HomeMy WebLinkAbout98-06979
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MICHAEL I'. ANTONELLI,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, I'ENNSYL VANIA
v
CIVIL ACTION - LAW
DENISE It ANTONELLI,
Dcfcndant
CUSTODY /VISIT A TION
NO. 98-6979 CIVIL TERM
OImER OF COURT
AND NOW. this day of , 1999, upon consideration of the attached Complaint. it is
hereby direetl".! that the parties and their respective counsel appear before
, "," -- -' Esquire, the Conciliator, at the Fourth Floor Conference Room,
Cumherland County Co0-thouse, Carlisle. P A. on the day of __' 19_. 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
may also be present at the conference. Failure to appear at the conference may provide grounds for
entry of a temporary or penn anent order.
FOR TilE COURT.
By',
Custody Conciliator
YOU SHOUU) TAKE THIS pAl'ER TO YOVl~ LAWYEI~ AT ONCE. IF
YOU DO NOT HAVE A LAWVER OR CANNOT AFFORI> ONE, GO TO
OR TELEPHONE TIlE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOl; CAN GET LEGAL HELP.
The Court of Common Picas of Cumbcrland County is required by law to comply with thc
Amcricans with Disahilities Act or I 99(). For infonnation ahout accessihle f;lcilities :UJd reasonable
accommodations available to disahled individuals having business before the court. please cont,lct
our oflice. All arrangenwnts mllst he made at least T2 hours prior to any h~arjng or business hcforc
the court. YOllmust attend the scheduled conferences or Iwaring,
Cl::\lnEHLANI> COl'Nn' IlAI~ ASSOCIATION
2 LIIlEIHY AVENIIE
CARLlSLE,PENNSYLVANIA 171lB
717-249--'166
(b) Every Wednesday evening from after school or at
4:00 p.m. through 8:00 p.m.;
(3) ~y~~r-YA~~~jg~ Father shall be entitled to two (2)
non-consecutive weeks of physical custody with the child from
June 15 through August 15 of each year, provided Father gives
Mother advance notice prior to May 1 of each year when he plans to
take a summer vacation with the child. Father may request two
(2) separate periods of su~ner vacation, provided each period does
not to exceed seven (7) days;
(4 )J!oliqi!Yl'.-,_ Mother and Father shall alternate the following
Holidays: Easter, Memorial Day, Fourth of July, Labor Day and
Thanksgiving Day. This alternating schedule shall commence with
Father having Labor Day in 1999 and alternating the holidays
listed thereafter. In the event a parties custody period shall
occur of such Holiday, the parties agree that custody period shall
modify to conform with the Holiday contact period as set forth in
this Agreement;
(5) ~hL~_~as ~9JlidAY. Father shall have physical custody of
the child each year on Christmas Day (December 25) commencing at
2:00 p.m. and continuing through December' 26, 1999 at 2:00 p.m.
The remaining period of the Christmas Holiday shall be shared
equally by Father and Mother;
( 6) M~~ti.tj,Q.n9.,LtiJ!1ei3_.-
provisions of this Agreement
agree.
Father and Mother agree that the
may be modified provided both parties
(7) 'l'r:anspoHatioJ1. Father and Hother shall generally share
transportation for the pickup of the child at the commencement and
2
termination of the time periods set forth above. Father shall obtain
the child from Mother's residence at the beginning of a custody period
and Mother shall obtain the child from Father's residence at the end of
a custody period. In the event Mother or Father is unable to comply with
the pickup times set forth, he or she shall provide the other party with
at least two (2) hours advance notice, when possible, of his or her
inability to comply with the time constraints set forth herein. Father
shall provide for all transportation on wednesday evenings.
(8) Emerqe\}cies ._ Father and Mother shall advise each other
immediately relative i:o any emergencies concerning the child and shall
further take any necessary steps to insure that the health and well
being of the child is always protected. The parties shall provide each
other with all home and work telephone numbers, as well as current
addresses for the residence of the child. Neither party shall use
access to such phone number as a means of harassing the other party.
