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HomeMy WebLinkAbout98-07304 ,8 ' ,- ."P , cf1 , C j o T ~, j ~. , '- ,cO ~ c... ~ J ,:1 \J .. ~ ,'J ,,) ~ ~~ i~ '~'....... j \ ; , , I ...... r:j \ i ,.. '- i:r 1 '? -~ ~ l~ - - I " " \ .. ':> I'" - ,,", " \ j ..: , I - , 'l --. ----- ..... i / LAW tlFFItTS NICHOLAS & FOREMAN, P.C. THE.PI.,ONt (717) 236.9391 !:AX (717) 236,6602 STEVE C, NICHOLAS BRUCE Q, FOREMAN JEFF FOREMAN YVONNE M, HUSIC JAMES L. WALSH 4409 NORTH FRONT SmEET HARRISBURG, PENNSYLVANIA 17110,1'/09 January :!<J. :!()()! The I lOll, Edward Guido. Judge Cumberland COllnty Court of Common Picas Cumberland County Courthouse In re: Douglas D, Brewbaker \" Sandra I.. Youngblood No, 9R-7304 Dear Judge Guido: Sandra Youngblood. defcndant in the abovc-eaptioned matter. ask that we no longer represent her. Nonctheless. wc rcceived an order of court with rcgard to a Contempt Order for her lllilure to abide by the Order. I did call Ms, Youngblood and she indicates that she is in compliance with thc order and will continue to comply with the Order, She indicates that she has communicated the same to the Court. Yel'l' trull' \,ours. o .' ,A ,.., r '\ , ,ie--, .' 'i I}: II \ ',i ' ,,/' 13ruc{l) ,1' orl~l1an BDF/mlr cc: L.isa Marie Coyne. Esquire Attorncy 1<11' Douglas I), Brcwbaker 'J.- N N E/t.INO ~ Sc...h f..J.~/c ,I .f 'f...,/'Yl,' /I.-lt"'llL ~fL ).. - / 7- 01 ;-:-- ,...:.. ~ '. ,,', . ; ,;".: , . ,- . -. ,- +. .' ~ ," . ,,\ . . ',' . . ,'. .. ~ DOUGLAS D, BREWBAKER, PlainL,iff IN THE COURT OF COMMON PLEAS OF CUMBEI'LAND COUNTY, PENNSYLVANIA v, NO, 9B~730~ CIVIL TERM SANDRA L. YOUNGI3LOOD, Defendant. CIVIL ACT]ON -LAW IN ,~USTODY ORDER OF COURT AND NO\~, this 12th day of January, 2001, all prior Orders of Court are vacated and replaced with the following: 1, ~eqal Custodv, The parties shall have shared legal custody of their daughter, Afton L. Brewbaker, born April 12, 1995, Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion, Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical l-ecords and i nfonna t ion. To the extent one parent has possession of any such records or information, that parent shall be required to "hare thee same, or copies thereof, with the otlwr parent wi thin such reasonable time ii', to make the records and informatlon of l',c',,,,onable use to the oth'2l- parent. 2. PJ"J'v';-:;i ('d1 ('11f---:1-(",(1\'. l'';utht'::,l' ;-_~h,Jl1 have pl:imary physical cU~3tod;/. }~",jthC"I' :__;lLJJ:1 h,"i\lI" r',:ll-t ial phy~:;jca] custody (,11 11i~3 ll',^'c-c:v.l2nd d(-.:J,Y~; ()~f, II \-:!l)ch l~<rl'~.;c';;tJy f,il1 duriJ:C] the v.,,'(:,ek. F01~ exa.mple', Father ;-:::Ld J ll,j",,!'_" P,i!': }"IJ phy~~jcal ('u:-,tody 1.}~om \'J(::dll(~~:3...1~.jY ;i.ltrC]" :.,cjlc,~,l lJilt:i J J"li,i,J/ 1~1,::)111j!lJ cc(-~CJl h,("..'k. _'. FdtlvJ :'il.j].1 ~~(. j n~.i~_.;!d i'_. r(-1-ji,:-,d:, of p:iJ.ti;-.jj Cll~.:tc,d)' OJ] h.::~ l1rL~l.:;CLd} d,jY;~" ~'~ ::: d: 1.1. ;_;Cl:C(.'] un1.1J '7:l_:(1 I).:~I. , .' . - .': I. .,. '. . ," . ;. , ' '.. 4' ,.'" ,- .-~ \, _, -' \ " . ..+,' , . . ; .' , . ' ". . . '!!!!!I!.'-~- :_.....,.~;>-,-_. ....~ ~ - ~..' - , . ~ These days shall not be scheduled on Saturdays or sundays so as to interfere wi th Mother's weekend ti me, Pel'sonal days shall be subject to a one-week notice to Mother, During any period of physical custody. Father will assist the Child with homework as necessal-Y. 4. Father shall have four nonconsecutive nine-day periods of visitation with his child each summer, Said periods may be exercised by giving ~lother notice by May 1st of each year of the four nonconsecutive nine-day periods he intends to exercise, 5, The Father shall have the following periods of holiday custody: Easter Sunday from 1:00 p.m, to 7:00 p,m, Memorial Day from 1:00 p,m, to 7:00 p.m, Father's Day from 1:00 p.m, to 7:00 p,m. Thanksgiving Day from 9:00 a.m. to 3:0U p,m. Christmas Eve, December 24, from Noon to 9:00 p,m. During holiday custody, the Father shall pick up and return the Child at the Mother's residence, G, During each party's period of custody he or she shall keep the other party informed of the Child's homework assignments for school, school meetings, and other non-academic and extracurricular activities in the Child's schedule. The parties shall also permit reasonable telephone contact between the Child and the other pac-ent during their periods of partial custody. 7, It is acknmdedged between the parties that they are e::-:p(;.riel1cing ::;C'l'i()Ut~ difficu1tiC:':.3 \\l'ilh tllelr conmnlnication ...:hieh i:::, in tl.ll:n, h':1".Jing dJ: ad\lc'r:~L~ impact Oll the}l: abiliti0::.> tel cc):~:nlunicat(' VJit11 r(:-~~drd '.:() cU~3todidl arr~)JJ\1l~~:11(:,J.lt::~ iC'l" tjJ\~ i...'.',' . . ~ ,~ """. . ' , , ' " ., 'J:. ~-" -". ':,', . '. " " \ - , . I - . . ' , 4J minor child, The part i e'1 are ordered and directed to complete the Seminal' for Separating P,ll'ents offered by Inner" \'Ior}",s in Harrisburg, Pennsylvania, The cost of the Seminar shall be shared equally bctween the par-ties, The pal"ties shall extend Proof of their complete cooperation unto the Inner \'Jorks staff. completion of the program shall be submitted to this Court and counsel for the other party within 90 days, This Order represents the prior Order of Court, as agreed to by the parties at the conciliation conference, amended in accordance with the request of the plaintiff, vlhich appears to be no longer objected to by the Defendant, By 10, vi o"~iS " tI ,',' . :' ,\,.' "', :,_'. .' ' :,,-',:' : . . '.' '., I \, ",: " 'I '; " ' ~ \ ~dward E, Gurdo, J, Lisa Marie Coyne, Esquire Attorney for Plaintiff Bruce D, Foreman, Esquire Attorney for Defendant Sheriff srs -- -~~.- DOUGLAS Do BREI-mAKER, plaint if f v, SANDRA L, YOUNGBLOOD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 98-7304 CIVIL TERM CIVIL ^CTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 12th day of January, 2001, it having been related to the Court that the Defendant has indicated that she has no intention of complying with Paragraph 6 of our Order of October 23, 2000, a rule is issued upon her to show cause why she should not be held in contempt, She is to this rule within ten days, file a response to x(\.oY t oJ) T \ 0 \ << \,l~c o ~1f Lisa Marie Coyne, Esquire Attorney for plaintiff Bruce Do Foreman, Esquire Attorney for Defendant Sheriff srs By the Court, 'p ~ (;-'C/\.liLv' kC) t D.,,) 11', t, I ,)' / 16/)') uJ;J-,' \ .I . ". L ,~\,lJO (, }~I"yJ~' 1,1 \ \,.,\)' ,\} ",ii' , " . 1,.,/ r . -'ll I . \! \, ,~ \ \,J.}.' i' I, ,"...": '.' ,'.:-~ ~""">"l: ,,::" ""..,.:,',... ','",'. ". """:,'. ,'.<, ,,'; ',',' . '.!:W@.I . ..,""'''''~ -." . '. . " -,' -;.' ," ~' H "',', ".:' ",; ::. ,'. ""'~: -',':- "'" '~"'. "'. '.: .'