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HomeMy WebLinkAbout00-05389JEREMY C. JUMPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SARAH J. PREDIX 00-5389 CIVIL ACTION LAW DEFENDANT . IN CUSTODY ORDER OF COURT AND NOW, Monday, March 19, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Tuesday, April 10, 2001 at 11:30 a.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 permanent order. FOR THE COURT, By: /s/ Melissa P Green:y. Esq.e Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (71.7)249-3166 ' r YGi'= •zx ume uaa ev nua? :?eaxuzxoa??wuYs I OF 'rll 01 joi If ' Z0 HM i" 35 CUiv:PCNNSlLVNNIA 17Y 11 JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-5389 SARAH J. PREDIX, CIVIL ACTION - LAW Defendant CUSTODY ORDER OF COURT AND NOW, this dayof , 2001, upon consideration of thewithin Complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the day of , 2001, 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. Either party may bring the child who is the subject of this custody action to the Conference, but the child/children's attendance is not mandatory. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: 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 Cumberland County Courthouse Fourth Floor Carlisle, PA 17013 (717) 240-6200 cc: Robert L. O'Brien, Esq. Paul J. Esposito, Esq. JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL ACTION - LAW CUSTODY PETITION TO MODIFY ORDER OF CUSTODY AND NOW, Defendant, by and through her counsel, Goldberg, Katzman & Shipman, P.C. and Paul J. Esposito, Esquire, files this Petition to Modify Order of Custody, and in support thereof, avers the following: 1. Petitioner, Sarah J. Predix, is the Defendant in the above-captioned custody action. 2. Respondent, Jeremy C. Jumper, is the Plaintiff in the above-captioned custody action. 3. The parties hereto are the parents of one minor child, Raelyn G. Predix, born January 2, 1999. 4. On December 15, 2000, the Honorable Kevin A. Hess entered an Order of Court, which granted the parties shared legal custody and granted Petitioner primary physical custody subject to Respondent's rights of partial custody which were delineated in the Order. 5. Paragraph 1 of Judge Hess' Order of December 15, 2000, provides as follows: 1. Legal Custody: 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 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. 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. 6. In December, 2000, Petitioner was advised by Raelyn's dentist that a full mouth restoration procedure was necessary as a result of decay to two teeth. Petitioner, despite her unceasing efforts, was, until very recently, unable to schedule the procedure as a result of Respondent's refusal to provide his authorization. The dentist would not proceed without both parents' authorization in light of the Order providing for shared legal custody. 7. In response to Respondent's insistence, an independent second opinion was obtained regarding the necessity of the dental work. 8. A second opinion was rendered by Dr. William R. Currie, D.D.S., whose conclusions were entirely consistent with Dr. Nancy L. Rajchel, D.D.S., who had made the initial diagnosis. 9. Notwithstanding these two opinions, Respondent unreasonably persisted in his refusal to authorize the proposed procedure, thereby jeopardizing Raelyn's health and well being. 10. According to her dentist, time is of the essence to perform this procedure in that Raelyn's teeth will continue to deteriorate and the damage may become irreparable if the procedure is not performed in the very near future. 11. Respondent has finally indicated that he will consent to the dental procedure. 12. Respondent's inexplicable position in this instance portends negatively for similar future occurrences pertaining to major decisions regarding Raelyn's health, education and welfare. Consequently, Petitioner believes that, in order to serve Raelyn's best interests, it is necessary that she be granted exclusive authority to make all major non- emergency decisions affecting Raelyn's general well-being, including, but not limited to, all decisions regarding her health and education. WHEREFORE, Petitioner respectfully requests that this Honorable Court enter an order modifying paragraph 1 of this Court's Order of December 15, 2000, to the extent that Petitioner is granted primary legal custody of Raelyn. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. By Law PAULA. Eye OSITO, ESQUIRE 320 Market Street Post Office Box 1268 Harrisburg, PA 17108-1268 Supreme Court ID #25454 Attorneys for Defendant/Petitioner VERIFICATION I verify that the statements contained in the foregoing PETITION TO MODIFY ORDER OF CUSTODY are true and correct to the best of my knowledge, information and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 3 "7- of %6z '(/7" SARAH J. PREDIX I/ I/ ? y' f J =•Cl C wv ?' SI JEREMY C. JUMPER, vs. SARAH J. PREDIX, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL ACTION - LAW : CUSTODY ORDER OF COURT AND NOW, this 15 a. day of December, 2000, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody: 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 Pa. C. S. § 5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. 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. 2. Physical Custody: Mother shall have primary physical custody of the minor Child subject to Father's rights of partial custody which shall be arranged as follows: A. Father shall have custody on Thursdays from 7:15 a.m. until 2:30 p.m. He shall pick up the Child at 7:15 a.m. from Mother's residence and return her at 2:30 p.m. In addition, to commence on December 12,.2000, Father shall have custody on alternating Tuesdays from 7:15 a.m. until 2:30 p.m. These Tuesdays shall coincide with the week after Mother's custodial weekend. B. Weekends: On alternating Saturdays to commence December 16, 2000, Father shall have physical custody from Saturday at 9:30 a.m. until Sunday at 5:30 p.m. This shall continue for the weekends of December 16, 2000, and December 30, 2000. To commence January 13, 2001, Father's periods of weekend custody shall continue on an alternating weekend basis but shall be extended to the period of time from Saturday morning at 9:30 a.m. until Monday afternoon at 2:30 p.m. Plaintiff Defendant w y r, C ai,„13 f ig'„ i ; uOUNT EENNSYLU,'' N A .. !`!MfiF?R¢FFIY `=9 1 ifi''9NMFRn.4v MI No. 00-5389 3. Holidays: A. Christmas: In even-numbered years, Father shall have custody on Christmas Eve and Mother shall have custody on Christmas Day. In odd- numbered years, Father shall have custody on Christmas Day and Mother shall have custody on Christmas Eve. Unless otherwise agreed, the custodial period for these holidays is from 9:30 a.m. until 7:00 p.m. B. Easter: The parties shall share time on the Easter holiday weekend as they shall mutually agree. C. Labor Day/Memorial Day: Mother shall have each Labor Day; Father shall have each Memorial Day. Unless otherwise agreed, the custodial period for these holidays shall be from 9:30 a.m. until 7:00 p.m. D. Thanksgiving Day: Father shall have partial custody on Thanksgiving Day each year from 9:30 a.m. until 3:00 p.m. E. The Child's Birthday: The Child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. F. Mother's Day/Father's Day: Mother's Day shall be with Mother; Father's Day shall be with Father. The period of partial custody for this holiday shall be from 9:30 a.m. until 7:00 p.m., unless otherwise agreed by the parties. 4. In the event that one of the parties is unable to be present for a period of two hours or more during their scheduled time of custody, that party shall contact the other parent prior to engaging the services of a third party to provide childcare for the minor Child. 5. Summer Vacation: Each party shall be entitled to a period of up to seven (7) continuous days of summer vacation subject to a (30) thirty-day notice to the other parent. In the event of the parties scheduling overlapping vacation times, the party first providing written notice of their plans shall have the privilege of first choice of vacation time. 6. In the event that either party would take the minor Child out of state, the traveling party will provide the other parent with notice of the location and telephone number where they are able to be reached during that time. The parties shall permit reasonable telephone contact between the minor Child and the non-custodial parent. 7. Illness: In the event that the Child is ill and the parties determine it is not in the Child's best interest for the Child to travel or participate in custodial time with one parent due to that illness, the party losing custodial time shall be provided compensatory time for those No. 00-5389 periods of illness. BY THE COURT, Kevin :Hess, Dist: Robert L. O'Brien, Esquire, 17 W. South Street, Carlisle, PA 17013 Paul J. Esposito, Esquire, 320 Market Street, Harrisburg, PA 17101 L or 1? ,aD I dl- 9 ? JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5389 SARAH J. PREDIX, CIVIL ACTION - LAW Defendant CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Raelyn G. Predix January 2, 1999 Mother 2. A Conciliation Conference was held on December 4, 2000, with the following individuals in attendance: the Father, Jeremy C. Jumper, and his counsel, Robert L. O'Brien, Esquire; the Mother, Sarah J. Predix. Mr. Esposito did not attend. 3. An agreement was reached by the parties as reflected in the Order as attached. Date Melissa Peel Greevy, Esquire Custody Conciliator E P 14 20 JEREMY C. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-5389 SARAH J. PREDIX, : CIVIL ACTION - LAW Defendant : CUSTODY ORDER OF COURT AND NOW, this ISy day of 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. Legal Custom. The parties, Jeremy C. Jumper and Sarah J. Predix, shall have shared legal custody of their minor Child, Raelyn G. Predix, born January 2, 1999. 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 records and information. 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. 2. Physical Physical Custody. Mother shall have primary physical custody of the minor Child subject to Father's rights to partial custody which shall be arranged as follows: A. Father shall have custody on Thursdays from 8:00 AM until 2:00 PM. He shall pick up the Child at 7:15 AM from Mother's residence and return her at 2:30 PM. In addition, Father shall have weekend physical custody on alternating weekends to begin Saturday, September 9. On alternating Saturdays Father shall have physical custody from 9:30 AM until 7:00 PM and on Sundays from 9:30 AM until 5:30 PM. In the event that Father is required to work weekend overtime in such a way that it would interfere with his periods of partial custody, Father agrees that he will provide notice to Mother of this change in circumstances by Wednesday preceding the upcoming weekend. In the event that such overtime is mandatory, it is expected that Mother shall cooperate with Father in providing compensatory time for Father to enjoy partial custody so that he may continue to enjoy frequent and continuing contact with the Child. B. Holidays: Christmas: For the year 2000, Christmas custody shall be as follows: December 24th from 9:30 AM until 7:00 PM the Child shall be with the Father. December 25th from 9:30 AM until 7:00 PM the Child j -j1 pD-()c- lu[ 00 Sf° 15 Pty` 2: 40 OPEN{ SYLVANINIA?? shall be with the Mother. Thanksgiving: Father shall have partial custody on Thanksgiving Day each year from 9:30 AM until 3:00 PM. Child's Birthday: The Child's birthday shall be enjoyed with whichever parent would ordinarily have physical custody on her birthday. C. Mother's Day/Father's Day: Mother's Day shall be with Mother; Father's Day shall be with Father. Period of partial custody shall be from 9:30 AM until 7:00 PM. The parties shall both attend a program at the Carlisle YMCA on September 28, 2000, from 9:30 AM until 11:00 AM with regard to toddler care. The Father shall be included and invited to attend all pediatric appointments with the child's pediatrician, Dr. Ryder and shall be instructed on the proper procedure for administering injections when necessary to respond to the Child's peanut allergy. 4. The parties shall return to Custody Conciliation at 11:15 AM on December 4, 2000, at the office of Melissa Peel Greevy, Esquire, for an additional Conciliation Conference. BY THE COURT, /? 4L . J. Dist: Robert L. O'Brien, Esquire, O'Brien, Baric and Scherer, 7 W. South Street, Carlisle, PA 17013 Paul J. Esposito, Esquire, Goldberg, Katzman and S 'man, 320 Market Street, Harrisburg, PA 1710 4 to o 9?5 1 . SEP 1 4 2801, JEREMY C. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5389 SARAH J. PREDIX, CIVIL ACTION - LAW Defendant CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Raelyn G. Predix January 2, 1999 Mother 2. A Conciliation Conference was held on September 6, 2000 with the following individuals in attendance: The Father, Jeremy C. Jumper, and his counsel, Robert L. O'Brien, Esquire; the Mother, Sarah J. Predix, and her counsel, Paul J. Esposito, Esquire. 3. An agreement was reached by the parties as reflected in the Order as attached. Z, 0-tr6 Date McMe il Greevy, Esquire Custody Conciliator MAY 012091 0 JEREMY C. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-5389 SARAH J. PREDIX, : CIVIL ACTION - LAW Defendant . CUSTODY ORDER OF COURT Kevin A. Hess, J. rti AND NOW, this 2'°' day of ,A, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: The prior Order of December 15, 2000, shall remain in full force and effect with the following modifications. 1. In the event that one of the parties is unable to be present for a period of four hours or more during their scheduled time of custody, that party shall contact the other parent prior to engaging the services of a third party to provide care for the minor Child. 2. Pursuant to 23 Pa. C. S.§ 5305, the parties shall attend counseling to address the responsibilities and decision making arrangements involved in shared legal custody arrangements. The counseling shall additionally be focused on resolving their difficulties with communication and shared decision making with regard to the best interests of the minor Child. Services shall be provided by the staff of the Howard H. Stevens Mental Health Center, unless otherwise agreed by the parties. 3. In the event that either party finds it necessary to revisit the issue of whether they are able to continue in the shared legal custody arrangement or otherwise seek modification of this Order, a report will be provided to the Court by a counselor who has seen the parties. BY THE COURT, Kevin Hess, J. Dist: Paul J. Esposito, Esquire, PO Box 1268, Harrisburg, PA 17108-1268 Gary L. Kelley, Esquire, 132-134 Walnut Street, Harrisburg, PA 17101 o,o G P ?` C;I'dJlA9Y f1i E',,°Y-3 rt.i 8 2 CUPJ En iU COUNTY PMSYLVANIA L JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5389 SARAH J. PREDIX, CIVIL ACTION - LAW Defendant CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliation submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Raelyn Predix January 2, 1999 Mother 2. A Custody Conciliation Conference was held on April 10, 2001, with the following individuals in attendance: the Father, Jeremy C. Jumper, and his counsel, Gary Kelley, Esquire; the Mother, Sarah J. Predix, and her counsel, Paul J. Esposito, Esquire. 3. The parties were seen for their third Custody Conciliation Conference with this Conciliator upon the Mother's petition to modify the Order granting the parties shared legal custody. Mother seeks to obtain an Order seeking primary legal custody of the minor Child. needed. 4. The parties reached an agreement in the form of an Order as attached. Counsel for the parties agreed that Mother's petition shall be held in abeyance and may be revisited if -Vc Date Melissa Peel Greevy, Esquire Custody Conciliator A JEREMY C. JUMPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SARAH J. PREDLY 00-5389 CIVIL ACTION LAW DEFENDANT . IN CUSTODY ORDER OF COURT AND NOW, this 7th day of August , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeMelissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 6th day of September , 2000, at 1:00 p.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 permanent order. FOR THE COURT, By: /s/ Melissa P. Greevy Esa Custody Conciliator W The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ji n U 00 AUS e : Pik ?. 48 CUrBC-; ,ND COUVTy Pff&'K YLVQA .1 JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. : CIVIL ACTION - LAW : NO. 2000 a l CIVIL TERM SARAH J. PREDIX, Defendant IN CUSTODY ORDER OF COURT AND NOW THIS _ day of , 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the _ day of , 2000 at A.M./P.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 permanent order. BY THE COURT, BY Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 JEREMY C. JUMPER Plaintiff Vs. SARAH J. PREDIX Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-,53,'9 CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Jeremy C. Jumper, an adult individual, residing at 154 Beetem Hollow Road, Newville, PA 17241, Cumberland County, Pennsylvania. 2. Defendant is Sarah J. Predix, an adult individual, currently residing at 285 Plaza Drive, Boiling Springs, PA 17007, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child : Raelyn G. Predix, age 1, born 1/22/99. The child was born out of wedlock. The child is presently in the custody of the Mother, Sarah J. Predix. During the past five years, or since the child's birth, she has resided with the following persons at the following addresses: (a) From birth to the present with Sarah J. Predix and the maternal grandmother Catherine Predix at 285 Park Drive, Boiling Springs, PA 17007 4. The relationship of the Plaintiff to the child is that of natural father. 5. The relationship of the Defendant to child is that of natural mother. 6. The parties have not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the child in this or in any other Court. Plaintiff does 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The Father has been denied reasonable contact with his child by the Mother. 8. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. NAME ADDRESS BASIS OF CLAIM Catherine Predix 285 Park Drive child has lived with Boiling Springs, PA 17007 her grandmother WHEREFORE, Plaintiff requests your Honorable Court to: A) grant times of partial custody of the child to the Father B) grant such other relief as is just and in the best interest of the child. Date: g Z Respectfully submitted, Robert L: O'Brien, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 (717) 249-6873 '1111 Mimi -In Im I MMMJI 11 I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. C Jer MY . J per DATE: 7-a25-- 60 JEREMY C. JUMPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 00-5389 CIVIL ACTION LAW SARAH J. PREDIX DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, April 25, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, June 02, 2003 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P Greev,y, Ems Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 _ - assaea --.e?wx:eusz'¢ ?adudnaaas ? ?4[?€ na wtwe?afss.<s i, - s.xer.?l,ii earp,u'fN?txM+?'t?.?? "'°S5R' k1Y '.:? ti.. , J' is y [NAP 1? U'UMY PENNSYLVAN IA /Y oW "Q3 Jv " JttEtit (L a o? ?p? ? '? 000 "Z73 JEREMY C. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW :CUSTODY SARAH J. PREDIX, Defendant : NO. 00-5389 CIVIL TERM ORDER OF COURT AND NOW, , 2003, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at onthe day of 2003, at o'clock, _.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 permanent order. FOR THE COURT: By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 JEREMY C. JUMPER, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY SARAH J. PREDD{, Defendant NO. 00-5389 CIVIL TERM COMPLAINT TO MODIFY CUSTODY ORDER Plaintiff, Jeremy C. Jumper by his attorney, Taylor P. Andrews, Esq., respectfully represents: The jurisdictional averments in Paragraphs 2 through 6 of the original Complaint for Custody filed by Plaintiff on August 2, 2000 are incorporated herein by reference. 