plainlin' (N TIlE COURT 01' COMMON ('LEAS : CUMBERLAND COUNTY, PENNSYLVANIA SIIARON L, RUDY, v, : CIVIL ACTION. CUSTODY RONALD L. CANDIOTO, JIl, DcCcl1dal11 NO. 98-4450 Civil Term ORDER AND NOW, this ~ ~ay of_fu~ 1998, upon consideration ofthc Stipulation of the panics dated AUb'llst 17, 1998, it is ordercd and dccrced that said Stipulation is adopted as an Order of this Court. J. :~:.: ,.." ,?:~,,: !'V~-.~:':!,':' :.~., :':'. ;.,~"t'r . ~;:":: :'. ';:":':"':};':.:;~'~".:::~,:(:i;':~f.'-::~I:,"::"::'::'r:~::?::;:'..':/'i:;;;~~;/; "Y\:c''':'~~:'':/''.. ',:,: , ,~":ij{'-t'>:<...'.. ,'ir;': ::",: . '.,. ", .., "'.~.' ':., l~c' ,l,~"_~' ", ,..'" ,. "',, ,<, 1 ., " ',..,.. SHARON L. RUDY, PlaintifT : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY v. RONALD L. CANDIOTO, JR., Defcndant NO. fJ. .</${j? &';.J I~~ OJSTODY STIPULATION AND NOW this /711. day of U{ruIJ/- ,1998, by and bctween SHARON RUDY, of 842 W. FOKcrofi Drive, Camp Hill, Cumbcrland County, Pennsylvania (hereinafier referred to as "Mother") and RONALD L. CANDlOTO, JR. 510 Indiana Avenue, Lemoyne, Cumberland County, Pennsylvania. (hereinafter referred to as "Father"). WITNESSETH WHEREAS, Mother and Father are the parents of the minor children, RYAN S. CANDIOTO (Date of birth: July 10,1983) and NICOLE M. CANDIOTO (Dale of birth: October 22, 1985), who currently reside with the Mother; WHEREAS, pursuant to the parties' Agreement dated April 26, 1989, they shared physical custody of their children. Said Agreement was clarified by an Order of Court dated Oetober II, 1991 wherein father was designated majority custodian for school enrollment purposes only; WHEREAS, the parties are desirous to modifY said Agreement and Order dated October II, 1991; and NOW THEREFORE, the parties in an effort to amicably resolve the issues relating to custody agree as follows: 1. Father and Mother shall have shared legal custody of the parties' minor children. Major SEr 91990., u,~ . oj SHARON I.. RUDY. Plaintiff ) ) ) ) ) ) ) IN TilE COURT OF COMMON PLEAS OF ClIl\HlERI.AND COUNTY. PENNSYI.V ANIA vs. NO. 911..J.J50 CIVIL TERM RONALD L. CANDIOTO. JR. Dclcnd.1l11 CIVIL ACTION - CUSTODY OIWER AND NOW this [1l. day of S,/Jl'.)j'; I. , . 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, ee: Barbara Sumple-Sullivan, Esquire David A. Wion, Esquire