.' '\.' _ '.1. ',' " ,-:," 'J I) 7(1I')i'JP :}. I (" -' _'.I ) DOUGLAS D. BREWBAKER. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO, 98-7304 SANDRA L. YOUNGBLOOD, Defendant CIVIL ACTION - LAW CUSTODY QJiD..EJLQECO_UR.I AND NOW, this J;tA. day of O~ . 2000, upon consideration of the attached Custody Conciliation Summary Report, it is ordered and directed as follows: 1. A hearing is schE':duled in Courtroom N.?..~ of the CU'7'berland County r." 00 i) Courthouse on the / J..-tII day of Uf1t^'w''1~, 2001, ate ..Jt) o'c1ockd..,~, at which time testimony will be taken, For purposes of the hearing, the Father, Douglas D, Brewbaker, 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, The hearing shall be limited solely to the issue of the length of summer vacation time for each party, These memoranda shall be filed at least ten days prior to the hearing date, 2. Pending further Order of Court or agreement of the parties, the remainder of this Order shall continue in effect. 3, Legal Custody, Douglas D, Brewbaker. the Father, and Sandra L. Youngblood, the Mother, shall have shared legal custody of the minor Child, Afton L. Brewbaker, born April 12, 1995, Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's seneral well-being including, but not limited to, all decisions regarding her health, education and religion, Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information, To the extent one parent has possession of any such records or information, that parent shall be required to sha.re the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 4, !:by.siC?l.c.ustQ<;ly, Mother shall have primary physical custody, Father shall have partial physical custody on his "weekend days off, which presently fall during the week. For example, Father shall have partial physical custody from Wednesday after school until Friday moming each week, 5, Father shall be entitled to periods of partial custody on his "personal days" from after school until 7:00 PM, These days shall not be scheduled on Saturdays or Sundays so as to interfere with Mother's weekend time, Personal days shall be subject to a one-week notice to . r'^"~:;:o:,~' ~ ..1-' '"'. . . , ' '. _.,...... ~ l' .,.'. . '.' . t " : '. ' . . . T. \ '~ ," I.. . ., t .,.;', I L ."~ No, 98-7304 Mother. During any period of physical custody, Father will assist the Child with homework as necessary, 6, It is acknowledged between the parties that they are experiencing serious difficulties with their communication which is, in turn, having an adverse impact on their abilities to communicate with regard to custodial arrangements for the minor Child, In furtherance thereto, the parties have agreed to complete the Seminar for Separating Parents offered by Inner Works in Harrisburg, Pennsylvania, The cost of the Seminar shall be shared equally between the parties, The parties shall extend their complete cooperation unto the Inner Works staff, Any failure to do so shall constitute a direct violation of this Order of Court, 7, During each party's period of custody he or she shall keep the other party informed of the Child's homework assignments for school, school meetings, and other non-academic and extracurricular activities in the Child's schedule, The parties shall also permit reasonable telephone contact between the Child and the other parent during their periods of partial custody, BY THE COURT, //::;) , ~ Edward E. Guido, J, Dis\: Lisa Marie Coyne, Esquire, 3901 Market Street, Camp Hill, PA 17011-4227 Bruce D, Foreman, Esquire, 4409 N, Front Street, Harrisburg, PA 17110-1709 ) ("fU; (I~ JOJ..'I-tiJ I...-fJ--WJ ... I , . ",' .:.: ' ',l ",' '." ," . ,,', .,',' . , .. , . ~ , ' '_' : ,. '. " , .' ,.. .', i , DOUGLAS D. BREWBAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO, 98-7304 SANDRA L. YOUNGBLOOD, Defendant CIVil ACTION - LAW CUSTODY CJJSTQDY GQl'iCILJ.~ TLQN.S_UMMARY R.E.P_ORI 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 DAn=_OEsIRTH CURRENT!,. Y IN C_USTODY J:>.E Afton L. Brewbaker April 12, 1995 Mother 2, A Conciliation Conference was held on September 26, 2000, with the following individuals in attendance: The Father, Douglas D, Brewbaker, and his counsel, Lisa Marie Coyne, Esquire: The Mother, Sandra L. Youngblood, and her counsel, Bruce Foreman, Esquire, 3, The parties agreed to the entry of an Order in the form as attached, However, there was one issue which remained to be resolved, This matter shall be scheduled for a hearing before Judge Guido, 4, The issue which was not resolved was the length of summer vacation time, The present arrangement has been that Father would have two weeks of vacation each summer. Father has requested to increase this summer vacation time to a period of four weeks, non- consecutive, subject to a thirty day notice to Mother, Father is actually seeking four nine-day periods of vacation so that the weekend beginning and ending his vacation week are both included in his vacation time, 5, Mother's position is that she has made several compromises in the within Custody Order including: an additional two hours for Father to be with the Child on the evening of Christmas Eve, an additional period of custody for Father to have partial custody on personal days which may be scheduled throughout the year, and continuing the previous practice of two periods of overnight custody during the week to coincide with Father's days off from work, Mother has offered to increase his vacation time to a period of three weeks, as a mid-point between the present two and Father's request for four weeks, However, she was unwilling to accede to his request for four weeks vacation during the summer. It should be noted that Mother has primary physical custody and the current and continuing custodial arrangement . , No. 98-7304 weeks vacation time available to them through their employment. 1(\-IS/7.0{/ t.' ( 1ft .>1'1); "~ ,I {};'O/i Melissa~Peel Greevy, Esquire Custody Conciliator Date ',' '_." '_1.' " t, .,' _ ':, ' . \' , ,". ,'\' '.' ...., . " ,.' , ' . I' ",' .' . ,. . . ',..,~ \. > , ' _ . -' -' '. COYNE & COYNE, P.c. AUo/'llcys lit LIIW Henry F. Coyne Lisa Marie Coyne 390] Market Slreet Camp Hill, I'a, ]7011-4227 Telephone: (7] 7) 737-0464 Facsimile: (717) 737-5]61 \ . :'. I ' " . . .,', I ." .,,: ~ '. : ," , . , . " '. ': < ^ .,' ~; - ," "' " , .January 12, 200 I /lalld Delivered Hon. Edward E, Guido Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 Re: Brewbaker v, Youngblood No, 98-7304 Civil Term (In Custody) Dear .Judge Guido: We represent Mr, Brewbaker, the Plaintiff Father in the above-referenced custody matter which is scheduled to be heard by this Court today, The limited issue concerning this hearing is Father's request to increase his summer visitation from 2 weeks to 4 weeks, Attached is Plaintiffs brief Memorandum of Law in support of his request. Very truly yours, COYNE & COYNE, p,c. LMC/cmc Ends, ~~::Zl? ~ /~a Marie Coyne T L....