2. Since the time of the original Complaint the minor child, Raelyn G. Predix, date of birth, January 2, 1999 has continued to reside at 285 Plaza Drive, Boiling Springs, Pennsylvania 17007 with Defendant. Sarah J. Predix. Plaintiff, Jeremy C. Jumper, now resides at 1127 Nanroc Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 4. On December 15, 2000 the Honorable Kevin A. Hess entered an Order of Custody and Visitation granting shared legal custody to the above named parties and primary physical custody to Defendant with specified rights of partial custody for Plaintiff. (A copy of the December 15, 2000 Court Order is attached hereto as Exhibit A). 5. On May 2, 2001 the Honorable Kevin A. Hess modified the December 15, 2000 Order by adding terms pertaining to counselling, babysitfing and problems with legal custody. (A copy of the May 2, 2001 Order is attached hereto as Exhibit B). 6. The hours specified in the above referenced Court Order for Plaintiff's partial custody no longer conform with the Plaintiff's work schedule with a new employer. While Plaintiff and Defendant have been able to resolve the differences by informal agreement at times, at other rimes, the Father has been denied his partial custody rights in a manipulative fashion. 7. The child, Raelyn G. Predix, is now enrolled at the Goddard School in the Mechanicsburg area and her daycare placement is very convenient to Plaintiff's residence. 8. Plaintiff seeks additional time with custody with his daughter, Raelyn with a schedule to be consistent with both parties work schedule and the coordination with the Goddard School enrollment. 9. Plaintiff seeks shared physical custody with a schedule to be determined through Conciliation. 10. Melissa Greevy has previously served as Conciliator in this case. WHEREFORE, Plaintiff requests the Court to modify the existing Custody Order to provide for shared physical custody. Respectfully submitted, ANDREWS & JOHNSON By: TA lrnr P. Andrews, Esq. ey for Plaintiff 78 West Pomfret Street Carlisle, PA 17013 Telephone: (717) 243-0123 4- JEREMY C. JUMPER, : IN THE COURT OF COMMON PLE Plaintiff : CUMBERLAND COUNTY, PENNS' vs. : NO. 00-5389 SARAH J. PREDIX, : CIVIL ACTION - LAW Defendant : CUSTODY ORDER OF COURT AND NOW, this day of December, 2000, upon consideration of attached Custody Conciliation Summary Report, it is hereby ordered and directed a 1. Leal Custody: Each parent shall have an equal right, to be exercised joie the other parent, to make all major non-emergency decisions affecting the Child's g being including, but not limited to, all decisions regarding her health, education and Pursuant to the terms of Pa. C. S. § 5309, each parent shall be entitled to all record information pertaining to the Child including, but not limited to, medical, dental, religi school records, the residence address of the Child and of the other parent. To the e parent has possession of any such records or information, that parent shall be requi share the same, or copies thereof, with the other parent within such reasonable time make the records and information of reasonable use to the other parent. 2. Physical Custody: Mother shall have primary physical custody of the minc subject to Father's rights of partial custody which shall be arranged as follows: A. Father shall have custody on Thursdays from 7:15 a.m. until 2:3 shall pick up the Child at 7:15 a.m. from Mother's residence and at 2:30 p.m. In addition, to commence on December 12, 2000, 1 shall have custody on alternating Tuesdays from 7:15 a.m. until These Tuesdays shall coincide with the week after Mother's cus weekend. B. Weekends: On alternating Saturdays to commence December 1 Father shall have physical custody from Saturday at 9:30 a.m. ui Sunday at 5:30 p.m. This shall continue for the weekends of De 16, 2000, and December 30, 2000. To commence January 13,, Father's periods of weekend custody shall continue on an altern; weekend basis but shall be extended to the period of time from morning at 9:30 a.m. until Monday afternoon at 2:30 p.m. No. 00-5389 3. Halidavs: A. Christmas: In even-numbered years, Father shall have custody on Christmas Eve and Mother shall have custody on Christmas Day. In odd- numbered years, Father shall have custody on Christmas Day and Mother shall have custody on Christmas Eve. Unless otherwise agreed, the custodial period for these holidays is from 9:30 a.m. until 7:00 p.m. B. Easter: The parties shall share time on the Easter holiday weekend as they shall mutually agree. C. Labor Day/Memorial Day: Mother shall have each Labor Day; Father shall have each Memorial Day. Unless otherwise agreed, the custodial period for these holidays shall be from 9:30 a.m. until 7:00 p.m. D. Thanksgiving Day: Father shall have partial custody on Thanksgiving Day each year from 9:30 a.m. until 3:00 p.m. E. The Child's Birthday: The Child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. F. Mother's Day/Father's Day: Mother's Day shall be with Mother; Father's Day shall be with Father. The period of partial custody for this holiday shall be from 9:30 a.m. until 7:00 p.m., unless otherwise agreed by the parties. 4. In the event that one of the parties is unable to be present for a period of two hours or more during their scheduled time of custody, that party shall contact the other parent prior to engaging the services of a third party to provide childcare for the minor Child. 5. Summer Vacation: Each party shall be entitled to a period of up to seven (7) continuous days of summer vacation subject to a (30) thirty-day notice to the other parent. In the event of the parties scheduling overlapping vacation times, the party first providing written notice of their plans shall have the privilege of first choice of vacation time. 6. In the event that either party would take the minor Child out of state, the traveling party will provide the other parent with notice of the location and telephone number where they are able to be reached during that time. The parties shall permit reasonable telephone contact between the minor Child and the non-custodial parent. 7. Illness: In the event that the Child is ill and the parties determine it is not in the Child's best interest for the Child to travel or participate in custodial time with one parent due to that illness, the party losing custodial time shall be provided compensatory time for those No. 00-5389 periods of illness. BY THE COURT, '<' 'q d' Kevin :Hess, .i. Dist: Robert L. O'Brien, Esquire, 17 W. South Street, Carlisle, PA 17013 Paul J. Esposito, Esquire, 320 Market Street, Harrisburg, PA 17101 I? R s -Mw -. JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00-5389 SARAH J. PREDIX, CIVIL ACTION - LAW Defendant CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAM DATE OF BIRTH CURRENTLY IN CUSTODY OF Raelyn G. Predix January 2, 1999 Mother 2. A Conciliation Conference was held on December 4, 2000, with the following individuals in attendance: the Father, Jeremy C. Jumper, and his counsel, Robert L. O'Brien, Esquire; the Mother, Sarah J. Predix. Mr. Esposito did not attend. 3. An agreement was reached by the parties as reflected in the Order as attached. Date Melissa Peel Greevy, Esquire Custody Conciliator a MAY 012001 JEREMY C. JUMPER, VS. SARAH J. PREDIX, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 : CIVIL ACTION - LAW Defendant : CUSTODY ORDER OF COURT Kevin A. Hess, J. rti AND NOW, this 2'1 dayof,A, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: The prior Order of December 15, 2000, shall remain in full force and effect with the following modifications. 1. In the event that one of the parties is unable to be present for a period of four hours or more during their scheduled time of custody, that party shall contact the other parent prior to engaging the services of a third party to provide care for the minor Child. 2. Pursuant to 23 Pa. C. S.§ 5305, the parties shall attend counseling to address the responsibilities and decision making arrangements involved in shared legal custody arrangements. The counseling shall additionally be focused on resolving their difficulties with communication and shared decision making with regard to the best interests of the minor Child. Services shall be provided by the staff of the Howard H. Stevens Mental Health Center, unless otherwise agreed by the parties. 3. In the event that either party finds it necessary to revisit the issue of whether they are able to continue in the shared legal custody arrangement or otherwise seek modification of this Order, a report will be provided to the Court by a counselor who has seen the parties. BY THE COURT, Kevin Ao iHess, J. Dist: Paul J. Esposito, Esquire, PO Box 1268, Harrisburg, PA 17108-1268 Gary L. Kelley, Esquire, 132-134 Walnut Street, Harrisburg, PA 17101 3 0?.0 JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00-5389 SARAH J. PREDIX, CIVIL ACTION - LAW Defendant CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliation submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Raelyn Predix January 2, 1999 Mother 2. A Custody Conciliation Conference was held on April 10, 2001, with the following individuals in attendance: the Father, Jeremy C. Jumper, and his counsel, Gary Kelley, Esquire; the Mother, Sarah J. Predix, and her counsel, Paul J. Esposito, Esquire. 3. The parties were seen for their third Custody Conciliation Conference with this Conciliator upon the Mother's petition to modify the Order granting the parties shared legal custody. Mother seeks to obtain an Order seeking primary legal custody of the minor Child. 4. The parties reached an agreement in the form of an Order as attached. Counsel for the parties agreed that Mother's petition shall be held in abeyance and may be revisited if needed. ?Ila-7la Date Melissa Peel Greevy, Esquire Custody Conciliator COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. DATE: a d 03 " C. Je C. per, P aintiff JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY NO. 00-5389 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that on this date, !q Z3 2003, I mailed a copy of Complaint to the following person at the following address by U.S. Mail delivered to: Paul J. Esposito, Esquire Counsel for Defendant 320 East Market Street Harrisburg, PA 17101 I verify that the statements made in the foregoing Certificate of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. ANDREWS & JOHNSON By: Ta P. Andrews, Esq. Apdrneys for Plaintiff 8 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 ? ? ?? o ? ? ? ct JUN 0 9 grin JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 00-5389 CIVIL TERM V. CIVIL ACTION - LAW SARAH J. PREDIX, IN CUSTODY Defendant HESS, J. --- ORDER OF COURT AND NOW, this /7 day of June, 2003, upon consideration of the Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parents, Jeremy C. Jumper and Sarah J. Predix, shall have shared legal custody of the minor child, Raelyn G. Predix, born January 2, 1999. 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 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. 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. 2. Physical Custody. Mother shall have primary physical custody. Father shall have rights of partial custody which shall be arranged as follows: A. Effective June 12, 2003, on alternate weekends, from Thursday after work or school until the child is returned to school on Monday morning. B. Effective June 19, 2003, on alternate Thursdays from after work until 8:00 p.m. 3. Holida s. A. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 23 at 7:00 p.m. until December 24 at 7:00 p.m. Segment B shall be from December 24 at 7:00 p.m, until December 25 at 7:00 p.m. In even numbered years, Father m?§ ? u -^aaar?wm+?ar?wn, ? bms?nuN3 ed?d?Y? d ,' 1 i:1r-tJ(' 1C OF , icli IRY 03 AIN 12 PM 2: 27 GtiPu?? ;L=,hU CUL?JTY I?ENi iSYLVANIA NO. 00-5389 CIVIL TERM shall have Segment A and Mother shall have Segment B. In odd numbered years, Mother shall have Segment A and Father shall have Segment B. B. Easter. Easter shall be divided into two segments, Segment A and Segment B. Segment A shall be from Good Friday at 7:00 p.m. until Easter Saturday until 7:00 p.m. Segment B shall be from Easter Saturday at 7:00 p.m. until Easter Evening at 7:00 p.m. In even numbered years, Father shall have Segment B and Mother shall have Segment A. In odd numbered years, Father shall have Segment A and Mother shall have Segment B. C. Labor Day and Memorial Da v. Mother shall have each Labor Day; Father shall have each Memorial Day. Unless otherwise agreed, the custodial period for these holidays shall be from 9:30 a.m. until 7:00 p.m. D. Thanksgiving. Father shall have partial custody on Thanksgiving Day each year from 9:30 a.m. until 3:00 p.m. E. Child's Birthday. The child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. F. Mother's Day and Father's Day. Mother's Day shall be with Mother; Father's Day shall be with Father. The period of partial custody for this holiday shall be from 9:30 a.m. until 7:00 p.m., unless otherwise agreed by the parties. 4. Summer Vacation. Each party shall be entitled to a period of nine uninterrupted days of custody for summer vacation, subject to a thirty day notice to the other parent. The custodial period shall commence with the Friday of the traveling parent's custodial weekend. In the event that the parties schedule overlapping vacation times, the party first providing written notice of their plans shall have the privilege of first choice of vacation time. The non-traveling parent may have a three to four hour partial custodial period the night before the traveling parent's departure for vacation. 5. It shall be permissible for the parties to use an alternate caregiver for the child. However, if an alternate caregiver is used for a period of eight hours or more, the other parent is to be notified of the name, address, phone and location of the alternate caregiver. 6. In the event that either party would take the minor child out of state, the traveling party will provide the other parent with notice of the location and telephone number where they are able to be reached during that time period. NO. 00-5389 CIVIL TERM 7. The parties shall permit reasonable telephone contact between the minor child and the non-custodial parent. 8. Illness. In the event that the child is ill and the parties determined it is not in the child's best interest for the child to travel or participate in custodial time with one parent due to that illness, the party losing custodial time shall be provided compensatory time for this period of illness. 9. Notwithstanding the standard custodial schedule decreased herein, the parties have agreed to exchange some of the routine custodial periods provided herein in the following fashion: A. Mother shall have custody for the period of June 12, 2003 through June 14, 2003 at 9:00 a.m. Mother shall have custody from 9:00 a.m. through 9:00 p.m. on June 28, 2003. B. Father shall have custody for the period following work on June 19, 2003 through June 21, 2003 at 9:00 p.m. BY THE COURT: .9/ evin A. Hess, J. Dist: a or P. Andrews, Esquire, 78 West Pomfret Street, Carlisle, PA 17013 aul J. Esposito, Esquire, PO Box 1268, Harrisburg, PA 17108-1268 VA R1? ob-ia-o3 JEREMY C. JUMPER, V. SARAH J. PREDIX, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Raelyn G. Predix January 2, 1999 Mother 2. The parties' fourth Custody Conciliation Conference was held on June 2, 2003. Present for the conference were: the Father, Jeremy C. Jumper, and his counsel, Taylor P. Andrews; the Mother, Sarah J. Predix and her counsel, Paul J. Esposito, Esquire. 3. The parties reached an agreement in the form of an Order as attached. 6/6 A3- L Date Melissa Peel Greevy, Esquire Custody Conciliator :214291 Michael A. Hynum, Esquire Supreme Court ID #85692 151 Reno Ave., Suite 202 New Cumberland, PA 17070 (717) 774-1357 Attorney for Defendant JEREMY C. JUMPER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA V. : NO. 00-5389 CIVIL TERM SARAH J. PREDIX, : CIVIL ACTION - LAW Defendant : IN CUSTODY CERTIFICATE OF SERVICE On this 23`d day of September 23, 2005, 1 certify that a copy of the Petition to Modify Order of Custody and Order of Court was served upon the following Plaintiff by placing the same in the United States mail, first class, postage prepaid, addressed as follows: Jeremy C. Jumper 984 West Old York Road Carlisle, PA 7013 ictoria Y. Ch Michael A. Hy 151 Reno Ave Ibers, Assistant to m, Esquire e, Suite 202 New Cumberland, PA 17070 (717) 774-1357 Attorney for Defendant ?? p ;'- c? jy _.. "Q V (.-'l.. ?`Q ??(' ? } ? 1?? ly:- ? / T F.-? q { 1 t ?? ? ? ?? _ a ?yyyy ????? JEREMY C. JUMPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 00-5389 CIVIL ACTION LAW SARAH J. PREDIX IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, September 22, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at MDJ Manlove's,1901 State St., Camp Hill, PA 17011 on Thursday, October 20, 2005 at 9:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P. Greets Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 -8••'"•..'"`.>.`-ressnara.rr,?az+aaaazxs+s.i.7tu ?:syr,a.;. vvi?c-?-.,?.zraLCas:.??zE?tt?€lauaauuwaww:?a.lm?;o-z>nwn?ava®e .: "-.....`.? ? ...^'' FILED-OFPCE OF THE PRM-UNOTARY 2000 SEP 22 PH 3: 22 CU M3., UNITY ..1 EIINII? v'v,YYdNI 9aa or ?a, A 4 44 * 9 as os G -1:2 RECEIVED SEP 16 2065 f" Michael A. Hynum, Esquire Supreme Court ID #85692 151 Reno Ave., Suite 202 New Cumberland, PA 17070 (717) 774-1357 Attorney for Defendant JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-5389 CIVIL TERM SARAH J. PREDIX, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER AND NOW, , 2005, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of 2005, at m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Michael A. Hynum, Esquire Supreme Court ID #85692 151 Reno Ave., Suite 202 New Cumberland, PA 17070 (717) 774-1357 Attorney for Defendant JEREMY C. JUMPER, Plaintiff vi. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PETITION TO MODIFY ORDER OF CUSTODY AND NOW, Defendant, by and through her counsel, Michael A. Hynum, Esquire, files a Petition to Modify Order of Custody, and in support thereof, avers the following: 1. Plaintiff is Jeremy C. Jumper, who currently resides at 984 West Old York Road, Cumberland County, Pennsylvania 17013. 2. Defendant is Sarah J. Predix, who currently resides at 445 State Street, Enola, Cumberland County, Pennsylvania 17025. 3. The parties hereto are the parents of the following minor child, who currently resides at 445 State Street, Enola, Cumberland County, Pennsylvania 17025: Raelyn G. Predix, born January 2, 1999, age 6 years 4. On June 12, 2003, this Honorable Court entered an Order of Court granting the parties shared legal custody of their child, primary physical custody to Defendant and partial physical custody to the Plaintiff. A true and correct copy of this Order is marked Exhibit "A", attached hereto and made a part hereof. 