(9) Drugf.hl,90hol use. Father and Mother shall refrain from the use
of any and all non-prescriptive drugs and alcohol while in the presence
of the child and during their respective periods of physical custody.
(10) 1'~_l_@hone contact. Father and Mother agree to allow each
other to speak with the child at any and all reasonable times as
requested by either party and that they shall avoid telephone
contacts with the child which occur after the child's bedtime.
For purposes of this Agreement, reasonable times shall be defined
as after 8:00 a.m. and before 8:00 p.m. on any day of the week.
Neither party shall use access to such phone number as a roc",ns of
harassing the other party.
(11) !':sj:ral1gement Neither parent shall do anything which may
estrange the child from the other party, or injure the opinion of
the child as to the other party, 01: which may hamper the free and
3
natural development of the child' s love or affection for the other
party. Neither parent shall disparage the ,reputation of the other
parent in the presence of the child.
(12) !:I..9difi_c.i!tion Any substantial modification or waiver of
any of the provisions of this Agreement shall be effective only if
made in writing and only if executed with the same formality as
this Agreement. In the event any Court deems this Custody
Agreement unenforceable due to changed or unforseen circumstances,
such decision shall have no effect on the remaining portions of
this Agreement.
(13) Jurisdiction The parties agree that any Court of
competent jurisdiction may enforce or modify relevant portions of
this Agreement. 'I'he parties further acknowledge that either party
may petition any Court with appropriate jurisdiction over the
child should circumstances change and either party desire or
require modification of this Agreement. The parties further
acknowledge and agree that the laws of pennsylvania shall govern
any custody proceeding initiated in any Court of competent
jurisdiction.
(14) Futu~e actj~Qns Each party agrees that this Custody
Stipulation and Agreement shall be enforceable by either party
until either the filing of another Custody petition or other
action in any Court of appropriate jurisdiction in this
commonwealth.
(15) ~o.J1llTlllni~_ilti()nsL_rhir_d_party(~are Bother and Father
ag.ree that each shall directly communicate to each other whenever
possible in accordance with the terms set forth in this Agreement
and that they shall not use child as a liaison to cOllulIunicate with
each other as to oral modifications of: this Aqreement and
.1
.....
,
\..,
BROUJOS & GILROY, P.c.
AITORNEYS AT LAW
4 NORTH HANOVER STREET
CARLISLE, PENNSYLVANIA 17013
717-243-4574 766-1690
JAN 21 ZOOOlV
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(b) Every wednesday evening from after school or at
4:00 p.m. through 8:00 p.m.;
(3) ~unullE'tr vaca~iofu Father shall be entitled to two (2)
non-consecutive weeks of physical custody with the child from
June 15 through August 15 of each year, pr.ovided Father gives
Mother advance notice prior to May 1 of each year when he plans to
take a summer vacation with the child. Father may request two
(2) separate periods of summer vacation, provided each period does
not to exceed seven (7) days;
(4)_Holiciay~ Mother and Father shall alternate the following
Holidays: Easter, Memorial Day, Fourth of July, Labor Day and
Thanksgiving Day. This alternating schedule shall commence with
Father having Labor Day in 1999 and alternating the holidays
listed thereafter. In the event a parties custody period shall
occur of such Holiday, the par'ties agree that custody period shall
modify to conform with the Holiday contact period as set forth in
this Agreement;
(5) ~!J1;jcs_t,mi!.Ui,Q.lj,,~qY Father shall have physical custody of
the child each year on Christmas Day (December 25) commencing at
2:00 p.m. and continuing through December 26, 1999 at 2:00 p.m.
The remaining period of the Christmas Holiday shall be shared
equally by Father and Hother;
( 6) l\dqit,ion!l,Lt,iI)\,"-~,
provisions of this Agreement
aqree.