-/ cc: Bruce D. Foreman, Esquire, w/enc!. via Facsimile Mr. Douglas Brewbaker . ,'~ ". OCT 2 I) 200Ct.tP DUG LAS D. BREWBAKER. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98-7304 SANDRA L. YOUNGBLOOD, . Defendant .?:";"~7~-. ., . I'" . . . "':1 CIVIL ACTION - LAW CUSTODY r:r.r 2 6 '~rry ORDER OF COURt t1JAJ AND NOW, this J;~ day of oJ;N:., ,2000, upon consideration of the attached Custody Conciliation Summary Report, it is ordered and directed as follows: 1. A hearing is sch~duled in Co~rtroom N.o..'J-2 of the Cumberland County ~ DO ;) Courthouse on the I J..-M day of UA^,UA~ ,200J, at9:.3() o'c1ockd..M., at which time testimony will be taken. For purposes of the hearing, the Father, Douglas D. Brewbaker, 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. The hearing shall be limited solely to the issue of the length of summer vacation time for each party. These memoranda shall be filed at least ten days prior to the hearing date. 2. Pending further Order of Court or agreement of the parties, the remainder of this Order shall continue in effect. 3. Legal Custody. Douglas D. Brewbaker, the Father, and Sandra L. Youngblood, the Mother, shall have shared legal custody of the minor Child, Afton L. Brewbaker, born April 12, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the tenms of this paragraph, each parent shall be entitled to all records and infonmation pertaining to the Child including, but not limited to, school and medical records and infonmation. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 4. Physical Cu.stQdy. Mother shall have primary physical custody. Father shall have partial physical custody on his 'weekend days off', which presently fall during the week. For example, Father shall have partial physical custody from Wednesday after school until Friday morning each week, 5. Father shall be entitled to periods of partial custody on his 'personal days' from after school until 7:00 PM. These days shall not be scheduled on Saturdays or Sundays so as to interfere with Mother's weekend time. Personal days shall be subject to a one-week notice to E;r4Jl (/! (I' ~o. 98.7304 Mother. During any period of physical custody, Father will assist the Child with homework as nec.essary. 6. It is acknowledged between the parties that they are experiencing serious difficulties with their communication which is, in turn, having an adverse impact on their abilities to cornmunicate with regard to custodial arrangements for the minor Child. In furtherance thereto, the parties have agreed to complete the Seminar for Separating Parents offered by Inner Works in Harrisburg, Pennsylvania. The cost of the Serninar shall be shared equally between the parties. The parties shall extend their complete cooperation unto the Inner Works staff. Any failure to do so shall constitute a direct violation of this Order of Court. 7. During each party's period of custody he or she shall keep the other party informed of the Child's homewor!( assignments for school, school meetings, and other non-academic and extracurricular activities in the Child's schedule. The. parties shall also permit reasonable telephone contact between the Child and the other parent during their periods of partial custody. BY THE COURT, ~ Edward E. Guido, J. Dis!: Lisa Marie Coyne. Esquire. 3901 Mar1<et Street. Camp Hill. PA 17011-4227 Bruce D. Foreman, Esquire. 4409 N. Frcnt Street. Harrisburg, PA 17110-1709 TRUE COpy FROM RECORD In Te;;llmcny whcrooL I ha.s unto set my hand and ~i'.tl W 01 ~.Jid C.)urt ;t C.:ilsle, Pa. This oJ 'I ~ day of (0if,i/",.~, olhvV '-k;u- 0 'rrt..iPL<- ~ I I Prothonc.tarf . ' .', ." '.' " .' .' . I' " , .<lOB 14: 4(J -. ,,"*. 71 '/44189% 'I~ELl SSA P Ci'.'EEW ESQ PAGE 02 DOUGLAS D. BREWBAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98-7304 ~'i':: " , , ) U'. l~ SANDRA L. YOUNGBLOOD, Defendant CIVIL ACTION. LAW CUSTODY AMENDED 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 tnls IIUgation is as follows: i'.. l!I~ME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alton L. Brewbaker Aprl112, 1995 Mother 2, A Conciliation Conference was held on September 26, 2000, with the following individuals In attendance: The Father, Douglas D. Brewbaker, and his counsel, Lisa Marie Coyne, Esquire; The Mother, Sandra L. Youngblood, and her counsel, Bruce Foreman, Esquire. 3. The parties agreed to the enby of an Order in the fonn as attached. However, there was one Issue which remained to be resolved. This matter shail be scheduled for a hearing before Judge Guido, 4. The issue which was not resolved was the length of summer vacation time. The present arrangement has been that Father would have two weeks of vacation each summer. Father has requested to increase this summer vacation time to a period of four weeks, non- consecutive, subject to a thirty day notice to Mother. Father is actually seeking four nina-<lay periods of vacation so that the weekend beginning and ending his vacation week are both included in his vacation time. 5. Mother's position is that she has made several compromises in the within Custody Order including: an additional two hours for Father to be with the Child on the evening of Christmas Eve, an additional perlod of custody for Father to have partial custody on personal days which may be scheduled throughout the year, and continuing the previous practice of two periods of overnight custody during the week to coincide with Father's days off from work. Mother has offered to Increase his vacation time to a period of three weeks, as a mid-point between the present two and Father's requ~t for four weeks, However, she was unwlUlng to accede to his request for four weeks vacation during the lIummer. It lIhould be noted that Mother has primary physical custody and the current and continuing custodial arrangement 200(\ 14: 4(\ 71744189% , I~ELISSA P GREEW ESQ PAGE 03 No. 98-7304 provides for her to have physical custody of the Child every weekend. Both parties have four weeks vacation time available to them through their employment. lo/;:J../oh xiM LdJ:~~ Me asa Peel Greevy, Esquire Custody Conciliator Date ."', ~. . :' , . . . ," ,,: . ' . . . I ':," '..' ,,'. .' . . " . . . .-.,' . ." . \ '~' 4.'. \ . _' " " .",' , CERTIFICATE OF S.~RVln: I. Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.c., hcrcby certify that true copy Plaintiffs Mcmorandum of Law was scrvcd this datc upon thc below.rcfcrcneed individuals at the below listcd addrcss by way of Facsimile on January II, 200 I and Iland.Delivery on January 12, 2001: Brucc D. Forcman, Esquire Nicholas & Forcmcn, P.c. 4409 North Front Strcct Harrisburg, P A 17110.1709 F){: 717-236-6602 COYNE & COYNE, P.c. Datcd: 1I..:::Ti41\J rll I Li a Marie Coync, Esq4 re 01 Markct Strect V Camp Hill, PA 17011-4227 (717) 737-0464 J . ........... "'. r - :-... . . \ . . _ '. . '" \ . '. \ ' '.. ,', ~ . .', ", .' .', -. ; t - l' . .' . , -' mn 31 /11I111\ 1'-.\ '\ DOUGLAS D. BREWBAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA .' " > "',: _ . . '. ' .l. ' :'. 'J' '. '. . .: .' . , ". - . " T", ,."" ' ~ vs. NO. 98-7304 SANDRA L. YOUNGBLOOD, Defendant CIVIL ACTION - LAW CUSTODY AMENDED 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: flIAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Afton L. Brewbaker April 12, 1995 Mother 2. A Conciliation Conference was held on September 26, 2000, with the following individuals in attendance: The Father, Douglas D. Brewbaker, and his counsel, Lisa Marie Coyne, Esquire; The Mother, Sandra L. Youngblood, and her counsel, Bruce Foreman, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. However, there was one issue which remained to be resolved. This matter shall be scheduled for a hearing before Judge Guido. 4. The issue which was not resolved was the length of summer vacation time. The present arrangement has been that Father would have two weeks of vacation each summer. Father has requested to increase this summer vacation time to a period of four weeks, non- consecutive, subject to a thirty day notice to Mother. Father is actually seeking four nine-day periods of vacation so that the weekend beginning and ending his vacation week are both included in his vacation time. 5. Mother's position is that she has made several compromises in the within Custody Order including: an additional two hours for Father to be with the Child on the evening of Christmas Eve, an additional period of custody for Father to have partial custody on personal days which may be scheduled throughout the year, and continuing the previous practice of two periods of overnight custody during the week to coincide with Father's days off from wor't<. Mother has offered to increase his vacation time to a period of three weeks, as a mid-point between the present two and Father's request for four weeks. However, she was unwilling to accede to his request for four weeks vacation during the summer. It should be noted that Mother has primary physical custody and the current and continuing custodial arrangement ..r !JI,.' r;'":T ~ j 1";' j;: I t~ CL~:",....I "J '.,.~ t):'-~TY i'.c:<:\'~ 'j L'.,'/,,'~i'\ . -".~" ...:.,. -, , " r;" '-", ~ . ,,':. '.',' , .,.. . ,:' ...,'....., ,::~_' '::, ' , _ ":,' ,~. . ~ ' . '. .. Me(issa Peer GreeV11 - Attorney and Counselor at Law 214 Senate Avenue, Suite 105 Camp Hill, Pennsylvania 17011.2336 Telephone: (717) 763.8995 : II: I :, J IIJOI! __J /~ Octobcr 2(,_ 2000 Richard .I, Picrcc Cumberland County Court or Conllnon Picas One Courthousc Square Carlisle, P A 17013-3387 Re: Brewbaker ,', Youngblood No. 98-730.t In Custody It has come to my attention that part of the last paragraph of the Custody Conciliation Summary Report did not appeal' in the originallilcd with the court. Therefore. enclosed is an Amended Custody Conciliation Summary Report. (;:j~ Melissa Peel Greevy _, , t" -. " . ' . ,':. ;".' I ~ . " . \ ".' " .:'" " " .' . .. . ,. ..". " Deal' Rick: \... Enc. I.,\W OFfiCES NICHOLAS & FOREMAN, P.C. 1 [lEYIIONE (I Il) 236.9331 fAX (717) 236.6602 ", \, ,:.... - . ". ".. ,.,' """,. ," I ' S;t:VE C. N1CHO~S BRUCE D. FOREMAN JEFF FOREMEN YVONNE M. HUSIC JAMES L. WALSfi 4409 NORTH FRONT STREET HARRISBURG. PENNSYLVANIA 17110.1703 December 12, 2000 Court Administrator Cumberland County Court Of Common Picas I Courthouse Square Carlisle,PA 17013 /Z,{1/ In re: Brewbaker v. Youngblood Number 98-7304 Dear Court Administrator: This oflice represents Sandra L. Youngblood with regard to the above-captioned custody matter. A conciliation occurred in this matter as resulting in the Order promulgated from Melissa P. Greevey, Esquire, custody conciliator, the only issue which remained open was the length of summer vacation. The father had sought an increase from a two-week vacation to four, nine-day periods. Ms. Youngblood has requested that we withdraw any contest that Mr. Brewbaker's request and withdraw our request for a hearing which has been scheduled before Judge Guido for Friday, January 5, 2001. On her behalf. I am requesting that the matter be returned to Conciliator Greevey with a request that the conciliation form be amended as set forth in this correspondence. This will make the hearing before Judge Guido loot freeing that time. Very truly yours. Bruce D. Foreman BDF/mlr cc: Sandra Youngblood Melissa P. Greevey, Esquire Lisa Marie Coyne, Esquire:../ p\.AINTlFPS EXHIBIT 1- . DOUGLAS D. BREWBAKER PLAINTIFF V, SANDRA L. YOUNGBLOOD DEFENDANT IN TIlE COIJRT OF COMMON PLEAS OF CUMIIFRLAND COUNTY,PENNSYLVANIA . ; > , , " . '. 'T '.' , '. ,,;:. ~ .' _ ' . . ':..' . ' _' _ " ,", . " "", _ '.:\ :' , ' .', ~'~" . l)!l-730-l CIVIL ACTION LA W IN CUSTODY QHIlElt OF COllRT AND NOW,lhis 3rd d~y of~!12!...-. 2000. upon consideration of the ~ltachcd Complaint, it is hereby directed that the p~rties and thcir respectivc counsel appear bc1(lrel\lclissa \', Grcc\'y. Esq, ,the conciliator. at_ 2\4 Scnatc A\'cnuc. Suitc 105. Camp Hill, I'A \ 70\1 on the 29th day of Augnst .2000, at 11:00 a,m, for a Pre-Hearing Custody Conference. At such con!ercnce. :111 crt(lrt will bc made to resolve the issues in dispute; or if this cannot be accomplished. to define and narrow the issues to he heard by the court, and to enter into a temporary order. All children age five or older may also be present at the contCrence. Failure to appear at the conference may pro\'ide grounds for entry of a temporary or permanent order. FOR TilE COURT. By: M AldjwLl!".GJ]'c.'P.),-,.E~~:., . (\Islody Conciliator The Court of Common Picas of Cumberland ('ounty is required by law to comply wilh the Americans with Disabilites Act of 1 l)l)O. For in!(lllnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court. please contact our oflicc. All arrangements must he made at ica~t 7'2. hours prior tn ~ny hl'...Ifil1l!. or husil1(,~s before ihe court. You must attend the scheduled conference or hearing. YOli SIIOlII.D TAKF TillS I'APFR ll) Yt)liR A'ITORNEY AT ONCE. IF YOU DO NOT IIAVE AN A'!TORNEY OR CAN:\Ol AFFORD 0:\1;. tiO TO OR TELEPHONE THE OFFICE SET FORTlIlIl'I.OW TO FIND 01 IT WIII;IO; YOI: C/\ N tiFT LHiAL IIELI'. ('umbL'rland County Itlr A~slH:jal\on 2 I.lherty A\'L'IlUC t '/IIIt,k. I'"nll') !I'allla 1701:1 I dq'h,,'"' (717) 2-1'J..1 lI,r, 'i. 