5. The best interests and permanent welfare of the parties' child will be served by a modification of the Court's Order for the following reasons: (a) At the time of entry of the Order, Raelyn was too young to attend school. She is now 6 years of age and in first grade. The 8:00 p.m. return time on Thursday evenings interferes with the bedtime schedule set up by Defendant to serve the best interests of Raelyn during the school year. (b) On weekends when Plaintiff is exercising partial physical custody of Raelyn, he is to deliver her to school on Monday mornings. However, Plaintiff must report to work at 7:00 a.m. on Monday mornings and it would therefore be in Raelyn's best interests to be returned to Defendant on Sunday evening. WHEREFORE, Defendant respectfully requests that this Honorable Court modify its Order as follows: (1) change visitation to Friday for the week that Father does not have custody of Raelyn; and (2) instruct Plaintiff to return Raelyn to Defendant by 7:00 p.m. on Sunday evening in line with Raelyn's school schedule. Respectfully submitted, Michael A. Hynum, Esquir Date: gI9I( Supreme Court ID #85692 151 Reno Ave., Suite 202 New Cumberland, PA 17070 (717) 774-1357 Attorney for Defendant VERIFICATION I verify that the statements contained in the foregoing PETITION TO MODIFY CUSTODY are true and correct to the best of my knowledge, information and belief. I understand that false statements contained therein are made subjection to the penalties of 23 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: [ ? Cv ?l G?L? Sarah Predix HUY 2003 JEREMY C. JUMPER, ii-' THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 00-5389 CIVIL TERM V. SARAH J. PREDIX, Defendant HESS, J. --- ORDER OF COURT CIVIL ACTION - LAW IN CUSTODY AND NOW, this , ?L±h day of June, 2003, upon consideration of the Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parents, Jeremy C. Jumper and Sarah J. Predix, shall have shared legal custody of the minor child, Raelyn G. Predix, born January 2, 1999. 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 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. 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. 2. Physical Custody. Mother shall have primary physical custody. Father shall have rights of partial custody which shall be 2rranged as follows: A. Effective June 12, 2003, on alternate weekends, from Thursday after work or school until the child is returned to school on Monday morning. B. Effective June 19, 2003, on alternate Thursdays from after work until 8:00 p.m. 3. Holidays. A. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 23 at 7:00 p.m. until December 24 at 7:00 p.m. Segment B shall be from December 24 at 7:00 p.m. until December 25 at 7:00 p.m. In even numbered years, Father I NO. 00-5389 CIVIL TERM shall have Segment A and Mother shall have Segment B. In odd numbered years, Mother shall have Segment A and Father shall have Segment B. B. Easter. Easter shall be divided into two segments, Segment A and Segment B. Segment A shall be from Good Friday at 7:00 p.m. until Easter Saturday until 7:00 p.m. Segment B shall be from Easter Saturday at 7:00 p.m. until Easter Evening at 7:00 p.m. In even numbered years, Father shall have Segment B and Mother shall have Segment A. In odd numbered years, Father shall have Segment A and Mother shall have Segment B. C. Labor Day and Memorial Day. Mother shall have each Labor Day; Father shall have each Memorial Day. Unless otherwise agreed, the custodial period for these holidays shall be from 9:30 a.m. until 7:00 p.m. D. Thanksgiving. Father shall have partial custody on Thanksgiving Day each year from 9:30 a.m. until 3:00 p.m. E. Child's Birthday. The child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. F. Mother's Day and Father's Day. Mother's Day shall be with Mother; Father's Day shall be with Father. The period of partial custody for this holiday shall be from 9:30 a.m. until 7:00 p.m., unless otherwise agreed by the parties. 4. Summer Vacation. Each party shall be entitled to a period of nine uninterrupted days of custody for summer vacation, subject to a thirty day notice to the other parent. The custodial period shall commence with the Friday of the traveling parent's custodial weekend. In the event that the parties schedule overlapping vacation times, the party first providing written notice of their plans shall have the privilege of first choice of vacation time. The non-traveling parent may have a three to four hour partial custodial period the night before the traveling parent's departure for vacation. 5. It shall be permissible for the parties to use an alternate caregiver for the child. However, if an alternate caregiver is used for a period of eight hours or more, the other parent is to be notified of the name, address, phone and location of the alternate caregiver. 6. In the event that either party would take the minor child out of state, the traveling party will provide the other parent with notice of the location and telephone number where they are able to be reached during that time period. NO. 00-5389 CIVIL TERM 7. The parties shall permit reasonable telephone contact between the minor child and the non-custodial parent. 8. Illness. In the event that the child is ill and the parties determined it is not in the child's best interest for the child to travel or participate in custodial time with one parent due to that illness, the party losing custodial time shall be provided compensatory time for this period of illness. 9. Notwithstanding the standard custodial schedule decreased herein, the parties have agreed to exchange some of the routine custodial periods provided herein in the following fashion: A. Mother shall have custody for the period of June 12, 2003 through June 14, 2003 at 9:00 a.m, Mother shall have custody from 9:00 a.m. through 9:00 p.m. on June 28, 2003. - B. Father shall have custody for the period following work on June 19, 2003 through June 21, 2003 at 9:00-p:m. BY THE,000RT: A. Hess, Dist: Taylor P. Andrews, Esquire, 78 West Pomfret Street, Carlisle, PA 17013 Paul J. Esposito, Esquire, PO Box 1268, Harrisburg, PA 17108-1268 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of id Court at Carlisle, Pa. Tq)ss .......1a,)Ai of..Zkwt°,., ?.Q. D (Y W C) ' -L -p m ` F J J in L' F -< 5 ?4L JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant HESS, J. --- nrT 'A 100 5,, IN THE COURT OF MON PLEAS C CUMBERLAND CO NO. 00-5389 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this z %J day of November, 2005, upon consideration of the Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parents, Jeremy C. Jumper and Sarah J. Predix, shall have shared legal custody of the minor child, Raelyn G. Predix, born January 2, 1999. 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 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. 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. 2. Physical Custody. Mother shall have primary physical custody. Father shall have rights of partial custody which shall be arranged as follows: A. Effective October 28, 2005, on alternating weekends, from Thursday after work or school until Sunday at 7:00 p.m. Father will oversee that the homework and agenda book are completed during his weekend periods of custody. Father will also ensure that the child is bathed Sunday evening prior to her return to Mother's custody. B. Effective November 3, 2005, on alternate Thursdays from after work until 7:30 p.m. 3. Holidays. The following holiday schedule shall supersede the regular schedule: FILED-OFFICE OF THE PROTHONOTARY 2005 NOV -3 AM 11: 42 cullkcs c;r uivT i Pc+' ! 19YLVAN A NO. 5389 CIVIL TERM A. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 23`d at 3:30 p.m. until December 24th at 6:00 p.m. and December 28th at Noon until January 1St at 3:00.m. Segment B shall be from December 24th at 6:00 p.m. until December 28t at Noon. In odd numbered years, Mother shall have Segment A and Father shall have Segment B. In even numbered years, Father shall have Segment A and Mother shall have Segment B. B. Easter. Easter shall be divided into two segments, Segment A and Segment B. Segment A shall be from Good Friday at 7:00 p.m. until Easter Saturday until 7:00 p.m. Segment B shall be from Easter Saturday at 7:00 p.m. until Easter Evening at 7:00 p.m. Ih even numbered years, Father shall have Segment B and Mother shall have Segment A. In odd numbered years, Father shall have Segment A and Mother shall have Segment B. C. Labor Day and Memorial Day. Mother shall have each Labor Day; Father shall have each Memorial Day. Unless otherwise agreed, the custodial period for these holidays shall be from 9:30 a.m. until 7:00 p.m. D. Thanksgiving. Father shall have custody on Thanksgiving Day each year from 2:00 p.m. until 8:00 p.m. and Mother shall have custody from 9:30 a.m. until 2:00 p.m. In the event that Thanksgiving is adjacent to Father's custodial weekend, his Thanksgiving period of custody shall run continuously from Thanksgiving Day at 2:00 p.m. until Sunday at 7:30 p.m. E. Child's Birthday. The child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. F. Mother's Day and Father's Day. Mother's Day shall be with Mother; Father's Day shall be with Father. The period of partial custody for this holiday shall be from 9:30 a.m. until 7:00 p.m., unless otherwise agreed by the parties. 4. Summer Vacation. Each parent is entitled to one (1) week of vacation during each of the months of June, July and August subject to not less than thirty (30) days notice to the other parent. The custodial period shall commence with the Friday of the traveling parent's custodial weekend. In the event that the parties schedule overlapping vacation times, the party first providing written notice of their plans shall have the privilege of first choice of vacation time. The non-traveling parent may have a three to four hour partial NO. 5389 CIVIL TERM custodial period the night before the traveling parent's departure for vacation. The custodial weeks shall not be scheduled consecutively nor shall they conflict with the child's camp or dance recital. Neither parent shall schedule vacation on the first week that school is dismissed without agreement of the other parent. The parties shall return to the ordinary schedule the first full week before the commencement of school each year. 5. It shall be permissible for the parties to use an alternate caregiver for the child. However, if an alternate caregiver is used for a period of eight hours or more, the other parent is to be notified of the name, address, phone and location of the alternate caregiver. 6. In the event that either party would take the minor child out of state, the traveling party will provide the other parent with notice of the location and telephone number where they are able to be reached during that time period. 7. The parties shall permit reasonable telephone contact between the minor child and the non-custodial parent. 8. Illness. In the event that the child is ill and the parties determined it is not in the child's best interest for the child to travel or participate in custodial time with one parent due to that illness, the party losing custodial time shall be provided compensatory time for this period of illness. 9. In the event that the parties agree to be flexible with the schedule in a way that decreases Father's custodial time, such as by trading weekends, Father shall be entitled to compensatory time within twenty (20) days. 10. Mother shall have custody for a period of three (3) hours prior to the Spring dance recital. 11. The parties shall consult with each other regarding activities in which the child may want to participate which would impact the other parent's custodial time. The child shall not be enrolled in additional extracurricular activities or sports which will impact the other parent's time without that parent's agreement. BY THE COURT: A. Ha Dist: Jrayfor P. Andrews, Esquire, 78 West Pomfret _: ichael A. Hynum, Esquire, 151 Reno Avenut , J. beat, Carlisle, PA 17013 Suite 202, New Cumberland, PA 17070 JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant RECF-1 7VE OF.T 3 2005 BY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Raelyn G. Predix January 2, 1999 Mother 2. Mother filed a Petition to Modify Order of Custody on September 12; 2005. A Custody Conciliation Conference was held on October 20, 2005 with the following individuals in attendance: the Father, Jeremy C. Jumper, and his counsel, Taylor P. Andrews, Esquire; the Mother, Sarah J. Predix, and her new counsel, Michael A. Hyman, Esquire. 3. The parties reached numerous agreements which are memorialized in the form of an Order as attached. However, the parties reached no agreement with regard to Father's request that his girlfriend, Amanda, be allowed to pickup the child at the beginning of his custodial periods. He reserves the right for a brief hearing on this. issue which, if requested, shall be scheduled without return to Conciliation if aid request is made within sixty (60) days of the date of the Order. 10 D to Melis- Peel Greevy, Esquire Custody Conciliator :261799 DEC 0 7 2005 JEREMY C. JUMPER, IN THE COURT OF CUMBERLAND COU Plaintiff NO. 00-5389 CIVIL TERM V. SARAH J. PREDIX, Defendant HESS, J. --- ORDER OF COURT CIVIL ACTION - LAW IN CUSTODY AND NOW, this /Z" day of 'Dtu.;.t v , 2005, upon consideration of the Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parents; Jeremy C. Jumper and Sarah J. Predix, shall have shared legal custody of the minor child, Raelyn G. Predix, born January 2, 1999. 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 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. 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. 2. Physical Custody. Mother shall have primary physical custody. Father shall have rights of partial custody which shall be arranged as follows: A. Effective October 28, 2005, on alternating weekends, from Friday after work or school until Sunday at 7:00 p.m. Father will oversee that the homework and agenda book are completed during his weekend periods of custody. Father will also ensure that the child is bathed Sunday evening prior to her return to Mother's custody. B. Effective November 3, 2005, on alternate Thursdays from after work until 7:30 p.m. 3. Holidays. The following holiday schedule shall supersede the regular schedule: u.1 A .+ too., GiV ? ; s xv F;, w` NO. 00-5389 CIVIL TERM A. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 23`d at 3:30 p.m. until December 24th at 6:00 p.m. and December 28th at Noon until January Vt at 3:00 p.m. Segment B shall be from December 24th at 6:00 p.m. until December 28th at Noon. In odd numbered years, Mother shall have Segment A and Father shall have Segment B. In even numbered years, Father shall have Segment A and Mother shall have Segment B. B. Easter. Easter shall be divided into two segments, Segment A and Segment B. Segment A shall be from Good Friday at 7:00 p.m. until Easter Saturday until 7:00 p.m. Segment B shall be from Easter Saturday at 7:00 p.m. until Easter Evening at 7:00 p.m. In even numbered years, Father shall have Segment B and Mother shall have Segment A. In odd numbered years, Father shall have Segment A and Mother shall have Segment B. C. Labor Day and Memorial Day. Mother shall have each Labor Day; Father shall have each Memorial Day. Unless otherwise agreed, the custodial period for these holidays shall be from 9:30 a.m. until 7:00 p.m. D. Thanksgiving. Father shall have custody on Thanksgiving Day each year from 2:00 p.m. until 8:00 p.m. and Mother shall have custody from 9:30 a.m. until 2:00 p.m. In the event that Thankssgiving is adjacent to Father's custodial weekend, his Thanksgiving period of custody shall run continuously from Thanksgiving Day at 2:00 p.m. until Sunday at 7:30 p.m. E. Child's Birthday. The child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. F. Mother's Day and Father's Day. Mother's Day shall be with Mother; Father's Day shall be with Father. The period of partial custody for this holiday shall be from 9:30 a.m. until 7:00 p.m., unless otherwise agreed by the parties. 4. Summer Vacation. Each parent is entitled to one (1) week of vacation during each of the months of June, July and August subject to not less than thirty (30) days notice to the other parent. The custodial period shall commence with the Friday of the traveling parent's custodial weekend. In the event that the parties schedule overlapping vacation times, the party first providing written notice of their plans shall have the privilege of first choice of vacation time. The non-traveling parent may have a three to four hour partial v ?w N0.00-5389 CIVIL TERM custodial period the night before the traveling parent's departure for vacation. The custodial weeks shall not be scheduled consecutively nor shall they conflict with the child's dance recital. Neither parent shall schedule vacation on the first week that school is dismissed without agreement of the other parent. The parties shall return to the ordinary schedule the, first full week before the commencement of school each year. 5. It shall be permissible for the parties to use an alternate caregiver for the child. However, if an alternate caregiver is used for a period of eight hours or more, the other parent is to be notified of the name, address, phone and location of the alternate caregiver. 6. In the event that either party would take the minor child out of state, the traveling party will provide the other parent with notice of the location and telephone number where they are able to be reached during that time period. 7. The parties shall permit reasonable telephone contact between the minor child and the non-custodial parent. 8. Illness. In the event that the child is ill and the parties determined it is not in the child's best interest for the child to travel or participate in custodial time with one parent due to that illness, the party losing custodial time shall be provided compensatory time for this period of illness. 9. In the event that the parties agree to be flexible with the schedule in a way that decreases Father's custodial time, such as by trading weekends, Father shall be entitled. to compensatory time within twenty (20) days. 10. Mother shall have custody for a period of three (3) hours prior to the Spring dance recital. 11. The parties shall consult with each other regarding activities in which the child may want to participate which would impact the other parent's custodial time. The child shall not be enrolled in additional extracurricular activities or sports which will impact the other parent's time without that parent's agreement. NO. 00-5389 CIVIL TERM 12. Transportation. The parent receiving custody of the child shall provide transportation incident to weekend custodial exchanges. Otherwise, Father shall provide transportation for weekday periods of custody. BY THE COURT: A. Hess, Dist: Taylor P. Andrews, Esquire, 78 West Pomfret Street/arlisle, PA 17013 Michael A. Hynum, Esquire, 151 Reno Avenue, Suite 202, New Cumberland, PA 1707 svv-?-?? .A? JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant °; 7 DEC 0 7 2005 LE17Y: IN THE COURT OF COMMON CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Raelyn G. Predix January 2, 1999 Mother 2. Subsequent to the October 20, 2005 Conciliation Conference counsel contacted the Conciliator regarding perceived discrepancies in the wording of the Order issued on November 2, 2005. Counsel concurred that a new Order be issued with regard to the changes sought by Mother's counsel with the exception of the exchange time on Thanksgiving Day. The Conciliator notes indicate that the parties had discussed exchange times of both 2:00 p.m. and 3:00 p.m. and that they finally settled on the 2:00 p.m. exchange time. Accordingly, Paragraph 3D shall remains unchanged pending mutual agreement of the parties. 3. The Order attached has been modified to provide for a change in the commencement of Father's weekend period of custody in Paragraph 2A from Thursday to Friday; Paragraph 4 has been modified to remove reference to not having the custodial week be in conflict with the child's camp; and a transportation s been included. Date Melissa Peel Greevy, Esquire Custody Conciliator :263688 JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-5389 CIVIL TERM SARAH J. PREDIX, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 24th day of April, 2006, the Family Law Clinic of the Penn State Dickinson School of Law is hereby appointed to represent the child in these matters. Edward E. Guido, J. /race E. D'Alo, Esquire For Sarah J. Predix V(3'a"-ry L. Kelley, Esquire For Jeremy C. Jumper Lucy Johnston-Walsh, Esquire Dickinson Family Law Clinic For the Child Sheriff Court Administrator srs ?o?P IE _ _ E_J... _F- ,: G_ _ JEREMY C. PREDIX, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-5389 SARAH J. PREDIX, Defendant IN CUSTODY ORDER OF COURT AND NOW THISL day of #Z, 2006, it is hereby ordered that upon agreement of the parties that: 1) The Temporary Protection From Abuse Order, Docket No. 06-1927, dated April 4, 2006, is hereby vacated. 