Father and Hother agree that the
may be modified provided both parties
(7) Tr.ilnspor.!~aticn. Father and Hother shall gene;::ally share
t.ranspol'tation for the pickup of Uw child at the cOl1Unencement and
2
termination of the time periods set forth above. Father shall obtain
the child from Mother's residence at the beginning of a custody period
and Mother shall obtain the child from Father's residence at the end of
a custody period. In the event Mother or Father is unable to comply with
the pickup times set forth, he or she shall provide the other party with
at least two (2) hours advance notice, when possible, of his or her
inability to comply with the time constraints set forth herein. Father
shall provide for all transportation on Wednesday evenings.
(8) Emergencies. Father and Mother shall advise each other
inunediately relative to any emergencies concerning the child and shall
further take any necessary steps to insure that the health and well
being of the child is always protected. The parties shall provide each
other with all home and work telephone numbers, as well as current
addresses for the residence of the child. Neither party shall use
access to such phone nlllnber as a means of harassing the other party.
(9) DrugLAl.cohoL!L~!:l-,- Father and Mother shall refrain from the use
of any and all non-prescriptive drugs and alcohol while in the presenc€
of the child and during their respective periods of physical custody.
( 10) Telephone'-<;:,QD,t.;3.~h Father and Mother agree to allow each
other to speak with the child at any and all reasonable times as
requested by either party and that they shall avoid telephone
contacts with the child which occur after the child's bedtime.
For purposes of this Agreement, reasonable times shall be defined
as after 8:00 a.m. and before 8:00 p.m. on any day of the week.
Neither party shall use access to such phone number as a means of
harassing the other party.
(11) Sst):,lWgemen,L Neither parent shall do anythinq which may
estrange the child from the other party, or injure the opinion of
the child as to the other' party, or' which may hamper the fwe and
3
.'
natural development of the child's love or affection for the other
party. Neither parent shall disparage the reputation of the other
parent in the presence of the child.
(12) ~odificat~Qn Any substantial modification or waiver of
any of the provisions of this Agreement shall be effective only if
made in writing and only if executed with the same formality as
this Agreement. In the event any Court deems this Custody
Agreement unenforceable due to changed or unforseen circumstances,
such decision shall have no effect on the remaining portions of
this Agreement.
( 13) Jurisdiction The parties agree that any Court of
competent jurisdiction may enforce or modify relevant portions of
this Agreement. The parties further acknowledge that either party
may petition any Court with appropriate jurisdiction over the
child should circumstances change and either pat'ty desire or
require modification of this Agreement. The parties further
acknowledge and agree that the laws of pennsylvania shall govern
any custody proceeding initiated in any Court of competent
jurisdiction.
(14) future acti_Q-'l,s, Each party agrees that this Custody
Stipulation and Agreement shall be enforceable by either party
until either the filing of another Custody petition or other
action in any Court of appropriate jurisdiction in this
Conunonwealth.
( 15) COll1!!l!l!1.i.Q9.t..i9J)sL,_Tl]inLI:arty__caXg 110ther and Father
agree that each shall directly cOllununicate to each other whenever
possible in accordance with the terms set fort.h in this Agreement
and that they shall not use child as a liaison to conununicate with
each other as to oral modifications of this Agreement and
4
MAR 1 '7 ?OOO
MICHAEL P. ANTONELLI, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : CIVIL ACTION - LAW
: NO. 98-6979
:
DENISE R. ANTONELLI, :
Defendant : IN CUSTODY
ORDER OF COURT
AND Naif this 15th day of March, 2000, the Conciliator, being
advised by counsel that all custody issues have been resolved by agreement
of the parties, hereby relinquishes jurisdiction in this case. The Custody
Conciliation Conference scheduled for today, March 15, 2000 is canceled.
FOR THE COURT,
C{LiLcb,.~
Dawn S. Sunday, Esquire I
CUstody Conciliator