'l.t)O g-)C)O 'f. ) ,0.0/ ',: niJ -,I l~ - -j \- i" ~:: ~-\ 2 .. h."", ','" I' 'lY CU~\',:~.~I-,l../': -,'j UJt....;,; I PENNSYi~:N,~\ {~i./. dory ,u...",(L/ /'b~;' 1'/1/,: ~.d~ , - ('7"/ /t(a~", ., .", 7.; ie' d7f ci./f ~. ~~:q;. ~ -, ?;...'"'"r("".,.~.,,\-'k~',"~ ,7 c;';?/<e. ,~.", ...._, C-'u"/(t"(/....t YU, . 'U'C;fr . ,,', ,. :', ) " , '. ' '. . ',;'--' , '~ " '.... ,.' ~ .' - ".., ",. . ._",'f~. "'_ ......~ ,'" .~- ".., ];~~t;j~'::::;'~;;-;: '': ',' , .,'" " I ' , . ':'. ,; " ,,,' ,', '.,'." '" ,:i"~',\;7;'f'f", ,,,,,,1 I"',,' , . 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"t, CAMPH!:iJ:4PA17011';,'/,\:: ",: I'" '1:i.;J::'-.'J':'~<,!", '~,"\:_":\:-:~rl~~~' ~~W'!.l(t!i"J:/{j,:,:,~'(.'r.,' ".,'.. / (j'~' I",I"/,;~\, ,~,\ '._'" '\"nl~~,,'("':)'q"."";,:'l~\t,\ )tl~Tl\'~'('1\i'fiC.'!,',:i;;'':''I{~\!:' "'\'" ' " . :- C?17)73.7~", ;'.!.; '" W;~ ,";';' r.\\ >,(,I:'!'{'~:;'~\'I;<:,:l\,~-;: 'r" .\.... ':1'/,\,(, .,><'\." , " >>'J' r , r, ',,~ \ .' ' '_'"j,/ ~~'11, "'''I':t.'lt~l''\ "'"'''''',''' ',' "", ',', ,', '.. ',' '.' ". . ,,;, ",:;;, ~":':(:"""'(,,,:.,,;;;:,; :t.."W< ,~.~Wo\';,~.\.: ','f' , '~:l ," I ',. ';'1) 0: " . ~:.. I'. ,;1., v ~ , " , , , L \ 'I I ; ( i I . . . ." ",' , '., ,::"', ,,'. -' '" . , :_r-r ,_...,. .."~.",,,,., ,: h.. r coYNE &COYNEi P.Ci . Attorneys at,'taW . 3901 Market Street CamP Bill, PA 170U-4227 (717) 737..0464 " '. '''':'1 \; J, .; ~~j:),.'" "',l ';, , " ';i, , ,/ ,'. l,'J;.i'.:".""t"' '~.; "\,!,i:t,~,,,!,...,I:~1 " ' " I"i-~\f'l':,"~l;' ," i';; ""~":\"'~r!'1"i4'tt.' ,,-----...:...." {i:~ ,,,,'I <\';:1,..;).':';;; ,. .:. " . ~\~,\'J,t~_~'\'Jj:' . ~. " ,.<','jo'j' tN'~)"'l'" " " :t.. . ~_. "!~"'(;'''''c,~ I \ " ,~, \ J " ';' ~. ~llf,f, '''> ',' " .' "'~ 1"-:" ~(,~ ~N" ;' ','i h-, ", ~1\q~.r~<< AU~2,,::,:I' .., "":""",,,,,,,,,,,,",,,,,,C!,,"'b,,~\,;,,;r.l('-~,,* . ,'.). ,', ,_,1--.;. ..".~r;~~..... .:. : I'; , ',1 l'.r"'~~~_ ... ., "') \ \ ( I i t . \ '... ":'-' , " " ' ., " ." . .~ - ~, " I' '.. _"", '" ~ .4 .- DOUGLAS D. BREWBAKER, Pctitjo ncr fDcfcnda n t, IN THE COURT OF COMMON PLEAS OF ClJMIlEnLAND COUNTY, PENNSYLVANIA at ,,' ': "," ' ", . ,c.- ,.," ," ..'. ",:.~~.-:..-__/6.,. ," 'I..:.", '.' .'_ '. . \'S. No. 98-7304 Civil TCfm SANDnA L. YOUNGBLOOD, ncspondcntfPlaintiff IN CUSTODY ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attaehed Petition, it is hereby directed thut the partics and their respective counsel appear beforc Esquire, Custody Conciliator, 2000, at on the __ day of o"clock _.m., for a Prehearing Custody Conference. At such confcrcncc. an effort will be made to rcsolve the issues in dispute; or if this cannot be accomplished, to define and narrow thc issues to be heard by the Court, and to cntcr into a tcmporary Ordcr. All children age five or oldcr may also be prcsent at thc confcrcnce. Failurc to appcar at the confcrencc may provide grounds for entry of a temporary or pcmJa!1cnt order. FOR TilE COURT By: Custody Conciliator YOII SHOULD TAKE TillS PAPER TO YOlln LAWYER AT ONCE. IF YOU DO NOT HA VE ALA 'VYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TilE OFFICE SET FORTH BELOW TO FIND OllT WHERE YOO CAN GET LEGAL HELl'. ClI1\IIlERLAND COIINTY BAR ASSOCIATION LA WYER REFERRAL SERVICE 2 LlIlEnTY A VENIIE CAIUJSLE. PA 17013 (800) <)<)0.<)108 cc: Usa Mane Coync. Esquire Bruee D. Foreman. Esquire ., DOUGLAS D. BREWBAKER, Pcl i liollcrlI>cl'cllda III, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 98-7304 Civil Tcrm SANDRA L. YOUNGBLOOD, RcspolldclIl/Plailllil'l' IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW COMES the Petitioner, Douglas D. Brewbaker, by and through his attorney, Lisa Marie Coyne, of Coyne & Coyne, P.c., and avers the following in support of his Petition for Modilication of an existing custody order: 1. Petitioner, Douglas D. B,'ewbaker, is an adult individual residing at 13 Highland Drive, Camp Hill, Cumberland County, Pennsylvania. 2. Rcspondent, Sandra Youngblood, is an adult individual residing at 117 York Strect, Enola, Cumberland County. Pennsylvania. 3. Thc Petitioner and Respondcnt arc the natural parents of " minor child AFTON L. BREWBAKER, born April 12, 1995. now age 5. 4. The Petitioner and Respondent havc never been married. 5. On II-larch 10, 1999, the parties entcrcd into a stipulation conccrning custody of AFTON L. BREWBAKER and which stipulation was incorporated into an Order of Court, dated April 7, 1999. (A copy of the currcnt custody ordcr is attached hercto as Exhibit "A"). 6. Since thc cntry of the Ordcr of (\!Urt. Rcspondent-Mothcr now indicates thai Pctitioncr- Fathc-r's existing wc.~l'kday overnight pCI'IOOS of p:1l1wl l'US100Y with his daughter wil1 no longer be grant cd bceausc thc chIld will st:lfl kindcrg"rtcnll1 thc Fall. . .. ., -; . . . . . l' " .' \ .' t . . ., . ~ .,'. :." '-"" ;"'. .. ':" ,': '. "" "'~. _ " .': ,~ ~. ) ,-, " ~. ,':l:i!!)~'''''-~''''' ,.."" '~~,,'~""-"'-""'''l'.'fr''' ;-:W.li~ _. '.,J- . ~"111"1-\." 7. Petitioner-Father rcsides less than live miles Irom the child's elementary school. S. Due to Father's work obligation f(lr thc railroad, he works on weekends and his days off are during the week. 9. During the school year, Petitioncr-Father can transport the child to school on the days the child has ovemights with Father, or, altcmatively, Father ean transport child to the Baby-sitter's residence where the child ean take the school bus. 10, Petitioner-Father desires to have a substantial presence in his child's life and to assist his child throughout the school tcrm by doing homework and other school-related activities with his daughter along with providing a stable. nurturing and loving presence in his child's life II. Petitioncr-Father desires four wecks of vacation with ehild during the year; however, Respondcnt 's counsel has indicatcd that s\Jch a request may not be acceptable to his client. 12. Respondent's eounsel. Bruce Fonmn. Esquire, has heen advised of the need for liling of this Petition for Modifieation of the Custody Order and request for a Custody Conciliation Conference. WIIEREFOiU!, Petitioner-Father respectliJlly requests that this Honorable Court modify the Order of April 7, 1999, to atTange a new partial custody schedule giving the Petitioner increased wecks of vacation as well as maintaining the existing o\'Cmight periods of partial custody during the week, and to provide any other such relicI' as this Court deems appropriate. Respeetfully submitted: COYNE & COYNE, P.c. Dated: / ..' '))' /: I I .11 / . /,,, ;,;; -llSa ~i:~;e V<l)nC .1<)(J1 Market Stlwt ('amp JlIII.PA 17011-4227 (71717.