2) The Protection From Abuse action is hereby consolidated into the custody action, Docket No. 00-5389. 3) Paragraph two of the Custody Order dated December 12, 2005, is hereby temporarily modified to include the following terms: a. Mother shall have primary physical custody. b. Mother and Father shall participate in therapeutic counseling together. c. The Father shall have therapeutic visitation with the child until such time that the therapist shall determine it appropriate for the child to have unsupervised visitation with the child. 4) Either party may petition the Court to me _'- pS P cc: .,?ace D'Alo, Esq. Counsel for Defendant teary Kelly, Esq. v Counsel for Plaintiff Lucy Johnston-Walsh, Esq. Guardian Ad Litem for Child Edward E. Guido, J. T THE NnTA, v 2CQ E,tf 30 AiN !0= v Clr , UiUf?( 1?% v i TRANSMISSION VERIFICATION REPORT TIME : 05/30/2006 15:07 NAME : PROTHONOTARY C LONG FAX : 7172406573 TEL SER.# BROH3J606381 DATEJIME 05/30 15:07 FAX NO./NAME 9 24907799 24587929 2438026 DURATION 00:00:20 PAGE(S) 02 RESULT OK MODE STANDARD ECM OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013-3387 (71.7)240-6195 To: Central. Processing, Legal Services Fax## From: Cumberland County Prothonotary RE: Message: 2 No of pages (including cover sheet) .?. . .. __ e-- e4.. ..'y -4, il.- :n Mi ,Annf or mfift to which it is JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW NO. 2000-42p? CIVIL TERM SARAH J. PREDIX, f Defendant IN CUSTODY ORDER OF COURT AND NOW THIS the attached complaint, counsel appear before _ day of , 2000, upon consideration of it is hereby directed that the parties and their respective the conciliator, at on the day of 2000 at A.M./P.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 permanent order. BY THE COURT, BY Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 JEREMY C. JUMPER Plaintiff Vs. SARAH J. PREDIX Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0. 2000-53J'9 CIVIL TERM : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Jeremy C. Jumper, an adult individual, residing at 154 Beetem Hollow Road, Newville, PA 17241, Cumberland County, Pennsylvania. 2. Defendant is Sarah J. Predix, an adult individual, currently residing at 285 Plaza Drive, Boiling Springs, PA 17007, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child : Raelyn G. Predix, age 1, born 1/22/99. The child was born out of wedlock. The child is presently in the custody of the Mother, Sarah J. Predix. During the past five years, or since the child's birth, she has resided with the following persons at the following addresses: (a) From birth to the present with Sarah J. Predix and the maternal grandmother Catherine Predix at 285 Park Drive, Boiling Springs, PA 17007 4. The relationship of the Plaintiff to the child is that of natural father. 5. The relationship of the Defendant to child is that of natural mother. 6. The parties have not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the child in this or in any other Court. Plaintiff does 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The Father has been denied reasonable contact with his child by the Mother. 8. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. NAME ADDRESS BASIS OF CLAIM Catherine Predix 285 Park Drive Boiling Springs, PA 17007 child has lived with her grandmother WHEREFORE, Plaintiff requests your Honorable Court to: A) grant times of partial custody of the child to the Father B) grant such other relief as is just and in the best interest of the child. Date: g Z (TD Respectfully submitted, Robert C O' rien, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 (717) 249-6873 I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Jer my . J per DATE: / o?5-- 6o JEREMY C. JUMPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SARAH J. PREDIX • 00-5389 CIVIL .ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 7th day of August , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeMelissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 6th day of September , 2000, at 1:00 p.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 permanent order. FOR THE COURT, By: /s/ Melissa P. r e Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL :KELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 62 4(p "?5 N AiNno 9W t!"Id ij 00 ?" ;iii 6EP 14 200 JEREMY C. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-5389 SARAH J. PREDIX, : CIVIL ACTION - LAW Defendant . CUSTODY ORDER OF COURT AND NOW, this day of ) J#1 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. Legal Custody. The parties, Jeremy C. Jumper and Sarah J. Predix, shall have shared legal custody of their minor Child, Raelyn G. Predix, born January 2, 1999. 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 records and information. 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. 2. Physical Custody. Mother shall have primary physical custody of the minor Child subject to Father's rights to partial custody which shall be arranged as follows: A. Father shall have custody on Thursdays from 8:00 AM until 2:00 PM. He shall pick up the Child at 7:15 AM from Mother's residence and return her at 2:30 PM. In addition, Father shall have weekend physical custody on alternating weekends to begin Saturday, September 9. On alternating Saturdays Father shall have physical custody from 9:30 AM until 7:00 PM and on Sundays from 9:30 AM until 5:30 PM. In the event that Father is required to work weekend overtime in such a way that it would interfere with his periods of partial custody, Father agrees that he will provide notice to Mother of this change in circumstances by Wednesday preceding the upcoming weekend. In the event that such overtime is mandatory, it is expected that Mother shall cooperate with Father in providing compensatory time for Father to enjoy partial custody so that he may continue to enjoy frequent and continuing contact with the Child. B. Holidays: Christmas: For the year 2000, Christmas custody shall be as follows: December 24th from 9:30 AM until 7:00 PM the Child shall be with the Father. December 25th from 9:30 AM until 7:00 PM the Child b?Nb'AUISNi??d 1l1NnCC? ?!t 0 1 :Z Wd 9 1 d3S 00 shall be with the Mother. Thanksgiving: Father shall have partial custody on Thanksgiving Day each year from 9:30 AM until 3:00 PM. Child's Birthday: The Child's birthday shall be enjoyed with whichever parent would ordinarily have physical custody on her birthday. C. Mother's Day/Father's Day: Mother's Day shall be with Mother; Father's Day shall be with Father. Period of partial custody shall be from 9:30 AM until 7:00 PM. 3. The parties shall both attend a program at the Carlisle YMCA on September 28, 2000, from 9:30 AM until 11:00 AM with regard to toddler care. The Father shall be included and invited to attend all pediatric appointments with the child's pediatrician, Dr. Ryder and shall be instructed on the proper procedure for administering injections when necessary to respond to the Child's peanut allergy. 4. The parties shall return to Custody Conciliation at 11:15 AM on December 4, 2000, at the office of Melissa Peel Greevy, Esquire, for an additional Conciliation Conference. BY THE COURT, ` /? 4 J. Dist: Robert L. O'Brien, Esquire, O'Brien, Baric and Scherer, 7 W. South Street, Carlisle, PA 17013 Paul J. Esposito, Esquire, Goldberg, Katzman and S man, 320 Market Street, Harrisburg, PA 17101 0 q 3 R? . 11 SEP 14 zoo JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5389 SARAH J. PREDIX, CIVIL ACTION - LAW Defendant CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Raelyn G. Predix January 2, 1999 Mother 2. A Conciliation Conference was held on September 6, 2000 with the following individuals in attendance: The Father, Jeremy C. Jumper, and his counsel, Robert L. O'Brien, Esquire; the Mother, Sarah J. Predix, and her counsel, Paul J. Esposito, Esquire. 3. An agreement was reached by the parties as reflected in the Order as attached. L ovo mac. C Date Me issa eel Greevy, Esquire Custody Conciliator F COMMON PLEAS OF IN THE CC CUMBERNp ?OUNTY PENNSY • JEREMY C• JUMPER, Plaintiff •• No. ()()-5389 VS. CNIL ACTION - I-p`W J. PREDIX, CUSTODY SARAH Defendant ORDER OF COURT December, 2000, upon consideration thfollows'. day of ordered and directed AND NOW, this a Report, it is hereby ointly with attached Custody Conciliation Sum?r ry ual right, to be exercised j general well- ICu tod:Each parent shall han edecisions q affecting the Child's g on and 1 • Le all major non-emergency regarding her health, educaaill records lag dion. arent, to make ions or not limited to, all decisions dental, religious the other p 5309, each parent shall to be entitled to xtent one being including, but C S § medical, To the e to , . Pursuant to the terms to th Child including, but not limited erent shall be aired req information pertaining nce address of the Child and of the other parent. reside such s or information, that p school records, th of any record other parent within such reasonable time as parent has possession or copies thereof, with t e share the same, ation of reasonable use to the other parent of the minor child make the records and inform physical custody llows: Ph sical Custody Mother shall have primary 2. rights of partial custody which shall be arrang m He s from 7:15 a•m• until 2:30 p subject to Father s Thursday shall have custody on from Mother's residen 000dFather her on December , A Father the Child at 7 to :15 a.m. commence shall pick up 15 a.m. until 2:30 p In addition, Tuesdays from 7 at 2 m T 's custodial :30 p•m• all have custody on tide alternatingwith the week after Mother These Tuesdays shall coin weekend. 2000, Saturdays to commencet 9e30 abmr until W e_ _e: On alternating from Saturday a 8. shall have physical custody , hall continue for the weekends f 13Decem 2001er Father Sunday at 5:30 p m This s To commence e 16 2000, and December nOd, c00tody shall continue of time froem Sat Father' 's periods of weeke the period weekend basis but shall be onday afte?noon at 2:30 P.m morning at 9:30 a.m. until r EJ%ll'NSYLl//'lA No. 00-5389 3. Holidays: A. Christmas: In even-numbered years, Father shall have custody on Christmas Eve and Mother shall have custody on Christmas Day. In odd- numbered years, Father shall have custody on Christmas Day and Mother shall have custody on Christmas Eve. Unless otherwise agreed, the custodial period for these holidays is from 9:30 a.m. until 7:00 p.m. B. Easter: The parties shall share time on the Easter holiday weekend as they shall mutually agree. C. Labor Day/Memorial Day: Mother shall have each Labor Day; Father shall have each Memorial Day. Unless otherwise agreed, the custodial period for these holidays shall be from 9:30 a.m. until 7:00 p.m. D. Thanksgiving Day: Father shall have partial custody on Thanksgiving Day each year from 9:30 a.m. until 3:00 p.m. E. The Child's Birthday: The Child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. F. Mother's Day/Father's Day: Mother's Day shall be with Mother; Father's Day shall be with Father. The period of partial custody for this holiday shall be from 9:30 a.m. until 7:00 p.m., unless otherwise agreed by the parties. 4. In the event that one of the parties is unable to be present for a period of two hours or more during their scheduled time of custody, that party shall contact the other parent prior to engaging the services of a third party to provide childcare for the minor Child. 5. Summer Vacation: Each party shall be entitled to a period of up to seven (7) continuous days of summer vacation subject to a (30) thirty-day notice to the other parent. In the event of the parties scheduling overlapping vacation times, the party first providing written notice of their plans shall have the privilege of first choice of vacation time. 6. In the event that either party would take the minor Child out of state, the traveling party will provide the other parent with notice of the location and telephone number where they are able to be reached during that time. The parties shall permit reasonable telephone contact between the minor Child and the non-custodial parent. 7. Illness: In the event that the Child is ill and the parties determine it is not in the Child's best interest for the Child to travel or participate in custodial time with one parent due to that illness, the party losing custodial time shall be provided compensatory time for those No. 00-5389 periods of illness. BY THE COURT, -x, 4 d, - Kevin . Hess, J. Dist: Robert L. O'Brien, Esquire, 17 W. South Street, Carlisle, PA 17013 O Paul J. Esposito, Esquire, 320 Market Street, Harrisburg, PA 17101 I 1n. JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5389 SARAH J. PREDIX, CIVIL ACTION - LAW Defendant CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Raelyn G. Predix January 2, 1999 Mother 2. A Conciliation Conference was held on December 4, 2000, with the following individuals in attendance: the Father, Jeremy C. Jumper, and his counsel, Robert L. O'Brien, Esquire; the Mother, Sarah J. Predix. Mr. Esposito did not attend. 3. An agreement was reached by the parties as reflected in the Order as attached. Date L,:i, ou? Melissa Peel Greevy, Esquire Custody Conciliator JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL ACTION - LAW CUSTODY PETITION TO MODIFY ORDER OF CUSTODY AND NOW, Defendant, by and through her counsel, Goldberg, Katzman & Shipman, P.C. and Paul J. Esposito, Esquire, files this Petition to Modify Order of Custody, and in support thereof, avers the following: 1. Petitioner, Sarah J. Predix, is the Defendant in the above-captioned custody action. 2. Respondent, Jeremy C. Jumper, is the Plaintiff in the above-captioned custody action. 3. The parties hereto are the parents of one minor child, Raelyn G. Predix, born January 2, 1999. 4. On December 15, 2000, the Honorable Kevin A. Hess entered an Order of Court, which granted the parties shared legal custody and granted Petitioner primary physical custody subject to Respondent's rights of partial custody which were delineated in the Order. 5. Paragraph 1 of Judge Hess' Order of December 15, 2000, provides as follows: a _ t d C7 c= nj; C17 ;_' -C . r ?- 1 C-? C} C) W tv r?E-h -?C JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-5389 SARAH J. PREDIX, CIVIL ACTION - LAW Defendant CUSTODY ORDER OF COURT AND NOW, this day of , 2001, upon consideration of the within Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of , 2001, 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. Either party may bring the child who is the subject of this custody action to the Conference, but the child/children's attendance is not mandatory. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: 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 Cumberland County Courthouse Fourth Floor Carlisle, PA 17013 (717) 240-6200 cc: Robert L. O'Brien, Esq. Paul J. Esposito, Esq. Michael A. Hynum, Esquire Supreme Court ID #85692 151 Reno Ave., Suite 202 New Cumberland, PA 17070 (717) 774-1357 Attorney for Defendant JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-5389 CIVIL TERM SARAH J. PREDIX, CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE On this 23`d day of September 23, 2005, 1 certify that a copy of the Petition to Modify Order of Custody and Order of Court was served upon the following Plaintiff by placing the same in the United States mail, first class, postage prepaid, addressed as follows: Jeremy C. Jumper 984 West Old York Road Carlisle, PA 7013 ictoria Y. Ch Michael A. Hy 151 Reno Av( Ibers, Assistant to m, Esquire e, Suite 202 New Cumberland, PA 17070 (717) 774-1357 Attorney for Defendant ?,.? rv? = cry -_ cn r?? ?? m _ '? .?n? '. . ..,,: .1 G r ? (T1 ? C_ ? ? i .. 4: - e_+? ?; ? ? JEREMY C. JUMPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SARAH J. PREDIX 00-5389 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, March 19, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before _Melissa P. Greevy, Esq. the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Tuesday, April 10, 2001 at 11:30 a.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 permanent order. FOR THE COURT, By: /s/ Melissa P Greevv Es0--p Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 VINV "- ? sr! -! a 9? -.S w ? QZ '0 W 10 I`LCJ fr ?1 ` J t'`! J0 MAY 012001/ JEREMY C. JUMPER, VS. SARAH J. PREDIX, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL ACTION - LAW Defendant CUSTODY ORDER OF COURT Kevin A. Hess, J. r" AND NOW, this 2 day of Q, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: The prior Order of December 15, 2000, shall remain in full force and effect with the following modifications. 1. In the event that one of the parties is unable to be present for a period of four hours or more during their scheduled time of custody, that party shall contact the other parent prior to engaging the services of a third party to provide care for the minor Child. 2. Pursuant to 23 Pa. C. S.§ 5305, the parties shall attend counseling to address the responsibilities and decision making arrangements involved in shared legal custody arrangements. The counseling shall additionally be focused on resolving their difficulties with communication and shared decision making with regard to the best interests of the minor Child. Services shall be provided by the staff of the Howard H. Stevens Mental Health Center, unless otherwise agreed by the parties. 3. In the event that either party finds it necessary to revisit the issue of whether they are able to continue in the shared legal custody arrangement or otherwise seek modification of this Order, a report will be provided to the Court by a counselor who has seen the parties. BY THE COURT, Kevin. Hess, J. Dist: Paul J. Esposito, Esquire, PO Box 1268, Harrisburg, PA 17108-1268 - R Gary L. Kelley, Esquire, 132-134 Walnut Street, Harrisburg, PA 17101 Ol . 03 0 ? df VA-VSNN'zd I'? ll c -- AI VW 10 JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5389 SARAH J. PREDIX, CIVIL ACTION - LAW Defendant CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliation submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Raelyn Predix January 2, 1999 Mother 2. A Custody Conciliation Conference was held on April 10, 2001, with the following individuals in attendance: the Father, Jeremy C. Jumper, and his counsel, Gary Kelley, Esquire; the Mother, Sarah J. Predix, and her counsel, Paul J. Esposito, Esquire. 3. The parties were seen for their third Custody Conciliation Conference with this Conciliator upon the Mother's petition to modify the Order granting the parties shared legal custody. Mother seeks to obtain an Order seeking primary legal custody of the minor Child. 4. The parties reached an agreement in the form of an Order as attached. Counsel for the parties agreed that Mother's petition shall be held in abeyance and may be revisited if needed. ?lla?lai Date Melissa Peel Greevy, Esquire Custody Conciliator JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :CUSTODY : NO. 00-5389 CIVIL TERM COMPLAINT TO MODIFY CUSTODY ORDER Plaintiff, Jeremy C. Jumper by his attorney, Taylor P. Andrews, Esq., respectfully represents: 1. The jurisdictional averments in Paragraphs 2 through 6 of the original Complaint for Custody filed by Plaintiff on August 2, 2000 are incorporated herein by reference. 2. Since the time of the original Complaint the minor child, Raelyn G. Predix, date of birth, January 2, 1999 has continued to reside at 285 Plaza Drive, Boiling Springs, Pennsylvania 17007 with Defendant, Sarah J. Predix. 3. Plaintiff, Jeremy C. Jumper, now resides at 1127 Nanroc Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 4. On December 15, 2000 the Honorable Kevin A. Hess entered an Order of Custody and Visitation granting shared legal custody to the above named parties and primary physical custody to Defendant with specified rights of partial custody for Plaintiff. (A copy of the December 15, 2000 Court Order is attached hereto as Exhibit A). 5. On May 2, 2001 the Honorable Kevin A. Hess modified the December 15, 2000 Order by adding terms pertaining to counselling, babysitting and problems with legal custody. (A copy of the May 2, 2001 Order is attached hereto as Exhibit B). 6. The hours specified in the above referenced Court Order for Plaintiffs partial custody no longer conform with the Plaintiff's work schedule with a new employer. While Plaintiff and Defendant have been able to resolve the differences by informal agreement at times, at other times, the Father has been denied his partial custody rights in a manipulative fashion. 7. The child, Raelyn G. Predix, is now enrolled at the Goddard School in the Mechanicsburg area and her daycare placement is very convenient to Plaintiff's residence. 8. Plaintiff seeks additional time with custody with his daughter, Raelyn with a schedule to be consistent with both parties work schedule and the coordination with the Goddard School enrollment. 9. Plaintiff seeks shared physical custody with a schedule to be determined through Conciliation. 10. Melissa Greevy has previously served as Conciliator in this case. WHEREFORE, Plaintiff requests the Court to modify the existing Custody Order to provide for shared physical custody. Respectfully submitted, ANDREWS & JOHNSON By: T 1 r P. Andrews, Esq. A ey for Plaintiff 78 West Pomfret Street Carlisle, PA 17013 Telephone: (;717) 243-0123 JEREMY C. JUMPER, IN THE COURT OF COMMON PLE Plaintiff CUMBERLAND COUNTY, PENNS' vs. NO. 00-5389 SARAH J. PREDIX, CIVIL ACTION - LAW Defendant CUSTODY ORDER OF COURT AND NOW, this 15"' day of December, 2000, upon consideration of attached Custody Conciliation Summary Report, it is hereby ordered and directed a 1. Legal C? us_tody: Each parent shall have an equal right, to be exercised joie the other parent, to make all major non-emergency decisions affecting the Child's g( being including, but not limited to, all decisions regarding her health, education and Pursuant to the terms of Pa. C. S. § 5309, each parent shall be entitled to all record information pertaining to the Child including, but not limited to, medical, dental, religi school records, the residence address of the Child and of the other parent. To the E parent has possession of any such records or information, that parent shall be requi share the same, or copies thereof, with the other parent within such reasonable timE make the records and information of reasonable use to the other parent. 2. Physical Qustodv: Mother shall have primary physical custody of the minc subject to Father's rights of partial custody which shall be arranged as follows: A. Father shall have custody on Thursdays from 7:15 a.m. until 2:3 shall pick up the Child at 7:15 a.m. from Mother's residence and at 2:30 p.m. In addition, to commence on December 12, 2000, 1 shall have custody on alternating Tuesdays from 7:15 a.m. until These Tuesdays shall coincide with the week after Mother's cus weekend. B. Weekends: On alternating Saturdays to commence December 1 Father shall have physical custody from Saturday at 9:30 a.m. ui Sunday at 5:30 p.m. This shall continue for the weekends of De 16, 2000, and December 30, 2000. To commence January 13, Father's periods of weekend custody shall continue on an altern, weekend basis but shall be extended to the period of time from morning at 9:30 a.m. until Monday afternoon at 2:30 p.m. EXHIBIT TI No. 00-5389 3. Holidays: A. Christmas: In even-numbered years, Father shall have custody on Christmas Eve and Mother shall have custody on Christmas Day. In odd- numbered years, Father shall have custody on Christmas Day and Mother shall have custody on Christmas Eve. Unless otherwise agreed, the custodial period for these holidays is from 9:30 a.m. until 7:00 p.m. B. Eas er: The parties shall share time on the Easter holiday weekend as they shall mutually agree. C. Labor Day/Memorial Day: Mother shall have each Labor Day; Father shall have each Memorial Day. Unless otherwise agreed, the custodial period for these holidays shall be from 9:30 a.m. until 7:00 p.m. D. Thanksgiving Day: Father shall have partial custody on Thanksgiving Day each year from 9:30 a.m. until 3:00 p.m. E. The Child's Birthday: The Child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. F. Mother's Day/Father's Day: Mother's Day shall be with Mother; Father's Day shall be with Father. The period of partial custody for this holiday shall be from 9:30 a.m. until 7:00 p.m., unless otherwise agreed by the parties. 4. In the event that one of the parties is unable to be present for a period of two hours or more during their scheduled time of custody, that party shall contact the other parent prior to engaging the services of a third party to provide childcare for the minor Child. 5. Summer Vacation: Each party shall be entitled to a period of up to seven (7) continuous days of summer vacation subject to a (30) thirty-day notice to the other parent. In the event of the parties scheduling overlapping vacation times, the party first providing written notice of their plans shall have the privilege of first choice of vacation time. 6. In the event that either party would take the minor Child out of state, the traveling party will provide the other parent with notice of the location and telephone number where they are able to be reached during that time. The parties shall permit reasonable telephone contact between the minor Child and the non-custodial parent. 7. Illness: In the event that the Child is ill and the parties determine it is not in the Child's best interest for the Child to travel or participate in custodial time with one parent due to that illness, the party losing custodial time shall be provided compensatory time for those No. 00-5389 periods of illness. BY THE COURT, -,<, 4 d, Kevin. Hess, Dist: Robert L. O'Brien, Esquire, 17 W. South Street, Carlisle, PA 17013 Q Paul J. Esposito, Esquire, 320 Market Street, Harrisburg, PA 17101 I I /?- R g JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5389 SARAH J. PREDIX, CIVIL ACTION - LAW Defendant CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Raelyn G. Predix January 2, 1999 Mother 2. A Conciliation Conference was held on December 4, 2000, with the following individuals in attendance: the Father, Jeremy C. Jumper, and his counsel, Robert L. O'Brien, Esquire; the Mother, Sarah J. Predix. Mr. Esposito did not attend. 3. An agreement was reached by the parties as reflected in the Order as attached. Ia -/ i- zvzq,-d Date Melissa Peel Greevy, Esquire Custody Conciliator .MAY Q 12DOie JEREMY C. JUMPER, vs. SARAH J. PREDIX, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 : CIVIL ACTION - LAW Defendant : CUSTODY ORDER OF COURT Kevin A. Hess, J. rti AND NOW, this 2- day of , 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: The prior Order of December 15, 2000, shall remain in full force and effect with the following modifications. 1. In the event that one of the parties is unable to be present for a period of four hours or more during their scheduled time of custody, that party shall contact the other parent prior to engaging the services of a third party to provide care for the minor Child. 2. Pursuant to 23 Pa. C. S.§ 5305, the parties shall attend counseling to address the responsibilities and decision making arrangements involved in shared legal custody arrangements. The counseling shall additionally be focused on resolving their difficulties with communication and shared decision making with regard to the best interests of the minor Child. Services shall be provided by the staff of the Howard H. Stevens Mental Health Center, unless otherwise agreed by the parties. 3. In the event that either party finds it necessary to revisit the issue of whether they are able to continue in the shared legal custody arrangement or otherwise seek modification of this Order, a report will be provided to the Court by a counselor who has seen the parties. BY THE COURT, Kevin Dist: Paul J. Esposito, Esquire, PO Box 1268, Harrisburg, PA 17108-1268 Gary L. Kelley, Esquire, 132-134 Walnut Street, Harrisburg, PA 17101 J. 0 EXHIBIT a JEREMY C. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00-5389 SARAH J. PREDIX, : CIVIL ACTION - LAW Defendant : CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliation submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Raelyn Predix January 2, 1999 Mother 2. A Custody Conciliation Conference was held on April 10, 2001, with the following individuals in attendance: the Father, Jeremy C. Jumper, and his counsel, Gary Kelley, Esquire; the Mother, Sarah J. Predix, and her counsel, Paul J. Esposito, Esquire. 3. The parties were seen for their third Custody Conciliation Conference with this Conciliator upon the Mother's petition to modify the Order granting the parties shared legal custody. Mother seeks to obtain an Order seeking primary legal custody of the minor Child. 4. The parties reached an agreement in the form of an Order as attached. Counsel for the parties agreed that Mother's petition shall be held in abeyance and may be revisited if needed. Date - ?/, ?, ?loL Melissa Peel Greevy, Esquire Custody Conciliator COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. DATE: `7' -W03 lw,, C. Je C. per, P aintiff JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :CUSTODY : NO. 00-5389 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that on this date, `+4 IL3 , 2003, I mailed a copy of Complaint to the following person at the following address by U.S. Mail delivered to: Paul J. Esposito, Esquire Counsel for Defendant 320 East Market Street Harrisburg, PA 17101 I verify that the statements made in the foregoing Certificate of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. ANDREWS & JOHNSON By: )R22---ZZZ1 TTayt?i P. Andrews, Esq. rneys fbr Plaintiff 8 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 ?) ?-? _ ? ?- ??„) 'T. :c , (?? , ` T _ =?3 r ? l ?' ?- ,) --- ;? ; } _ .? (Ji -•-j _? w ? ?? U ? ?? o ? o ? a? JUN 0 9 9nnZ v JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 00-5389 CIVIL TERM V. SARAH J. PREDIX, Defendant HESS, J. --- ORDER OF COURT CIVIL ACTION - LAW IN CUSTODY AND NOW, this /2" day of June, 2003, upon consideration of the Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parents, Jeremy C. Jumper and Sarah J. Predix, shall have shared legal custody of the minor child, Raelyn G. Predix, born January 2, 1999. 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 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. 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. 2. Physical Custody. Mother shall have primary physical custody. Father shall have rights of partial custody which shall be arranged as follows: A. Effective June 12, 2003, on alternate weekends, from Thursday after work or school until the child is returned to school on Monday morning. B. Effective June 19, 2003, on alternate Thursdays from after work until 8:00 p.m. 3. Holidays. A. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 23 at 7:00 p.m. until December 24 at 7:00 p.m. Segment B shall be from December 24 at 7:00 p.m. until December 25 at 7:00 p.m. In even numbered years, Father H{NVAIMN?d LZ :Z I'd Z 9 U CO AdbJj NO. 00-5389 CIVIL TERM shall have Segment A and Mother shall have Segment B. In odd numbered years, Mother shall have Segment A and Father shall have Segment B. B. Easter. Easter shall be divided into two segments, Segment A and Segment B. Segment A shall be from Good Friday at 7:00 p.m. until Easter Saturday until 7:00 p.m. Segment B shall be from Easter Saturday at 7:00 p.m. until Easter Evening at 7:00 p.m. In even numbered years, Father shall have Segment B and Mother shall have Segment A. In odd numbered years, Father shall have Segment A and Mother shall have Segment B. C. Labor Day and Memorial Da v. Mother shall have each Labor Day; Father shall have each Memorial Day. Unless otherwise agreed, the custodial period for these holidays shall be from 9:30 a.m. until 7:00 p.m. D. Thanksgiving. Father shall have partial custody on Thanksgiving Day each year from 9:30 a.m. until 3:00 p.m. E. Child's Birthday. The child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. F. Mother's Day and Father's Day. Mother's Day shall be with Mother; Father's Day shall be with Father. The period of partial custody for this holiday shall be from 9:30 a.m. until 7:00 p.m., unless otherwise agreed by the parties. 4. Summer Vacation. Each party shall be entitled to a period of nine uninterrupted days of custody for summer vacation, subject to a thirty day notice to the other parent. The custodial period shall commence with the Friday of the traveling parent's custodial weekend. In the event that the parties schedule overlapping vacation times, the party first providing written notice of their plans shall have the privilege of first choice of vacation time. The non-traveling parent may have a three to four hour partial custodial period the night before the traveling parent's departure for vacation. 5. It shall be permissible for the parties to use an alternate caregiver for the child. However, if an alternate caregiver is used for a period of eight hours or more, the other parent is to be notified of the name, address, phone and location of the alternate caregiver. 6. In the event that either party would take the minor child out of state, the traveling party will provide the other parent with notice of the! location and telephone number where they are able to be reached during that time period. NO. 00-5389 CIVIL TERM 7. The parties shall permit reasonable telephone; contact between the minor child and the non-custodial parent. 8. Illness. In the event that the child is ill and the parties determined it is not in the child's best interest for the child to travel or participate in custodial time with one parent due to that illness, the party losing custodial time shall be provided compensatory time for this period of illness. 9. Notwithstanding the standard custodial schedule decreased herein, the parties have agreed to exchange some of the routine custodial periods provided herein in the following fashion: A. Mother shall have custody for the period of June 12, 2003 through June 14, 2003 at 9:00 a.m. Mother shall have custody from 9:00 a.m. through 9:00 p.m. on June 28, 2003. B. Father shall have custody for the period following work on June 19, 2003 through June 21, 2003 at 9:00 p.m. BY THE COURT: evin AAHess, J. Dist: a or P. Andrews, Esquire, 78 West Pomfret Street, Carlisle, PA 17013 aul J. Esposito, Esquire, PO Box 1268, Harrisburg, PA 17108-1268 V RY.S oL-ia-o3 JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Raelyn G. Predix January 2, 1999 Mother 2. The parties' fourth Custody Conciliation Conference was held on June 2, 2003. Present for the conference were: the Father, Jeremy C. Jumper, and his counsel, Taylor P. Andrews; the Mother, Sarah J. Predix and her counsel, Paul J. Esposito, Esquire. 3. The parties reached an agreement in the form of an Order as attached. & Date Ivielissa Pete Greevy, Esquire Custody Conciliator :214291 Michael A. Hyrum, Esquire Supreme Court ID #85692 151 Reno Ave., Suite 202 New Cumberland, PA 17070 (717) 774-1357 AttomeY for Defendant JEREMY C. JUMPER, Plaintiff vi. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PETITION TO MODIFY ORDER OF CUSTODY AND NOW, Defendant, by and through her counsel, Michael A. Hynum, Esquire, files a Petition to Modify Order of Custody, and in support thereof, avers the following: 1. Plaintiff is Jeremy C. Jumper, who currently resides at 984 West Old York Road, Cumberland County, Pennsylvania 17013. 2. Defendant is Sarah J. Predix, who currently resides at 445 State Street, Enola, Cumberland County, Pennsylvania 17025. 3. The parties hereto are the parents of the following minor child, who currently resides at 445 State Street, Enola, Cumberland County, Pennsylvania 17025: Raelyn G. Predix, born January 2, 1999, age 6 years 4. On June 12, 2003, this Honorable Court entered an Order of Court granting the parties shared legal custody of their child, primary physical custody to Defendant and partial physical custody to the Plaintiff. A true and correct copy of this Order is marked Exhibit "A", attached hereto and made a part hereof. 5. The best interests and permanent welfare of the parties' child will be served by a modification of the Court's Order for the following reasons: (a) At the time of entry of the Order, Raelyn was too young to attend school. She is now 6 years of age and in first grade. The 8:00 p.m. return time on Thursday evenings interferes with the bedtime schedule set up by Defendant to serve the best interests of Raelyn during the school year. (b) On weekends when Plaintiff is exercising partial physical custody of Raelyn, he is to deliver her to school on Monday mornings. However, Plaintiff must report to work at 7:00 a. m- on Monday mornings and it would therefore be in Raelyn's best interests to be returned to Defendant on Sunday evening. WHEREFORE, Defendant respectfully requests that this Honorable Court modify its Order as follows: (1) change visitation to Friday for the 'week that Father does not have custody of Raelyn; and (2) instruct Plaintiff to return Raelyn to Defendant by 7:00 P.M. on Sunday evening in line with Raelyn's school schedule. Respectfully submitted, Date: Qjq/&s Michael A q A. Hynum , Es ui Supreme Court ID IM5692 151 Reno Ave., Suite 202 New Cumberland, PA 17070 (717) 774-1357 Attorney for Defendant f ' " ??1DC./ " VERIFICATION I verify that the statements contained in the foregoing PETITION TO MODIFY CUSTODY are true and correct to the best of my knowledge, information and belief. I understand that false statements contained therein are made subjection to the penalties of 23 falsification to authorities. Date: -WaL- ,-a.C.s_ §4904 relating to unsworn Sarah Predix Exhibit 6 A" UXONY zn?? JEREMY C. JUMPER, ii_' THE COURT OF COMMON PLEAS OF Plaintiff CUMBERL„ND COUNTY, PENNSYLVANIA V. NO. 00-5389 CIVIL TERM SARAH J. PREDIX, CIVIL ACTION - LAW Defendant IN CUSTODY HESS, J. --- ORDER OF COURT AND NOW, this 1h Conciliation Summary Report, it is heday Of June, upon reby ordered anOd directed as followsion of the Custody 1 • Legal Custodv The parents Jeremy C. have shared legal custody the minor child, Raelyn G. Predix, born Janua parent shall have an equal right, to be exercised jointly Jwlh the other arar J Po ma shall Each 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 Pa. C. , the child including parent shall be entitled to all records and information pertaining to not residence address of the ch Id lad of the other dental, religious a school records, the - Parent possession of any such records or information, thatare re "sh the extent one e has same, or copies thereof, with the other parent within such reasonable time as to mak shall be required to share the records and information of reasonable use to the other parent. parent. mak the 2. Physical Custodv. have rights of Partial custody Mother shall have primary which physical custody. Father shall fellows: A. Effective June 12, 2003, on alternate weekends, from Thursday after work or school until the child is returned to school on Monday morning. 