\7.04114 I';l. SU]1Il'me Ct. No. 5:17HX :1 {{I n 'lit '.\'.fc Jr J'l '1 it/mil 'r.Fat hi'r By: . : " ." " , . . ':. , .' ^. , , ' .' " . "',' A......: -,'- ',~ " .... ...., . .."", , . .' . ..' - , """_. .....n.~'._~ ~. 'tl'....~.~. r SANDRA L. YOUNGBLOOD, Plaintiff, : IN TIlE COURT OF COMMON PLEAS OF : CUl\1BERLAi\'D COUNTY,PE....~SYLVAt'IL\ vs. : NO. 98-7304 DOUGLAS D. BREWBAKER, Defendant. : IN CUSTODY ORDER OF COURT AND NOW this 1~ day of ~ . 1999, in consideration of the attached "",,^ck~"""'''b~ p~~ ~ Defendant's Petition concerning custody' it is hereby ordered and directed as follo\\'s: I. The parties shall have shared legal custody of their daughter, Afton L. Brewbaker, born April 12, 1995. 2. Primary physical custody of ACton L. Brewbaker shall be with the Plaintiff, the mother, Sandra L. Youngblood subject to periods of temporary physical custody with the Defendant, the father, Douglas Brewbaker, as set forth hereinafter: a. Commencing February 15, 1999, to March 28, 1999, father shall have custody of child every week, Monday through Friday, from 8:30 a.m. to 4:30 p.m. Father shall pick up and return child to babysitter, b, Commencing the week of March 29, 1999, unll1 the child re:lches school age, the father, Douglas Brewbaker, shall have custody of the child every week from Tuesday at 1 :00 p.m. until Thursday at 7:00 p.m. with the father picking the chIld up from daycare and returning the child to the mother's residence. I' /{ / X;// /0' / 7 19 " . ': .' '. ' :. :.,.~,"'" ..,. . '?'~'.-.,,-~ ":":'~.-" ':'1 ," " ,.'.':~: -. '. ,"'. :1' '--;',- '. ,," ,. ~t;,~'....... -" -'--:11'-= "P-~""-. ~.. '~1l:.-';~-',,'''1' ......:."~~' - .._...~ ..______._.ww.-. .-- \ I .__.._.....____....---.------- ___ - _..._ - __nO . -"._- ...-:-... -- .--.----.----.... ._~,._._--- \ c. The father, Douglas Brewbaker, shall have two designated weeks of vacation custody which week shall be designated at least thirty (30) days in advance by Defendant to Plaintiff and which weeks shall have at least three (3) weeks in between them. d. The father shall have the following periods of holiday custody: Easter Sunday from I :00 p.m. to 7 :00 p.m. Memorial Day from I :00 p.m. to 7:00 p.m. Father's Day from I :00 p.m. to 7:00 p.m, Thanksgiving Day from 9:00 a.m. to 3:00 p.m. Christmas Eve, December 24 from Noon to 7:00 p.m. During holiday custody, the Father shall pick-up and return the child at the mother's residence. J. cc: Bruce D. Foreman, Esquire For Plaintiff Lisa Marie Coyne, Esquire For Defendant TRUE COPY FROM Rl=r Ir. T ,st'mcr.'y whrr--r I h- _~ORD I. >...,.. , , r~ U".'" --t h d and the sael of <J'd r .. ''':. .. my an ", _ourt at Car';', Pa Th.:tL "''', . lS ....7........... day of ..~.:...c.. at:; . ,r' r. .' 19.,,1...L ............._~;;4' a. .......'...~~....- "" Prothonotary .' , _, _ .--~,~~-=--, ,_....,... ;' "~:~''', ",'7,h ~:.',':: ~-".-, '" ':, .\,,': '., 'II, .. ... " ~ .. '. .' . " " Y oungbloodStipulation2 SANDRA YOUNGBLOOD, Plaintiff THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA .. -', '.~ ......;lM;.....'.,;:oJf--~..,~-- .--~...~-~- '---".~,," '.' ,-,,;~.,.~,-.,~t.'l'" " " .... 'I'" ':'" .~. . v. : NO. 98-7304 CIVIL DOUGLAS BREWBAKER, Defendant CIVIL ACTION - LAW STIPULATION The parties hereto, represented by counsel, request, stipulate and agree to the entry of the following Order with regard to the custody of their minor child, Afton L. Brewbaker born April 12, 1995, now 3 y, years: 1, The parties shall share legal custody of the said minor child. 2. Primary physical custody of the said minor child shall be in the mother, Sandra Youngblood subject to periods of temporary physical custody in the father, Douglas Brewbaker, set forth hereinafter; a. Conunencing February 15, 1999, to March 28,1999, Father shaIlhave custody of child .:v.:ry w.:.:k Monday through Friday 8:30 a.m.. to 4:30 p.m. Father to pick up and return child to baby-siner. b, Conunencing the week of March 29, 1999, until the child reaches school age, the father, Douglas Brewbaker, shall have custody every week from Tuesday at 1:00 p.m. until Thursday at 7:00 p.m. with the father picking the child up from daycare and returning the child to the mother's residence; .-. 1~~.-s:..._ -.,.- "- c, The father, Douglas Brewbaker, shall have two designated weeks of vacation custody which weeks shall be designated at least thirty days in advance by defendant to Plaintiff and which weeks shall have at least three weeks in between them; '" c, The father shall have the following periods of holiday visitation: Easter Sunday from 1:00 p,m. to 7:00 p,m.; Memorial Day from 1:00 p,m. to 7:00 p.m,; Father's Day from 1:00 p,m. to 7:00 p.m.; Thanksgiving Day from 9;00 a.m. to 3:00 p.m.; Christmas Eve, December 24, from noon to 7:00 p.m. For each holiday visitation the father shall pick the aforesaid minor child up from the mother and return the child to the mother's residence. Having read the foregoing, and intending to have the same entered as an Order of Court, the parties hereto so stipulate with their attorneys as witnesses this I 0 ~ay of ~~1999. Witness: ,. i Marie Coyne, squire B~ere , ' "'~, .."....,,;'~,_..- ...... -", -__-. 1.- . ',-" <.-",~'J,:~'};;.-J J .........._, ~,' :-. ", ~ , '" ~',". \,. " 6_'_~ .~ .~.~_ . " ",~,' \' " ~",. " ,',' - .'. ", " . ,~, . ," '. "". ~ ;,~ . '".:.0""'.,,,.,......._ ~. SANDRA YOUNGBLOOD. Plaintiff vs, DOUGLAS BREWBAKER. Defendant AND NOW this ) , ...s" " .AUb J j 1999 (~. .....\ \j ) ) ) ) ) ) ) IN TI IE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 98.7304 CIVIL TERM CUSTODYIVISIT ATION ORDER OF COURT , / . day of i i . 1999. having not heard from the parties for some time. the undersigned Conciliator assumes the matter has been resolved and hereby relinquishes jurisdiction of the case. I I' either of the parties wishes further proceedings in this action, they should petition the Court anew. Bruce 0, Foreman. Esquire Mr. Douglas Brewbaker 629 West King's Highway Audubon. N.I 08 I 06 FOR 1'1 IE COURT. I i, n " 1; I '. . . . '" - ,'" '. l., . " ' ',' ..... . ' . . ,:-". ." . .: . :".__ , .'"' .': '. . _ .' :', . ,,', . \' \"""'" '---' \ MICHAEL L. BANGS Custody CO!lcilia/or . l ::.:' ('r' - ~ t:. \ ",,,' ( .:', ".\. " ','.,,\ . .. ',. .', . ,,1 . . ." . .' . . ~." '. - ' . " - ,~ ':'-'\"~'" '. n.< \ -, r ";1 \ " _,:1,': .~, 1 "~;.' :". ':\ .\ "'i " , ,', '1l t::,~:;~~'r, ,;;i;:i'i :;'){,~,V';" I;:. :,{ ;,::; ,':'::-":,,;' ,'.-;i;;/i,,:~:<,:t~:;i;i;:~~~}:;1i[:'f"~'\:;~'::':'~k:J~\ . ~~hl "''''-;\~:'~~/\'i,J:,;,::.','.':~''}', ~':~\;~'J(.'