8:00 P.M. B. Effective June 19, 2003, on alternate Thursdays from after work until 3. Holes s. A. Christmas. Segme Christmas shall be divided into two segments, nt A and Segment B. Se P.m. until December 24 at 7:00 gment A shall be from December 23 at 7:00 7:00 p.m. until December 25 at 77:00' Segment B shall be from December 24 at P.M. In even numbered years, Father NO. 00-5389 CIVIL TERM shall have Segment A and Mot Years, Mother shall have Segme t her A and shall Fahave Segment B. In ther shall have Seg odd numbered B ment B. Easter. Easter shall be divided into two segments, Segment A and Segment B. Segment A shall be from Good Frida at Easter Saturday until 7:00 P.M. Segment B shall be fromyEasterOSaturday at 7:00 p.m. until Easter Evening at 7:00 P.M. until shall have Segment B and Mother shal -m. In even have Segment A. ?n odd numbered years, Father shall have Segment A and Mother shall have Segment years, B. Labo Day; Father shallr Da t ndhMMemoal Dgay. a Mother shall have each Labor custodial period for th have al ese holidays shall be from 9:30 a .m. otherwise agreed, the until 7:00 p.m. D. Thanksgiving_ Father shall have partial custody on Thanksgiving Day each year from 9`30 a.m. until 3:00 p.m. E. Child's Birthd? The child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. -r's D it and Mother; Father'stDay shhaII be with F this ather.Day. holiday shall be f rom 9:30 a.m. Mother's Day shall be with ay an F the until 7:00 The period of partial custody for parties. p.m., unless otherwise agreed by 4• Summer Vacation. Each Party shall be entitled to a period of nine uninterrupted days of custodY for summer vacation, subject to a thin da parent. The custodial period shall commence with the Friday of f Y notice to the other custodial weekend. In the event that the parties schedule the traveling parents vacation time. overlapping vacation times, , the The party first providing written notice of their plans shall have the privilege of first choice of e non- period the night before the avelii9 parent may have a three to four hour g parent's departure for vacation. Partial custodial child. HoweveIt fshall an be permissible lf hepar for a other parent is to be notified of the name, parties to use an alternate caregiver for the , alternate caregiver i used period of eight hours or more, the caregiver. address phone and location of the alternate 6• In the event that either traveling party will provide the other party would take the where the parent with notice of the location anddtelephonet the they are able to be reached during that time period. number NO. 00-5389 CIVIL TERM and the non-custodial parent. ?• The parties shall permit reasonable telephone contact between the minor child 8. Illness. In the event that the child is ill and the the child's best ni erest for the child to travel or participate in custodial time with one due to that illness, the parties determined it is not in this period of illness. party losing custodial time shall be provided compensatory parent ry time for 9. Notwithstanding the standard custodial schedule decreased herein, the following fashion: parties have agreed to exchange some of the routine custodial periods provided herein in the A. Mother shall have custody for the through 9:00 Period of June 12, 2003 through June 14, 2003 at 9:00 a.m. Mother shall have custody from 9:00 a.m. P.M. on June 28, 2003. B. Father shall have custody for the period following work on June 19, 2003 through June 21, 2003 at 9:00 p.m BY rcevin A. Hess Dist: Taylor P. Andrews, Esquire, 78 West Pomfret Street, Carlisle, PA Paul J. Esposito, Esquire, PO Box 1288, Harrisburg, PA 17108.1288 17013 TRUE COPY FROM RECORD In Testimony Whereof, I here unto set my hand and the seal of laid Court?a]t Carlisle, Pa, oM.n 1 'Y Cl) 70 ? 1 d 61 c I? f N JEREMY C. JUMPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SARAH J. PREDIX DEFENDANT 00-5389 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, September 22, 2005 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at MDJ Manlove's, 1901 State St., Camp Hill, PA 17011 on Thursday, October 20, 2005 at 9:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P. Greevy, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 howl prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 f _ ?'!I?0 Z? :C fld ZZ cd , loot -5a- so ?6 !+?1( %t OWd 32H.i d0 RECEIVED SEP 16 20M fA Michael A. Hynum, Esquire Supreme Court ID #85692 151 Reno Ave., Suite 202 New Cumberland, PA 17070 (717) 774-1357 Attorney for Defendant JEREMY C. JUMPER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA V. NO. 00-5389 CIVIL TERM SARAH J. PREDIX, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER AND NOW, , 2005, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of , 2005, at m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Michael A. Hyrum, Esquire Supreme Court ID #85892 151 Reno Ave., Suite 202 New Cumberland, PA 17070 (717) 774-1357 Attorney for Defendant JEREMY C. JUMPER, Plaintiff A. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PETITION TO MODIFY ORDER OF CUSTODY AND NOW, Defendant, by and through her counsel, Michael A. Hynum, Esquire, files a Petition to Modify Order of Custody, and in support thereof, avers the following: 1. Plaintiff is Jeremy C. Jumper, who currently resides at 984 West Old York Road, Cumberland County, Pennsylvania 17013. 2. Defendant is Sarah J. Predix, who currently resides at 445 State Street, Enola, Cumberland County, Pennsylvania 17025. 3. The parties hereto are the parents of the following minor child, who currently resides at 445 State Street, Enola, Cumberland County, Pennsylvania 17025: Raelyn G. Predix, born January 2, 1999, age 6 years 4. On June 12, 2003, this Honorable Court entered an Order of Court granting the parties shared legal custody of their child, primary physical custody to Defendant and partial physical custody to the Plaintiff. A true and correct copy of this Order is marked Exhibit "A", attached hereto and made a part hereof. 5. The best interests and permanent welfare of the parties' child will be served by a modification of the Court's Order for the following reasons: (a) At the time of entry of the Order, Raelyn was too young to attend school. She is now 6 years of age and in first grade. The 8:00 p.m. return time on Thursday evenings interferes with the bedtime schedule set up by Defendant to serve the best interests of Raelyn during the school year. (b) On weekends when Plaintiff is exercising partial physical custody of Raelyn, he is to deliver her to school on Monday mornings. However, Plaintiff must report to work at 7:00 a.m. on Monday mornings and it would therefore be in Raelyn's best interests to be returned to Defendant on Sunday evening. WHEREFORE, Defendant respectfully requests that this Honorable Court modify its Order as follows: (1) change visitation to Friday for the week that Father does not have custody of Raelyn; and (2) instruct Plaintiff to return Raelyn to Defendant by 7:00 p.m. on Sunday evening in line with Raelyn's school schedule. Respectfully submitted, &IL4 0 to Michael A. Hynum, Esquir Date: QI9?l Supreme Court ID #85692 151 Reno Ave., Suite 202 New Cumberland, PA 17070 (717) 774-1357 Attorney for Defendant VERIFICATION I verify that the statements contained in the foregoing PETITION TO MODIFY CUSTODY are true and correct to the best of my knowledge, information and belief. I understand that false statements contained therein are made subjection to the penalties of 23 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: q ?? ua A lu C? L Sarah Predix Exhibit "A" '! D -:? ? JUN JEREMY C. JUMPER, : THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 00-5389 CIVIL TERM V. SARAH J. PREDIX, CIVIL ACTION - LAW IN CUSTODY Defendant HESS, J. --- ORDER OF COURT AND NOW, this 1) 9,+h day of June, 2003, upon consideration of the Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parents, Jeremy C. Jumper and Sarah J. Predix, shall have shared legal custody of the minor child, Raelyn G. Predix, born January 2, 1999. 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 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. 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. 2. Physical Custody. Mother shall have primary physical custody. Father shall have rights of partial custody which shall be arranged as follows: A. Effective June 12, 2003, on alternate weekends, from Thursday after work or school until the child is returned to school on Monday morning. B. Effective June 19, 2003, on alternate Thursdays from after work until 8:00 P.M. Holidays. A. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 23 at 7:00 p.m, until December 24 at 7:00 p.m. Segment B shall be from December 24 at 7:00 p.m. until December 25 at 7:00 p.m. In even numbered years, Father NO. 00-5389 CIVIL TERM shall have Segment A and Mother shall have Segment B. In odd numbered years, Mother shall have Segment A and Father shall have Segment B. B. Easter. Easter shall be divided into two segments, Segment A and Segment B. Segment A shall be from Good Friday at 7:00 p.m. until Easter Saturday until 7:00 p.m. Segment B shall be from Easter Saturday at 7:00 p.m. until Easter Evening at 7:00 p.m. In even numbered years, Father shall have Segment B and Mother shall have Segment A. In odd numbered years, Father shall have Segment A and Mother shall have Segment B. C. Labor Day and Memorial Day. Mother shall have each Labor Day; Father shall have each Memorial Day. Unless otherwise agreed, the custodial period for these holidays shall be from 9:30 a.m. until 7:00 p.m. D. Thanksgiving. Father shall have partial custody on Thanksgiving Day each year from 9.30 a.m. until 3:00 p.m. E. Child's Birthday. The child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. F. Mother's Day and Father's Day. Mother's Day shall be with Mother; Father's Day shall be with Father. The period of partial custody for this holiday shall be from 9:30 a.m. until 7:00 p.m., unless otherwise agreed by the parties. 4. Summer Vacation. Each party shall be entitled to a period of nine uninterrupted days of custody for summer vacation, subject to a thirty day notice to the other parent. The custodial period shall commence with the Friday of the traveling parent's custodial weekend. In the event that the parties schedule overlapping vacation times, the party first providing written notice of their plans shall have the privilege of first choice of vacation time. The non-traveling parent may have a three to four hour partial custodial period the night before the traveling parent's departure for vacation. 5. It shall be permissible for the parties to use an alternate caregiver for the child. However, if an alternate caregiver is used for a period of eight hours or more, the other parent is to be notified of the name, address, phone and location of the alternate caregiver. 6. In the event that either party would take the minor child out of state, the traveling party will provide the other parent with notice of the location and telephone number where they are able to be reached during that time period. NO. 00-5389 CIVIL TERM 7. The parties shall permit reasonable telephone contact between the minor child and the non-custodial parent. 8. Illness. In the event that the child is ill and the parties determined it is not in the child's best interest for the child to travel or participate in custodial time with one parent due to that illness, the party losing custodial time shall be provided compensatory time for this period of illness. 9. Notwithstanding the standard custodial schedule decreased herein, the parties have agreed to exchange some of the routine custodial periods provided herein in the following fashion: A. Mother shall have custody for the period of June 12, 2003 through June 14, 2003 at 9:00 a.m. Mother shall have custody from 9:00 a.m. through 9:00 p.m. on June 28, 2003. B. Father shall have custody for the period following work on June 19, 2003 through June 21, 2003 at 9:00 p.m. BY A. Hess, Dist: Taylor P. Andrews, Esquire, 78 West Pomfret Street, Carlisle, PA 17013 Paul J. Esposito, Esquire, PO Box 1268, Harrisburg, PA 17108-1268 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of id Court at 1Carlisle, Pa. T s .......1... of..U..°l., Q3 P o tdry .C_) ? (Z ?, ? O ,? d G? -, f ?; «, -? ,? --, _- '.' PJ ri G.7 j ? "r) ?- ; LMON (l)ll5 JEREMY C. JUMPER, IN THE COURT OF PLEA?O CUMBERLAND CO A Plaintiff V. NO. 00-5389 CIVIL TERM CIVIL ACTION - LAW SARAH J. PREDIX, Defendant IN CUSTODY HESS, J. --- ORDER OF COURT AND NOW, this 2 =J day of November, 2005, upon consideration of the Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parents, Jeremy C. Jumper and Sarah J. Predix, shall have shared legal custody of the minor child, Raelyn G. Predix, born January 2, 1999. 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 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. 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. 2. Physical Custody. Mother shall have primary physical custody. Father shall have rights of partial custody which shall be arranged as follows: A. Effective October 28, 2005, on alternating weekends, from Thursday after work or school until Sunday at 7:00 p.m. Father will oversee that the homework and agenda book are completed during his weekend periods of custody. Father will also ensure that the child is bathed Sunday evening prior to her return to Mother's custody. B. Effective November 3, 2005, on alternate Thursdays from after work until 7:30 p.m. 3. Holidays. The following holiday schedule shall supersede the regular schedule: Z! :1 I ?'V E- P1OM NOZ 31HI 20 ?'Of?O-t131i? NO. 5389 CIVIL TERM A. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 23`d at 3:30 p.m. until December 24th at 6:00 p.m. and December 28th at Noon until January 15t at 3:00 p.m. Segment B shall be from December 24th at 6:00 p.m. until December 28th at Noon. In odd numbered years, Mother shall have Segment A and Father shall have Segment B. In even numbered years, Father shall have Segment A and Mother shall have Segment B. B. Easter. Easter shall be divided into two segments, Segment A and Segment B. Segment A shall be from Good Friday at 7:00 p.m. until Easter Saturday until 7:00 p.m. Segment B shall be from Easter Saturday at 7:00 p.m. until Easter Evening at 7:00 p.m. In even numbered years, Father shall have Segment B and Mother shall have Segment A. In odd numbered years, Father shall have Segment A and Mother shall have Segment B. C. Labor Day and Memorial Day. Mother shall have each Labor Day; Father shall have each Memorial Day. Unless otherwise agreed, the custodial period for these holidays shall be from 9:30 a.m. until 7:00 p.m. D. Thanksgiving. Father shall have custody on Thanksgiving Day each year from 2:00 p.m. until 8:00 p.m. and Mother shall have custody from 9:30 a.m. until 2:00 p.m. In the event that Thanksgiving is adjacent to Father's custodial weekend, his Thanksgiving period of custody shall run continuously from Thanksgiving Day at 2:00 p.m. until Sunday at 7:30 p.m. E. Child's Birthday. The child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. F. Mother's Day and Father's Day. Mother's Day shall be with Mother; Father's Day shall be with Father. The period of partial custody for this holiday shall be from 9:30 a.m. until 7:00 p.m., unless otherwise agreed by the parties. 4. Summer Vacation. Each parent is entitled to one (1) week of vacation during each of the months of June, July and August subject to not less than thirty (30) days notice to the other parent. The custodial period shall commence with the Friday of the traveling parent's custodial weekend. In the event that the parties schedule overlapping vacation times, the party first providing written notice of their plans shall have the privilege of first choice of vacation time. The non-traveling parent may have a three to four hour partial NO, 5389 CIVIL TERM custodial period the night before the traveling parent's departure for vacation. The custodial weeks shall not be scheduled consecutively nor shall they conflict with the child's camp or dance recital. Neither parent shall schedule vacation on the first week that school is dismissed without agreement of the other parent. The parties shall return to the ordinary schedule the first full week before the commencement of school each year. 5. It shall be permissible for the parties to use an alternate caregiver for the child. However, if an alternate caregiver is used for a period of eight hours or more, the other parent is to be notified of the name, address, phone and location of the alternate caregiver. 6. In the event that either party would take the minor child out of state, the traveling party will provide the other parent with notice of the location and telephone number where they are able to be reached during that time period. 7. The parties shall permit reasonable telephone contact between the minor child and the non-custodial parent. 8. Illness. In the event that the child is ill and the parties determined it is not in the child's best interest for the child to travel or participate in custodial time with one parent due to that illness, the party losing custodial time shall be provided compensatory time for this period of illness. 9. In the event that the parties agree to be flexible with the schedule in a way that decreases Father's custodial time, such as by trading weekends, Father shall be entitled to compensatory time within twenty (20) days. 10. Mother shall have custody for a period of three (3) hours prior to the Spring dance recital. 11. The parties shall consult with each other regarding activities in which the child may want to participate which would impact the other parent's custodial time. The child shall not be enrolled in additional extracurricular activities or sports which will impact the other parent's time without that parent's agreement. BY THE COURT: A. Hess, J. Dist: Jraylor P. Andrews, Esquire, 78 West Pomfret _4chael A. Hynum, Esquire, 151 Reno Avenut treat, Carlisle, PA 17013 Suite 202, New Cumberland, PA 17070 J 1I UT I ZUII5 JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Raelyn G. Predix January 2, 1999 Mother 2. Mother filed a Petition to Modify Order of Custody on September 12, 2005. A Custody Conciliation Conference was held on October 20, 2005 with the following individuals in attendance: the Father, Jeremy C. Jumper, and his counsel, Taylor P. Andrews, Esquire; the Mother, Sarah J. Predix, and her new counsel, Michael A. Hyman, Esquire. 3. The parties reached numerous agreements which are memorialized in the form of an Order as attached. However, the parties reached no agreement with regard to Father's request that his girlfriend, Amanda, be allowed to pickup the child at the beginning of his custodial periods. He reserves the right for a brief hearing on this issue which, if requested, shall be scheduled without return to Conciliation maid request is made within sixty (60) days of the date of the Order. IDa D to Melis'a Peel Greevy, Esquire Custody Conciliator :261799 DEC 0 7 20050 JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS Ofd CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 00-5389 CIVIL TERM V. SARAH J. PREDIX, Defendant HESS, J. --- ORDER OF COURT CIVIL ACTION - LAW IN CUSTODY AND NOW, this /Z" day of De??v 2005, upon consideration of the Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parents, Jeremy C. Jumper and Sarah J. Predix, shall have shared legal custody of the minor child, Raelyn G. Predix, born January 2, 1999. 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 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. 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. 2. Physical Custody. Mother shall have primary physical custody. Father shall have rights of partial custody which shall be arranged as follows: A. Effective October 28, 2005, on alternating weekends, from Friday after work or school until Sunday at 7:00 p.m. Father will oversee that the homework and agenda book are completed during his weekend periods of custody. Father will also ensure that the child is bathed Sunday evening prior to her return to Mother's custody. B. Effective November 3, 2005, on alternate Thursdays from after work until 7:30 p.m. 3. Holidays. The following holiday schedule shall supersede the regular schedule: ?_? _ ? •- ??'t f "._ ? ?? ?.. _.. NO. 00-5389 CIVIL TERM A. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 23`d at 3:30 p.m. until December 24`h at 6:00 p.m. and December 28th at Noon until January 15` at 3:00 p.m. Segment B shall be from December 24th at 6:00 p.m. until December 28`h at Noon. In odd numbered years, Mother shall have Segment A and Father shall have Segment B. In even numbered years, Father shall have Segment A and Mother shall have Segment B. B. Easter. Easter shall be divided into two segments, Segment A and Segment B. Segment A shall be from Good Friday at 7:00 p.m. until Easter Saturday until 7:00 p.m. Segment B shall be from Easter Saturday at 7:00 p.m. until Easter Evening at 7:00 p.m. In even numbered years, Father shall have Segment B and Mother shall have Segment A. In odd numbered years, Father shall have Segment A and Mother shall have Segment B. C. Labor Day and Memorial Day. Mother shall have each Labor Day; Father shall have each Memorial Day. Unless otherwise agreed, the custodial period for these holidays shall be from 9:30 a.m. until 7:00 p.m. D. Thanksgiving. Father shall have custody on Thanksgiving Day each year from 2:00 p.m. until 8:00 p.m. and Mother shall have custody from 9:30 a.m. until 2:00 p.m. In the event that Thanksgiving is adjacent to Father's custodial weekend, his Thanksgiving period of custody shall run continuously from Thanksgiving Day at 2:00 p.m. until Sunday at 7:30 p.m. E. Child's Birthday. The child's birthday shall be enjoyed with the parent who would ordinarily have physical custody on her birthday. F. Mother's Day and Father's Day. Mother's Day shall be with Mother; Father's Day shall be with Father. The period of partial custody for this holiday shall be from 9:30 a.m. until 7:00 p.m., unless otherwise agreed by the parties. 4. Summer Vacation. Each parent is entitled to one (1) week of vacation during each of the months of June, July and August subject to not less than thirty (30) days notice to the other parent. The custodial period shall commence with the Friday of the traveling parent's custodial weekend. In the event that the parties schedule overlapping vacation times, the party first providing written notice of their plans shall have the privilege of first choice of vacation time. The non-traveling parent may have a three to four hour partial NO. 00-5389 CIVIL TERM custodial period the night before the traveling parent's departure for vacation. The custodial weeks shall not be scheduled consecutively nor shall they conflict with the child's dance recital. Neither parent shall schedule vacation on the first week that school is dismissed without agreement of the other parent. The parties shall return to the ordinary schedule the first full week before the commencement of school each year. 5. It shall be permissible for the parties to use an alternate caregiver for the child. However, if an alternate caregiver is used for a period of eight hours or more, the other parent is to be notified of the name, address, phone and location of the alternate caregiver. 6. In the event that either party would take the minor child out of state, the traveling party will provide the other parent with notice of the location and telephone number where they are able to be reached during that time period. 7. The parties shall permit reasonable telephone contact between the minor child and the non-custodial parent. 8. Illness. In the event that the child is ill and the parties determined it is not in the child's best interest for the child to travel or participate in custodial time with one parent due to that illness, the party losing custodial time shall be provided compensatory time for this period of illness. 9. In the event that the parties agree to be flexible with the schedule in a way that decreases Father's custodial time, such as by trading weekends, Father shall be entitled to compensatory time within twenty (20) days. 10. Mother shall have custody for a period of three (3) hours prior to the Spring dance recital. 11. The parties shall consult with each other regarding activities in which the child may want to participate which would impact the other parent's custodial time. The child shall not be enrolled in additional extracurricular activities or sports which will impact the other parent's time without that parent's agreement. NO. 00-5389 CIVIL TERM 12. Transportation. The parent receiving custody of the child shall provide transportation incident to weekend custodial exchanges. Otherwise, Father shall provide transportation for weekday periods of custody. BY THE COURT: A. Hess, Dist: Taylor P. Andrews, Esquire, 78 West Pomfret Street/Carlisle, PA 17013 Michael A. Hynum, Esquire, 151 Reno Avenue, Suite 202, New Cumberland, PA 1707 /p „ , JEREMY C. JUMPER, Plaintiff 05 DEC0720?/F IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL TERM V. CIVIL ACTION - LAW SARAH J. PREDIX, Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Raelyn G. Predix January2, 1999 Mother 2. Subsequent to the October 20, 2005 Conciliation Conference counsel contacted the Conciliator regarding perceived discrepancies in the wording of the Order issued on November 2, 2005. Counsel concurred that a new Order be issued with regard to the changes sought by Mother's counsel with the exception of the exchange time on Thanksgiving Day. The Conciliator notes indicate that the parties had discussed exchange times of both 2:00 p.m. and 3:00 p.m. and that they finally settled on the 2:00 p.m. exchange time. Accordingly, Paragraph 3D shall remains unchanged pending mutual agreement of the parties. 3. The Order attached has been modified to provide for a change in the commencement of Father's weekend period of custody in Paragraph 2A from Thursday to Friday; Paragraph 4 has been modified to remove reference to not having the custodial week be in conflict with the child's camp; and a transportation s been included. Date Melissa Peel Greevy, Esquire Custody Conciliator :263688 JEREMY C. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-5389 CIVIL TERM SARAH J. PREDIX, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 24th day of April, 2006, the Family Law Clinic of the Penn State Dickinson School of Law is hereby appointed to represent the child in these matters. Edward E. Guido, J. race E. D'Alo, Esquire For Sarah J. Predix Yary L. Kelley, Esquire For Jeremy C. Jumper Lucy Johnston-Walsh, Esquire Dickinson Family Law Clinic For the Child Sheriff yw<` Court Administrator 4 4- s } srs i ?yY ,1 ? JEREMY C. PREDIX, Plaintiff V. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 : IN CUSTODY ORDER OF COURT AND NOW THIS day of ?Z' 2006, it is hereby ordered that upon agreement of the parties that: 1) The Temporary Protection From Abuse Order, Docket No. 06-1927, dated April 4, 2006, is hereby vacated. 2) The Protection From Abuse action is hereby consolidated into the custody action, Docket No. 00-5389. 3) Paragraph two of the Custody Order dated December 12, 2005, is hereby temporarily modified to include the following terms: a. Mother shall have primary physical custody. b. Mother and Father shall participate in therapeutic counseling together. c. The Father shall have therapeutic visitation with the child until such time that the therapist shall determine it appropriate for the child to have unsupervised visitation with the child. 4) Either party may petition the Court to modify BY THE 45 P cc: ,?Zace D'Alo, Esq. Counsel for Defendant j,Wary Kelly, Esq. Counsel for Plaintiff Lucy Johnston-Walsh, Esq. Guardian Ad Litem for Child Edward E. Guido, J. ,) rO ljM'r nll??? '01 3 O4 AVM goo L i?tr?lC fW rJ? 3Hi dO JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 4&44" DO- 5589 CIVIL ACTION - CUSTODY MOTION FOR STATUS CONFERENCE AND CUSTODY HEARING AND NOW, comes the Plaintiff, Jeremy C. Jumper, by and through his attorney, Gary L. Kelley, and files this Motion for a Hearing, and in support thereof, respectfully avers as follows: 1. Plaintiff is Jeremy C. Jumper. 2. Defendant is Sarah J. Predix who is represented by Grace E. D'Alo, Esquire. 3. On or about April 24, 2006, the parties appeared before the Honorable Edward E. Guido, Judge, for, inter alia, an in chambers conference. 4. As a result of this conference, this Honorable Court issued an Order which provided, inter alia, that either of the parties could request a hearing in the above matter upon appropriate request to this Honorable Court. 5. It is in the best interest of justice that this matter be scheduled for a Status Conference and, subsequently, a hearing upon the merits. WHEREFORE, based upon all of the foregoing, the Plaintiff, Jeremy C. Jumper, respectfully requests that this matter be expeditiously scheduled for a Status Conference before this Honorable Court and a hearing upon the merits thereafter. Respectfully submitted, Gary . K lley ID o. 46 O1 l? 1119 t Street, Suite B Harrisburg, PA 17101 (717) 238-1484 Attorney for Plaintiff JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5718 CIVIL ACTION - CUSTODY CERTIFICATE OF SERVICE I, GARY L. KELLEY, Esquire, attorney for PLAINTIFF in the above-captioned matter, do hereby certify that I served a true and correct copy of Motion For A Status Conference And Custody Hearing on counsel for Defendant on the 1st day of March, 2007 by First Class US Mail, postage prepaid, addressed as follows: Grace E. D'Alo, Esq. 401 East Louther Street, Suite 103 Carlisle, PA 17013 By: - )?", 'JdfPA-" GA KELLE squire I.D. 4 801 1119 North Front Street, Suite B Harrisburg, PA 17102 (717) 238-1484 Attorney for Plaintiff r ? ,.- r,',..~.l _ "Yl ?, ?-.f _ ? ? ?. tt R _ r ^? ' i;"? " _ _ { t y v'3 rMAR 0 2 2007 JEREMY C. JUMPER, Plaintiff V. SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.46-54 6b-5381 CIVIL ACTION - CUSTODY ORDER AND NOW, this day of March, 2007, upon consideration of Plaintiffs Motion For A Status Conference And Custody Hearing, it is hereby ORDERED AND DECREED that a Status Conference in the above matter is hereby scheduled for ! `' 114?. / , 2007 at •IDO AMj*in chambers before the Honorable Edward E. Guido, Judge. The purpose of this conference is discuss the necessity of a hearing in this matter and to further define and narrow the issues to be heard by the Court if a hearing is determined to be necessary. The parties are directed to be available for discussion at this conference. Distribution: Grace E. D'Alo, Esq., 401 E. Louther Street, Suite 103, Carlisle, PA 17013 Gary L. Kelley, Esq., 1119 N. Front Street, Suite B, Harrisburg, PA 17102 due in ..3- oS- 0 7 EDWARD E. GUIDO, JUDGE ;, ?`1 _ 1 JEREMY C. JUMPER, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, 00.5389 :NO. 06.5710 V. : CIVIL ACTION - CUSTODY SARAH J. PREDIX, Defendant. PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of Defendant, Sarah J. Predix. Richard C. Seneca, Esquire PA Supreme Court I.D. No. 49807 564 Old York Road Etters, PA 17319 (717) 932-0465 Attorney for Defendant, Sarah J. Predix r V CERTIFICATE OF SERVICE I hereby certify that a copy of the attached Praecipe to Enter Appearance was served upon the following persons by depositing the same in the U.S. Mail, First Class, postage prepaid, on March 12, 2007, at Etters, Pennsylvania: Gary L. Kelley, Esquire 1119 North Front Street, Suite B Harrisburg, PA 17102 Grace E. D'Alo, Esquire 401 East Louther Street, Suite 103 Carlisle, PA 17013 Richard C. Seneca, Esquire PA Supreme Court I.D. No. 49807 564 Old York Road Etters, PA 17319 f?'S c - rv ? -Tj A • • L i (? ' .?ry. ? 1 AJ ?'\ JEREMY C. JUMPER, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, NO. 06-5718 V. CIVIL ACTION - CUSTODY SARAH J. PREDIX, Defendant. MOTION FOR CONTINUANCE AND NOW, comes Defendant, Sarah J. Predix, by and through her attorney, to request a continuance of the Status Conference scheduled for March 15, 2007, and in support thereof avers as follows: 1. The undersigned counsel for Defendant entered his appearance in this action on or about March 13, 2007, and received word of the Status Conference on March 14, 2007. 2. The undersigned counsel is unable to adequately prepare for and attend the Status Conference due to previously scheduled commitments. 3. The undersigned counsel has conferred with counsel for Plaintiff, Jeremy C. Jumper who concurs in this Motion for Continuance. WHEREFORE, Defendant, Sarah J. Predix respectfully requests that this Honorable Court continue the Status Conference scheduled for March 15, 2007. Respectfully submitted, Richard C. Seneca, Esquire PA Supreme Court ID No. 49807 564 Old York Road Etters, PA 17319 (717) 932-0465 CERTIFICATE OF SERVICE I hereby certify that a copy of the attached Motion for Continuance was served upon the following person by depositing the same in the U.S. Mail, First Class, postage prepaid and by telecopier on March 15, 2007, at Etters, Pennsylvania: Gary L. Kelley, Esquire 1119 North Front Street, Suite B Harrisburg, PA 17112 Telecopier: 238-1761 Richard C. Seneca, Esquire ? ° ??i Tr %t3 ? -? - ??'- ?? ?4,?' p'"'3 ?` ? r? N ?+.3 NAR 19 2007 &d JEREMY C. JUMPER, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, 00 - 5389 NO. 'Od=5? 1 V. CIVIL ACTION - CUSTODY SARAH J. PREDIX, Defendant. ORDER AND NOW, this 15th day of March 2007, upon consideration of Defendant, Sarah J. Predix's Motion for a Continuance, the Motion is hereby Granted and the Status Conference scheduled for this date is hereby continued until further Order of the Court. BY,E COURT: Edward E. Guido, Judge Dis 'bution: ry L. Kelley, Esq., 1119 N. Front Street, Suite B, Harrisburg, PA 17102 ichard C. Seneca, Esq., 564 Old York Road, Etters, PA 17319 J flC,`? r ,, „ t?Pvco 00 -oz! Wd 13 8vw LOU AHVIQN0r'Aio8d 3RL d0 3O1 40-O 3 LAGUNA REYES MALONEY, LLP 1 1 19 NORTH FRONT STREET, HARRISBURG, PA 1 7 102 TEL.: (717) 233-5292 / FAx: (71 7) 233-5394 LRM@STANFORDALUMNI.ORG ATTORNEYS FOR PLAINTIFF/PETITIONER JEREMY JUMPER, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 00-5389 SARAH J. PREDM § CIVIL ACTION - CHILD CUSTODY Defendant § PETITION TO MODIFY CUSTODY ORDER AND NOW, comes the Plaintiff/Petitioner, Jeremy Jumper, by his attorneys, Laguna Reyes Maloney, LLP, and represents as follows: 1. Plaintiff/Petitioner, Jeremy Jumper (hereinafter "Father"), is an adult individual residing at 170 Falling Springs Rd., Landisburg, Perry County, Pennsylvania 17040. He is the natural father of Raelyn Predix, born January 2, 1999 (hereinafter "the child"). 2. Defendant/Respondent, Sarah J. Predix, (hereinafter "Mother"), is an adult individual residing at 285 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania 17007. She is the natural mother of the child. 3. On May 30, 2006, an Order of Court was issued in the above-captioned case which essentially ordered Father and Child to have therapeutic visitation until such time that the therapist shall determine it appropriate for the child to have unsupervised visitation with the Father (attached hereto as Exhibit "A"). 4. A review of the medical and counseling records in this case demonstrates that Mother has obviously hijacked the "therapeutic counseling" and effectively alienated the Child from her Father for over a year now. The Mother's course of conduct demonstrate that she will never allow the anticipated re-unification of the Child with Father unless she is forced to do so by court intervention. 5. The said Order states that either party may petition the Court to modify it. 6. Father believes that the current parenting situation is obviously harmful to the child's emotional and mental well-being and therefore, he seeks to modify the prior Order of Court. WHEREFORE, Father respectfully requests that this Honorable Court enter an Order directing the parties to attend a conciliation conference ?*d to grant whatever relief is subsequently found to be in the best 4erest kf the child. R6Qer R. Laguna, J. Esquire Supreme Court I.D. .: 75900 Attorney for Plaintiff/Petitioner LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 VERIFICATION I verify that the statements made in the foregoing Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein may subject me to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. 0 Jere J er ` JEREMY C. PREDIX, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. SARAH J. PREDIX, ' Defendant NO. 00-5389 : IN CUSTODY ORDER OF COURT` AND NOW THIS day of, 2006, it is hereby ordered that upon agreement of the parties that: 1) The Temporary Protection From Abuse Order, Docket No. 06-1927, dated April 4, 2006, is hereby vacated. 2) The Protection From Abuse action is hereby consolidated into the custody action, Docket No. 00-5389. 3) Paragraph two of the Custody Order dated December 12, 2005, is hereby temporarily modified to include the following terms: a. Mother shall have primary physical custody. b. Mother and Father shall participate in therapeutic counseling together. c. The Father shall have therapeutic visitation with the child until such time that the therapist shall determine it 'appropriate for the child to have unsupervised visitation with the 5hif. rATHj? 4) Either party may petition the Court to modify this d er. BY THE CDURT: Edward E. Guido, J. cc: Grace D'Alo, Esq. Counsel, for Defendant Gary Kelly, Esq. Counsel for Plaintiff Lucy Johnston-Walsh, Esq. Guardian Ad Litem for Child ME COPY FROMACCMD $4ocd`, I hire unto wt my aw-ft usl .of said QuM a~iie. Ps. EXHIBIT A LAGUNA REYES MALONEY, LLP 1 1 19 NORTH FRONT STREET, HARRISBURG, PA 1 7102 TEL.: (7 1 7) 233-5292 / FAX: (71 7) 233-5394 LRM@STANFORDALUMNI.ORO ATTORNEYS FOR PLAINTIFF/PETITIONER JEREMY JUMPER, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 00-5389 SARAH J. PREDIX, § CIVIL ACTION - CHILD CUSTODY Defendant § CERTIFICATE OF SERVICE I hereby certify that I served a certified copy of the Petition to Modify Custody Order filed in the above-captioned case upon Defendant's counsel, Richard C. Seneca, Esquire, and the Guardian Ad Litem for the Child, Lucy Johnston-Walsh Esquire via first-class U.S. mail, addressed as follows: Richard C. Seneca, Esquire 564 Old York Road Etters, PA 17319 Lucy Johnston-Walsh, Esquire 45 N. Pitt St. Carlisle, PA 17013 9- 19 -G7 Date er R. Laguna, ., Esquire Supreme Court I. . o.: 75900 .GP- r*.I? tU 00 JEREMY JUMPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. SARAH J. PREDIX DEFENDANT 2000-5389 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, September 25, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 25, 2007 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Giko Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 AW IfIv :Z1 W S2 83S LUZ ed57eo well ?