~'.lENRY'~;'FJ~CO'V:NE':~:.M;'.~I~' ';{\:'1'~~d,I,'~'~':I?;;'i'A:,~:t~+~ii" 1..'tt.a?;g~_ '".', './,.,:+ "I~<\" "\, "J ~' "'~ !;,:;",:, - /';', '~;"" : ~:' ;"; \ \ ( ..,. '"P,."'" " 1W ..:.";,"',' "t'",'\,,'Gi ,.... ',.: .'! ',' . '. ,_' > " ;', . . I. _ '. .,'". .'. '.-. "', SANDRA L. YOUNGBLOOD, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV ANIA vs. : NO. 98-7304 DOUGLAS D. BREWBAKER, Defendant. : IN CllSTODY ORDER OF COURT AND NOW this 7~ day of ~ . 1999, in considcration or 11", atta<,hl'd ~ck~"hrJ..# p...x;.:..~ ~ Defendant's Petition concellling custod;' it is hereby ordered and dircctcd as rollows: 1. Thc partics shall havc sharcd legal custody of thcir daughter. Anon L. Ilrewhakl'l. hOIll ApriI12,1995. 2. Primary physical custody of Aflon L. Brcwbakcr shall be with th~ Plamtltl. the 1110Ih,."1. Sandra L. Youngblood subjcct to periods of temporary physical custody with th~ J)~kllllanl. 1111' lall11'1. Douglas Br~wbaker. as sct forth hercinancr: a. Commcncing Fcbruary 15. 1999. to March 2S, 1991). j:lll11'r ,hall hall' l'lI'h"I~' of child every wc~k, Monday through Friday, Ii-om S:30 a.111. to 4:30 p.m. I;alhl'r "hall pick lip alld 1l'11I1Il child to babysittcr. h. Cmnm~ncmg th~ w~ek ofMar~h 29. 1l)9().lllll1llhe <,hil<I ,,'ad\\", ,<,hllol "1'1'. ,I\\' father. Douglas Brewbaker, shall have custody "fthe ~hilll every week 1''''111 11Il',day ;It 11101'111. 1I1l111 Thursday at 7:00 p.m. with th~ fath~r picking Ihe dnld up Ii'mn day,;u, and n.tlll1llllg thl' 1'1111.1 hI thl' mother's resIdence. ., .,', " '. .,.',,'.. ,': ' ',. ',".: ',~.,', .~.... ,', ~ " '. '. " ',_____,......_u , " I. ,'" . c. The father, Douglas Brewbaker, shall have two designated weeks of vaeation custody which week shall be designated at least thirty (30) days in advance by Defendant to Plaintiff and which weeks shall have at least three (3) weeks in between them. d. The father shall have the following periods of holiday eustody: Easter Sunday from I :00 p.m. to 7:00 p.m. Memorial Day trom I :00 p.m. to 7:00 p.m. Father's Day trom I :00 p.m. to 7:00 p.m. Thanksgiving Day from 9:00 a.m. to 3:00 p.m. Christmas Eve, Deeember 24 from Noon to 7:00 p.m. During holiday custody, the Father shall piek-up and retul11 the ehild at the mother's residence. J. ec: Bruce D. Foreman. Esquire For Plaintiff (' ",y e,' )1\,,~l~Lt,~ "1/7/1'1, .J -!' Lisa Marie Coyne, Esquire For Defendant , . ,',.',"'.'. t: "'. .:', ,.,':,,' ',':', ::. ,1 '. .' '<:' . :,' '",' :.,~.,..'~,:." "'. ," ..... '1'-'- . , . '~\~r.nY ('" I 'C'. :..;; I, I' ',l .,' ~ 1 c; \',; r:: ~ CU;\/;~~,.~: .~.. . ...: ;.>~):J;'~T'{ F:C;<i\~SY ~ .ii\l ~~f:\ - ' ' .' ' , '. . ,- -. "."" '. . \. . . ". .'~ _' . ' . I' ;-'-' ~ .--...,. ..' ,,-f'-,..".'.' :"-''';',,,:,",,'..-i..,,~., ',,".'..,.., WHEREFORE, Defendant rcspectfully rcqucsts that the previously cxccutcd Stipulation conccming thc tcrms and conditions of custody of Allon L. Brcwbakcr, a minor child, bc incorporatcd into an Ordcr of Court. Rcspcetfully submittcd, Datcd: /'/1,'/1 'i' , CO';J;u~)CO~N)~ I'.C./\/ BY:! /-b~!J.~ l\ v:___ ~isa0aric Coync, Esqlyrc 3901 Market Strcct bmpHill,I'A 170]1-4227 I'a. S. Ct. No. 53788 AI/orney fi)1' Defi!1ldal/l 2 Y oungbloodStipulalion2 SANDRA YOUNGBLOOD, PI ai nti ff THE COURT OF COivlMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 98.7304 CIVIL DOUGLAS BREWBAKER, Defendant CIVIL ACTION - LA \V ;-,.~ C.' ,: :~:~ STII'ULA TION ;::1 ( :~. -, The parties hereto, represented by counsel, request. stipulate and agree to the entry of the following Order with regard to the custody of their minor child, Afton L. Brewbaker born April 12, 1995, now 3 y, years: 1. The parties shall share legal custody of the said minor child. 2. Primary physical custody of the said minor child shall be in the mother, Sandra Youngblood subject to periods of temporary physical custody in the father, Douglas Brewbaker, set forth hereinafter: a. Commencing February 15, 1999, to March 28. 1999, Father shall have custody of child every week Monday thwugh Friday 8:30 :l.Ill. to 4:30 p.m. Father to pick up and return child to baby.sittcr. b. COlllmencing the \\eek of March :29. 1999. until the child reaches school age. the father. Dougbs 131Twbakn. shall haw custody ewry week from Tuesday at 1 :00 1'.111. until Thursday :1t 7:00 1'.111. with th~ r'lthcr pick in:; the child up fro111 daycaf<' and fl.'turning th~ chilJ h1 l11L' J1h11hcr' s rl'~id('nLL': . i.J I( l1J?: I" /' /l v '. c. The father, Douglas Brewbaker. shall have two designated weeks of vacation custody which weeks shall be designated at least thirty days in advancc by defendant to Plaintiff and which weeks shall have at least three weeks in bet\\'el'n them; c. The father shall have the l'allowing periods of holiday visitation: Easter Sunday from 1 :00 p.m. to 7:00 p.m.: Memorial Day from I :00 p.m. to 7:00 p.m.: Father's Day from 1 :00 p.m. to 7:00 p.m.; Thanksgiving Day from 9:00 a.m. to 3:00 p.m.; Christmas Eve, December 24, from noon to 7:00 p.m. For each holiday visitation the father shall pick the aforesaid minor child up from the mother and return the child to the mother's residence. Having read the foregoing, and intending to have the same entered as an Order of .j1.. Court, the parties hereto so stipulate with their attorneys as witnesses this I O-day of /1)fI1:.( Ji F cbrua~', 1999. Witness: ~o~";" ~ ilt 1i),t- Bruce D.'r-oremarv Esquire ,. "'~" ",""'j7""'~' ......., ;..,r~. ',' " t ,,', ."., ,'~"~' _' '. ,.' '.... ", ' .~.:.', L ',:' ,'. ,~ .:, .', ',~, " . ,"'., . ',; '., - y \1\l11ghllllltlSt ipulali\11l:.! SANlmA YOUNGBLOOD, Plaintiff TilE COURT 01' Cmv1i'vl0N PLEAS Cl IMBERLANIl COUNTY, PENNSYLV ANIA v. NO. 9R.7J04 CIVIL DOUGLAS mmWBAKER, Defendant CIVIL ACTION - l.A W STlI'llLATlON The parties hereto, represented by counseL request, stipulate and agree to the entry of the following Order with regard to the cuslody of their minOl' child, Alion L. Brewbaker born April 12. 1995, now J 'I, years: I. The parlies shall share legal custody of the said minor child. 2. Primary physical custody of the said minor child shall be in the mOlher, Sandra Youngblood subject to periods of temporary physical custody in the lather, Douglas Brewbaker, set forth hercinaticr: a. Commencing February 15, 11)99. to March 2R. 1999, Fathcr shall have custody of ehild every week Monday throug.h Friday RJ() a.m. 10 4:J() p.m. Father to pick up and return child to baby-sitter. b. Commencing the week of !\larch 21). 1999. untiltbe child reaches scbool age. the I~ltber, Douglas Brewbaker. shall ha\'\.