- )? ttMl 0 jr -% JEREMY JUMPER, Plaintiff vs. SARAH J. PREDIX, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 2000-5389 CIVIL ACTION LAW IN CUSTODY PRAECIPE Please enter my appearance on behalf of Sarah J. Predix, the Defendant in the above captioned matter. Respectfully submitted, Y: -Diane M.?Dils, Esquire 1400 ortii Second Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 Date: October 10, 2007 or . .w. CERTIFICATE OF SERVICE I, Diane M. Dils, Esquire, hereby certify that a true and correct copy of the within Praecipe has been served upon the following individuals, by first class, United States mail, by depositing a copy of the same at the post office in Harrisburg, Pennsylvania, on 0?day of October, 2007, addressed as follows: Roger R. Laguna, Jr., Esquire 1119 North Front Street Harrisburg, PA 17102 Lucy Johnston-Walsh, Esquire 45 North Pitt Street Carlisle, PA 17013 Respectfully submitted, Date: 0*ber 10, 2007 Y: 451'ane M. Dils, Esquire 1400 North Second Street First Floor, Front Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 r M+? C) -" LJ? OCT 292DD7? JEREMY JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW SARAH J. PREDIX, NO. 00-5389 Defendant : IN CUSTODY COURT ORDER 1. A hearing is scheduled in Court Room No. 3 of the Cumberland County Courthouse on the ro* day of , 2007 at -.m. At this hearing, the father shall 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 the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. In the event father initiates additional therapeutic counseling/visitation with the minor child with a licensed professional that legal counsel for the parties discussed at the Custody Conciliation Conference, mother shall cooperate and insure that the minor child attends all scheduled sessions in advance of the hearing set forth above. Father shall incur the costs with respect to those sessions. Judge cc: Roger R. Laguna, Jr., Esquire i,"ane M. Dils, Esquire Catherine Fitz-Patrick, Student Attorney , \O AND NOW this ' " daY of 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 9-S : I 1 ! C 13O LOOZ -H JEREMY JUMPER, Plaintiff v SARAH J. PREDIX, Defendant Prior Judge: Edward E. Guido : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 00-5389 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Raelyn Predix, born January 2, 1999. 2. A Conciliation Conference was held on October 25, 2007, with the following individuals in attendance: The father, Jeremy Jumper, with his counsel, Roger R. Laguna, Jr., Esquire, and the mother, Sarah J. Predix, with her counsel, Diane M. Dils, Esquire, and Katherine Fitz-Patrick, Student Attorney, Dickinson School Of Law Family Law Clinic who was representing the minor child. 3. This case was before the Court in May 2006 at which time the matter was referred to a counselor for some therapeutic visitation. There is a history of the child having issues with the dad, and the Court clearly back in May 2006 wanted the parties to work towards getting the dad some kind of meaningful contact with the minor child and, hopefully, some type of unsupervised visitation in the future. However, it appears counseling did not go very well and there are a variety reports that have been issued by the counselor since May 2006. The most recent report suggests the I_ child is still reluctant to even see her father in a joint counseling session, but certainly that the child is unwilling to go visit with the father unsupervised. 4. The father is appropriately frustrated over the fact that it has been eighteen months since the last hearing and that there has been no real meaningful movement towards reconciliation with his minor daughter. The mother and counsel for the child suggest the father may not have followed up as much as he should have with respect to some individual counseling. 5. This case needs to be heard by a Judge with the Court issuing a specific Order relative to what contact, if any, the father would enjoy with the minor child. The Conciliator recommends a hearing in this case. Date: /U s-6-7 Hubert X. Gilroy, Esq re Custody Conciliator LAGUNA REYES MALONEY, LLP I I 19 NORTH FRONT STREET, HARRISBURG, PA 1 7 1 02 TEL.: (7 1 7) 233-5292 / FAX: (71 7) 233-5394 LRM@STAN FORDALU MN I .ORG ATTORNEYS FOR PLAINTIFF JEREMY JUMPER, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 00-5389 SARAH J. PREDIX, § CIVIL ACTION - CHILD CUSTODY Defendant § MOTION FOR CONTINUANCE AND NOW, comes the Plaintiff, Jeremy Jumper, by and through his attorneys, Laguna Reyes Maloney, LLP, and respectfully requests to continue the Custody Hearing in this matter and states the following: 1. A conciliation conference was held on October 25, 2007. 2. On October 31, 2007, an Order was entered scheduling a Custody Hearing for December 5, 2007 at 1:00 p.m. (attached hereto as "Exhibit A") 3. The undersigned, counsel for Plaintiff, is requesting to continue the Custody Hearing in this matter because he has a previously scheduled hearing in York County on the same day as this hearing. 4. Diane M. Dils, Esquire, counsel for the Defendant, indicated that she has no objection to the continuance of the Custody Hearing. WHEREFORE, Plaintiff respectfully requests that this Honorable Court continue the Custody Hearing in this matter to a later date. 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 LAGUNA REYES MALONEY, LLP OCT 2 9 2007 M4 JEREMY JUMPER, Plaintiff v SARAH J. PREDIX, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : NO. 00-5389 : IN CUSTODY COURT ORDER AND NOW, this _31'day of O , 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: TH , Judge 1. A hearing is scheduled in Court Room No. 3 of the Cumberland County Courthouse 1.. DD iA . e+ . on the 5-4A day of P'4?, 2007 at -.in. At this hearing, the father shall 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 the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. In the event father initiates additional therapeutic counseling/visitation with the minor child with a licensed professional that legal counsel for the parties discussed at the Custody Conciliation Conference, mother shall cooperate and insure that the minor child attends all scheduled sessions in advance of the hearing set forth above. Father shall incur the costs with respect to those sessions. cc: Roger R. Laguna, Jr., Esquire TRUE COPY r-0 ?????® an 1 ? s aoy ? :?-:? j t?xrr <?t my hand Diane M. Dils, Esquire anZ71 seai Of rlis` Pa. Katherine Fitz-Patrick, Student Attorney q j t?.i ?''?..._ ..,r.?. B..?. EXHIBIT A' ' LAGUNA REYES MALONEY, LLP I I 19 NORTH FRONT STREET, HARRISBURG, PA 1 7 1 02 TEL.: (7 1 7) 233-5292 / FAx: (71 7) 233-5394 LRM@STAN FORDALUMN I .ORO ATTORNEYS FOR PLAINTIFF JEREMY JUMPER, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 00-5389 SARAH J. PREDIX, § CIVIL ACTION - CHILD CUSTODY Defendant § CERTIFICATE OF SERVICE I hereby certify that I served a certified copy of the Motion for Continuance filed in the above-captioned case, via first-class U.S. mail, addressed as follows: Diane M. Dils, Esquire 1400 N. Second St. (First Floor Front) Harrisburg, PA 17102 Katherine Fitz- 'ck, Student Attorney ykr Children's Adv c `cy Clinic 45 N. Pitt St. Carlisle, PA 17 13.2899 &6g rA. Lague Jr. Esquire Supreme Court 13, o.: 75900 ? o d cn CC) A,' Y JEREMY C. JUMPER, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, NO. 2000-5389 V. SARAH J. PREDIX, Defendant. CIVIL ACTION - CUSTODY PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Withdraw my appearance for Defendant, Sarah J. Predix in the above- captioned action. c?? Richard C. Seneca, Esquire PA Supreme Court ID No. 49807 564 Old York Road Etters, PA 17319 (717) 932-0465 1., .. CERTIFICATE OF SERVICE I hereby certify that a copy of the attached Praecipe to Withdraw Appearance was served upon the following persons by depositing the same in the U.S. Mail, First Class, postage prepaid, on November 15, 2007, at Etters, Pennsylvania: Roger R. Laguna, Jr., Esquire Laguna Reyes Maloney, L.L.P. 1119 North Front Street Harrisburg, PA 17102-3318 Diane M. Dils, Esquire Dils & Dils 1400 North Second Street Harrisburg, PA 17102 Richard C. Seneca, Esquire PA Supreme Court I.D. No. 49807 564 Old York Road Etters, PA 17319 c? ° O rn ? , p .? rn-Tt _ .77 Olt -< NOV 1620070V JEREMY JUMPER, § Plaintiff § V. § SARAH J. PREDIX, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5389 CIVIL ACTION - CHILD CUSTODY ORDER AND NOW, this day of 2007, upon consideration of Plaintiff's Motion for Continuance, it is hereby ORDERED that the motion has been GRANTED and the Custody Hearing is now scheduled for 209at l• ?? 7 •m•, at the Cumberland County Courtho e in Court Room No. 3. Y THE COST: J. DISTRIBUTION: PA 17102 .116iane M. Dils, Esquire, 1400 N. Second St. (First Floor Front), Harrisburg, ,Roger R. Laguna, Jr., Esquire, 1119 N. Front St., Harrisburg, PA'17102 45 N. Pitt St.. Carlisle, PA 17013-2899 Catherine Fitz-Patrick, Student Attorney, Children's Advocacy 7?tlN ;r` ray y Ri ro 4 ?G G ? AON t?Q? LAGUNA REYES MALONEY, LLP 1 1 19 NORTH FRONT STREET, HARRISBURG, PA 1 7102 TEL.: (7 1 7) 233-5292 / FAX: (7 1 7) 233-5394 LRMgSTANFORDALU MN I.ORG ATTORNEYS FOR PLAINTIFF JEREMY JUMPER, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 00-5389 SARAH J. PREDIX, § CIVIL ACTION - CHILD CUSTODY Defendant § MOTION FOR CONTINUANCE AND NOW, comes the Plaintiff, Jeremy Jumper, by and through his attorneys, Laguna Reyes Maloney, LLP, and respectfully requests to continue the Custody Hearing in this matter and states the following: 1. A conciliation conference was held on October 25, 2007. 2. On October 31, 2007, an Order was entered scheduling a Custody Hearing for December 5, 2007 at 1:00 p.m. (attached hereto as "Exhibit X'). 3. The undersigned, counsel for Plaintiff, is requesting to continue the Custody Hearing in this matter because he has a previously scheduled hearing in York County on the same day as this hearing. 4. Diane M. Dils, Esquire, counsel for the Defendant, indicated that she has no objection to the continuance of the Custody Hearing. WHEREFORE, Plaintiff respectfully requests that this Honorable Court continue the Custody Hearing in this matter to a later date. y xo r Lagun,,;ir!, Esquire e Court I.D. No.: 75900 Attorney for Plainti f y LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 OCT 2 s 2007 a14 JEREMY JUMPER, Plaintiff v SARAH J. PREDIX, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : NO. 00-5389 : IN CUSTODY COURT ORDER AND NOW, this 3" day of 04t_, 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 3 of the Cumberland County Courthouse on the r day of 1PSC?3 2007 at - m. At this hearing, the father shall 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 the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. In the event father initiates additional therapeutic counseling/visitation with the minor child with a licensed professional that legal counsel for the parties discussed at the Custody Conciliation Conference, mother shall cooperate and insure that the minor child attends all scheduled sessions in advance of the hearing set forth above. Father shall incur the costs with respect to those sessions. ]BY TH , Judge cc: Roger R. Laguna, Jr., Esquire TRVUE COPY ;'T'OM RECORD Diane M. Dils, Esquire 9n 1..,;t rnor?y ??r? :c,r, + ? ?zC Jr v -3t my hand and e seal of :;.' ',;,,A# rEi Fa. Katherine Fitz-Patrick, Student Attorney •. j d J&ud 0_0 not EXHIBIT A LAGUNA REYES MALONEY, LLP 1 1 19 NORTH FRONT STREET, HARRISBURG, PA 1 7 1 02 TEL.: (71 7) 233-5292 / FAx: (71 7) 233-5394 LR M@STAN FORDALU M N L ORG ATTORNEYS FOR PLAINTIFF JEREMY JUMPER, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 00-5389 SARAH J. PREDIX, § CIVIL ACTION - CHILD CUSTODY Defendant § CERTIFICATE OF SERVICE I hereby certify that I served a certified copy of the Motion for Continuance filed in the above-captioned case, via first-class U.S. mail, addressed as follows: Diane M. Dils, Esquire 1400 N. Second St. (First Floor Front) Harrisburg, PA 17102 Katherine Fitz-'- Student Attorney Children's Adv c l cy Clinic 45 N. Pitt St. Carlisle, PA 17 132899 A6g tr . Lagun Jr. Esquire Supreme Court I. o.: 75900 C'a +? z rn t _ ?l: iJ t f? JEREMY JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-5389 CIVIL TERM SARAH J. PREDIX, Defendant CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this 9th day of January, 2008, hearing in this matter is continued to Wednesday, March 19, 2008, at 9:30 a.m. At said hearing, we will hear only from the parties and any of the counselors hereinafter set forth. We will schedule a subsequent hearing to hear from ancillary witnesses if requested. Pending said hearing, the following Temporary Order shall control: 1. The parties shall have shared legal custody of their daughter, Raelyn Grace Predix, born January 2, 1999. 2. Mother shall have primary physical custody of said child. 3. The parties shall undergo family counseling with Jamie Orris at Pa. Guidance Associates, with an eye towards reinstituting the relationship between father and child. Ms. Orris shall focus her efforts on helping father and daughter to reunify so that father may have regular periods of partial physical custody. She shall also focus her efforts upon helping mother and father cooperate toward the rebuilding of the relationship between father and child. 4. Father shall continue his individual counseling with Eric Finger. 5. Mother shall continue her individual counseling with Dr. Batista. 6. All three counselors shall communicate with each 46 other so that the parents' individual counselors can work on issues that will aid in the reunification process. 7. Guardian ad litem for the child shall be entitled to communicate with the counselors with regard to the parties' progress towards reunification. The parties shall sign limited releases allowing such communication. 8. Father shall be responsible for submitting all sessions involving the child to his insurance. Father shall be responsible for the co-pay on all sessions involving he and the child. Mother shall be responsible for the co-pay in all sessions involving her and the child. The parties shall be jointly responsible for the co-pay in all sessions in which they participate jointly or in which the child only participates. Roger R. Laguna, Jr., Esquire For the Plaintiff Diane M. Dils, Esquire For the Defendant Katherine Fitz-Patrick, Certified Legal Intern Lucy Johnston-Walsh, Esquire The Children's Advocacy Clinic G.A.L. for the Child srs I k's r" ?r t LCL ,??0108 Edward E. Guido, J. ?V Fz :1i 111V o l N r COO Ju l j ': ,a. I. ?o JEREMY JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS : NO. 00-5389 CIVIL TERM SARAH J. PREDIX, Defendant : CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this 19th day of March, 2008, hearing in this matter is continued to Thursday, May 29, 2008, at 1:00 p.m. The sole purpose of that hearing is to get an update on the progress of reunifiction from Ms. Orris. We will also hear from the parties and any ancillary witnesses the parties desire to present. Pending said hearing, the following temporary order of court shall control: 1. The parties shall have shared legal custody of their daughter, Raelyn Grace Predix, born January 2, 1999. 2. Mother shall have primary physical custody of said child. 3. The parties shall undergo family counseling with Jamie Orris at Pa. Guidance Associates, with an eye towards reinstituting the relationship between father and child. Ms. Orris shall focus her efforts on helping father and daughter to reunify so that father may have regular periods of partial physical custody. She shall also focus her efforts upon helping mother and father cooperate toward the rebuilding of the relationship between father and child. 4. The parties shall agree upon a third party other than Ms. Orris to supervise the visitation. If the parties are unable to agree, we will make a decision based upon the recommendation of Ms. Orris. 5. Guardian ad litem for the child shall be entitled to communicate with the counselors with regard to the parties' progress towards reunification. The parties shall sign limited releases allowing such communication. 6. Father shall be responsible for submitting all sessions involving the child to his insurance. Father shall be responsible for the co-pay on all sessions involving he and the child. Mother shall be responsible for the co-pay in all sessions involving her and the child. The parties shall be jointly responsible for the co-pay in all sessions in which they participate jointly or in which the child only participates. 7. The parties shall share the fee of Ms. Orris for her testimony today. It appearing to the Court that mother has already paid for the services, father is directed to reimburse her one half of that amount, being $500, within 30 days. In the future, we will be happy to check the progress with a report stipulated to by the parties. The costs of the report shall be shared. If either party is unwilling to stipulate to a report and desires to have Ms. Orris testify, that party shall pay her fee. 8. We will address the sharing of the counseling fees prior to Ms. Orris at t next cheduled hearing. By the Edward E. Guido, J. /oger R. Laguna, Jr., Esquire Foor the Plaintiff X ane M. Dils, Esquire For the Defendant Melissa Pearl Tanguay, Certified Legal Intern y cy Johnston-Walsh, Esquire The Children's Advocacy Clinic G.A.L. for the Child :mlc SIG :(, wi viz U14 OCR ? ,raUi ??' y?,_ 4a vHi JO '1? .! i r! E1 f LAW OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street, First Floor, Front Harrisburg, PA 17102 Telephone No. (717) 233-8743 JEREMY for Sarah J. Predix, Defendant JUMPER : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5389 SARAH J. PREDIX : CIVIL ACTION -LAW Defendant : IN CUSTODY STIPULATION AND AGREEMENT OF THE PARTIES AND NOW, this day of , 2008, comes the above named parties, Jeremy Jumper, represente y R err R. Laguna, Esquire and Sarah J. Predix, represented by Diane M. Dils, Esquire, and the parties intending to be legally bound, do hereby stipulate and agree as follows: s?g/OY 'ndA'1? 2 Y 5 5 4 On March 31, 2008, Plaintiff Jeremy Jumper, while in the presence of his daughter Raelyn, and the therapist, Jamie Orris, LSW, indicated that hey4?"-' Xd"wished to suspendHthe reunification process. On April 4, 2008, Jeremy Jumper agreed and consented that Jamie Orris, LSW, may continue counseling the minor child individually. 5? ?S"° COW OS? fi 3. Upon the recommendations of Jamie Orris, MSW, the minor child, Raelyn shall not be required to speak with her father via the telephone, nor shall the minor child be required to have any contact with her father at this time. 4. Any contact between the minor child, Raelyn, and the Plaintiff, Jeremy Jumper, shall be orchestrated by Jamie Orris, MSW, at some time in the future, should there be a request made by Plaintiff. The parties agree to accept the recommendation of Jamie Orris, MSW, as to any contact between child and father and agree to cooperate with said recommendations. 5. If in the future, father desires to attempt to reunite with his daughter, father, Jeremy Jumper shall contact Jamie Orris, MSW, for any recommendation and assistance in doing so. 6. The parries shall share legal custody of the minor child, Raelyn. Primary physical- custody of said minor child shall be in mother, Sarah J. Predix. 7. Mother. Sarah J. Predix, hereby waives her right for the Court to determine father's portion of the counseling costs as a result of the reunification process previously conducted by Dr. Virginia Hart; and instead shall proceed through the Domestic Relations Office. Father, Jeremy Jumper, is however, bound by Paragraph 7 of the Order dated March 19, 2008. 2 101,Ir 8. The hearing scheduled for Thursday, May 29, 2008, at 1:00 p.m. is hereby cancelled. 9. The parties, upon executing this Stipulation and Agreement, acknowledge that it is their intent that this Stipulation and Agreement be entered as an Order of Court. 10. The appointed Guardian ad Litem for the minor child hereby joins in this Stipulation and Agreement. 11. This Sti IN WIT s the day al SER R. LA and Agreement supersedes all prior court orders. S WHEREOF, the parties hereto have signed their hands and first above written. ESQ. IANE W. DILS, ESQ. IMP?1lT T-? ? A T T? /} T T ? T T 4 ? 1..?; +aa?f ri5?1nQ Fetfe % rC CERTIFIED LEGAL INTERN --(SEAL) J MY JU PER AU (SEAL) SARAH J. P EDIX (SEAL) ti LU OHNSTON-WALSH, ESQ. G ARDIAN AD LITEM FOR MINOR CHILD 3 c?;? ? a .? - ` - a ? ?-;j ., ?...._ J s tv..? ' ?-'... ?.", - ?: !' . , .? ?? f'?.3 y .'L`' Jeremy Jumper, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-5389 CIVIL TERM Sarah J. Predix, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of ' •?` , 2008 the attached V•• Stipulation and Agreement is hereby approved and entered as an Order of Court. J. -tM,b" - Z[ )tt.y 90 • yi1 :,.. t. l Gtr ?? _ _,. ?1v1 ua:? go/cfft