~ custody every week lj'01l1 Tuesday at 1 :O() p.m. ul11il Thursday at 7:00 p.m. with the I:lther picking the child up from daycare and returning the child to tbe n1<lther's residence: . . .. '.. "~ " . ,",' '.' . " . . . " ,,-' c. Thc 1;lthcr, Douglas Brcwbakcr. shall havc two dcsignatcd wccks of vacation custody which wccks shall bc dcsignatcd at least thirty days in advancc by dclcndant to I'laintilTand which wccks shall havc at Icast thrcc wccks in bctwccn thcm: c. Thc nahcr shall havc thc 1()lIowing pcriods of holiday visitation: Eastcr Sunday Irom 1:00 p.l11. to 7:00 p.m.: tvlcmorial Day Ihllll 1:00 p.l11. to 7:00 p.m.: Fathcr's Day from 1:00 p,111. to 7:00 p.m.: Thanksgiving Day li'OI11'J:OO a.l11. to 3:00 p.m..; Christmas Eve, Dcccmbcr 24. from noon to 7:00 p.m. For cach holiday visitation thc I;lthcr shall pick thc aforesaid minor child up li'om thc mothcr and rcturn the child to thc mothcr's rcsidcnce. lIaving read thc fiJrcgoing, and intcnding to havc thc samc cntcred as an Ordcr of . ;;. Court. thc partics hcreto so stipulatc with thcir attorncys as witnesscs this /0 -day of ,4t(tl~: 1999. Witncss: ~ (~ I' I lh (,I-,,~ ~.V.._ /.i' Maric Coync. :squirc' \./ / ~ ':/ ~squire " '. ' . , '.'. . '~. ." " '.~ . ' " " ,,' '. . !. . " :- . :',i I ;" " . '. .' " l ,'" "' ,'. .'. " ,'" , . . ',. . . . " . ,,' I ~: ,:.' "'" \ " " :.' - :": '. :'''".' .' 1. ',:,.... _ , _ , : " .....~. .' . --\. -".' SANDRA YOUNGBLOOD, Plaintiff THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. DOUGLAS BREWBAKER, Defendant CIVIL ACTION - LAW COMPLAINT FOR CUSTODY AND NOW, comes Plaintiff, SANDRA L. YOUNGBLOOD, and by her attorneys, NICHOLAS & FOREMAN, respectfully represent as follows: 1. Plaintiff, SANDRA YOUNGBLOOD, is an adult individual sui IUrlS. residing at 117 York Street, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant, DOUGLAS BREWBAKER, is an adult individual sui juris. residing at 629 West King's Highway, Audubon, New Jersey 08106. 3. Plaintiff and the minor child who is the subject of instant complaint have been bonafide residents of this Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff requests an award of joint legal custody and primary physical custody of the minor child, AFTON L. BREWBAKER, born April 12, 1995, the minor child of the parties in the instant action. 5. The child is presently in the physical custody of the Plaintiff. 6. The father of the child is DOUGLAS BREWBAKER, the Defendant. 7. The mother of the child is SANDRA YOUNGBLOOD, the Plaintiff. 8. During the 3Y2 years since the child was born, from April '12, 1995, to the present, the child has resided with the Plaintiff, her rnother, SANDRA YOUNGBLOOD, at 117 York Street, Enola. Cumberland County, Pennsylvania 17025. The only other person residing at the said residence with the parties is TIFFANY YOUNGBLOOD, the daughter of Plaintiff SANDRA YOUNGBLOOD and sister of the minor child, AFTON L. BREWBAKER . _., ~.t ...-.- -.. ---.. '" ~'" . '&'J;' . , ~~...!...."...".. .,".,. ,.,tt. . .! '. . . , . ~ . ~. '. ~ : " . '" ',! \ . -' " i ,'"" _' . 9. Plaintiff has not participated as a party in any prior litigation concerning the custody of the said children in this Court or in any other Court and, to the best of her knowledge, there has never been any prior custody litigation. 10. No person(s) not a party to this transaction are known to the Plaintiff to have had physical custody or claims to custody or visitation with regard to the said minor child. 11. The best interest and permanent welfare of the said child, AFTON L. BREWBAKER, will be served by granting joint legal custody to the parties hereto and primary physical custody of the said minor child to the Plaintiff, SANDRA YOUNGBLOOD, because of numerous benefits to the child which would result from this ongoing stable relationship and the care and love that would be provided to her. 12. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order granting joint legal custody of the said minor child, AFTON L. BREWBAKER, to Plaintiff and Defendant with primary physical custody of the said child, AFTON L. BREWBAKER, to Plaintiff, SANDRA YOUNGBLOOD, subject to periods of agreed upon temporary physical custody in the Defendant, DOUGLAS BREWBAKER. Respectfully submitted, NICHOLAS & FOREMAN By Bruce D. Foreman, Es'quire 4409 North Front Street Harrisburg, Pennsylvania 17110 (717) 236-9391 Attorney I.D. #21193 Attorneys for Plaintiff . ,~ , : : "_ . ':' ", ,., .' , . . .. .' " " .' : ' . . \' , ~ : ~ , ' . , .. J,' , VERI FICA TION I verify that the statements made in foregoing document are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: IcPj~ <5'-- ,. ,'. \ '.' . I ,- f, l, ., , ", '. ',: '!".' ...' ,.'... ,: " \', ~. . '. . . ;', " , . . ~ t" , " f" "", .e N. .t€). \ " ':~ " " I:,: ,~ " ' ctJ" ....'.~. , ,,",.' " "1., :?"'i.-' , J >, . - ~ ' '~ '~ ,', "~:"':jQ. ,,', ::,' ,.,'. '.", '~, " " .. . . , .' ,',,; ,. " '\ 't., , " '..~~. " '. ::> ,- " : ...:I' ' , ~ ':1 '. ...:1>1 ll<en " z z z ",'- Or.:! >I. " ~ll< t:l 0 0 . r< u~ en '\',. ::;l 1'Ll'~ U OP p:; .0 , r<U 0 , fg '. I'Ll ,'l,. o! r< "U . Z H [;3; .~ "'. 'J" '.' ., 'r< ' ~ '''' . ",,' " j'" . " .,,.. i::JB 0 z u , ,.'. ,"p' ,I; ",' "", ., ~ . ~. '1" , . NICHOLAS & FOREMAI"J, P.C. . '. '.' "'.f,",,",:, DOUGLAS I), BHEWBAKEH, Plaintiff, IN TilE COlIRT OF COMMON PLEAS CliMBEHLANJ> COliNTY, PENNSYLVANIA No. 911-7304 CIVIL TERM \'S. SANDRA L, YOUNGBLOOD, Dcfcndant, : IN ClJSTOJ>Y PRAECIPE TO THE PROTHONOTARY: Kindly docket nfreeord Plaintiff's proof of attendance issued eonceming the seminar for scparating parents presented by Inner Works of Harrisburg, Pennsylvania which attendance was directed per the Order of Court, dated January] 2, 200 I. Respectfully submitted, COYNE & COYNE, P.c. Date: 3,' 3["0 ( BY: - I isa Marie Coyne. Esquire (/ 390 I Market Street Camp Hill, PA 17011.4227 (717) 737-0464 Pa. Supreme Cl. No. 53788 Al/orl1cY.fi)/' Plail1l![r . , .'." ',' ":...--" ',:H ",' :. .'., ..'. :',," ....,'.. ,r" . ", ,"" ....:~:., ,,:. '~,,~:'\ ..'.' :-, :," . . .. " :' ~ . " , " \ " .,", :' ."., " . J ',' ,"".,'."': ' .' ~ '). . . " (J.,.lnII~I~>HI~!)L'i~B VI.CE I, Lisa Maric Coync. Esquirc. hcrcby ccrtify that truc copics ofthc Praccipc has bccn scrvcd upon thc bclow-rcfcrcnccd individual by scnding thc samc by lirst cIass mail, postagc prcpaid, addrcsscd as follows: Brucc D. Forcman, Esquirc Nicholas & Forcman, P.C. 4409 N0l1h Front Strect lIan"isburg, PAl 71 10- 1709 Datcd: 3 <3,;1 -01 aric Coync, Esqui c M arkct S (rcct CampHill,PA 17011-4227 (717) 737-0464 Pa. S. Cl. No. 53788 Attorncy for Plaintiff . ",' : "., " ' _' '1, ' .' , .' " , ' ': ", .' ' . ' . . .: " : . >', ',.' ::~' ".:'. \ . ,w " .", " ---- , '-'. ..",...,.....' -. -_...._'.-~,.>-... ,---.'.'." "."', "