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HomeMy WebLinkAbout00-05566 ,-- . ~"", ",,", ~. ~' ~",-i . TERESA M. KANEV PLAINTIFF V, WILLIAM R. STAFFORD DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 00-5566 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 15th day of August ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite lOS, Camp Hill, PA 17011 on the 12th day of September , 2000, at 11:00 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. FOR THE COURT, By: Isl Melissa P. Greevy. Esq.tIJ 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 HA VB 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 i~ ~\I "I ".~I ., :1! ~!i !!I ::,' '!I I 'j '1 _._-~- ~, .' ", , < --, .,. '- .-<-" -~, '~' ,~' .~, -^,,,.~~-- ~'--~ ~'-' -~ . ,- "' ~ $' '<< ~,~" (V- -..f F;; cn-,O~F<~E . ,--...,' . V'l',1t1Ti.\RY ,',__",'1--".1" 00 AUG 15 Prl 2: 25 CU'AP::;;:;L'c"D COUN1Y . IVn...i_11 .,' PENNSY0/ANIA 1f:Js:tJeJ M~ ~ ~ 4 ~ ~'/(;-a; 71~ ~ ~ ~.1i. 0=-.-(5":&11 4pr~,;Qj ~'~ 1I!l!i~1lI~~,~ . ~d'W'l,#.1il~~~IJiI~ "",",_'~~" ~'j.1g!jf;"~~"fJ~;;I'~!"\F""<\\!~'~ISil-Wo;11'I',1:-lI!i!'''~I~mliJ1;!~", ' ,., - .. ,..~~-- --:;' Ii 5546-1-4/CUST CONCILIA nON ORDER! A VLlkld A!ugust 10, 2000 TERESA M. KANEV, PLAINTIFF v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLV AN1A : NO. OD- SS'1..1.. WILLIAM R. STAFFORD, DEFENDANT : CML ACTION - CUSTODY ORDER OF COURT AND NOW, ,2000, upon consideration ofthe attached Petition, it is hereby directed that the parties and their respective counsel appear before , Esquire, the Conciliator, at the Fourth Floor Conference Room, Cumberland County Courthouse, Carlisle, Pennsylvania, on the day of , 2000, 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 shall 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 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 WIIERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 '~ TERESA M. KANEV, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V AN1A v. WILLIAMR. STAFFORD, DEFENDANT : NO. : CIVIL ACTION - DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. , When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 WIIERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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 of business before the Court. ili( , ~~c 5546-1-4/CUSTODY COMPLAINT/A VLIk1d TERESA M. KANEV, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V AN1A v. NO. WILLIAM R. STAFFORD, DEFENDANT CIVIL ACTION - CUSTODY PETITION TO CONFIRM CUSTODY 1. Plaintiff is TeresaM. Kanev residing at 2610 Waterford, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is William R. Stafford, residing at 584 Madison Avenue, York, York County, Pennsylvania. 3. Plaintiff seeks to confirm the current custody arrangements for the following children: Name Present Residence Age Matthew Stafford 2610 Waterford Camp Hill, P A 17011 11 Kelsey Stafford 2610 Waterford Camp Hill, P A 17011 8 4. The children were not born out of wedlock. The children are presently in the custody of Plaintiff. 5. During the past five (5) years, the children have resided with the following persons and at the following addresses: ~ Persons Addresses Dates Plaintiff and Paul Kanev 2610 Waterford Camp Hill, PA 17011 6/99 to Present Plaintiff 39 Hanover Street Codorus, P A 17311 Approx. 5/97 to 6/99 Plaintiff and Plaintiff s parents 5 Monticello Avenue Codorus, P A 17311 1994 to Approx. 5/97 6. The mother of the children is Plaintiff, Teresa Kanev. She is divorced from the father of the children, Defendant, William Stafford. Plaintiff is remarried. 7. The relationship of Plaintiff to the children is that of mother. Plaintiff currently resides with the following persons: Name Relationship Paul M. Kanev Husband 8. The relationship of Defendant to the children is that of Father. Defendant currently resides with the following persons: Name Relationship Melissa Fiance 9. The parties were divorced pursuant to a Decree entered by the York County Court of Common Pleas on June 21, 1995. Prior to the entry ofthe Decree, the parties entered into an agreement with regard to custody of their minor children. Said custody provisions were incorporated into the parties' Separation and Property Settlement Agreement dated May 8, 1995. The relevant provisions are attached hereto as Exhibit "A." Plaintiff has no information of any other custody proceedings concerning the children pending in %] 'I "'~':i a Court oHhis Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or who claims to have custody or visitation rights with respect to the children. 10. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. Plaintiff is a fit parent. B. The children are doing extremely well under Plaintiff s primary care. C. The current custody schedule provides continuity, stability and certainty to the children's lives. 11. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WIlEREFORE, Plaintiff requests this Court confirm the existing custody arrangement by entering an order granting Plaintiff and Defendant shared legal custody and granting Plaintiff primary physical custody. Respectfully submitted, SMIGEL, ANDERSON & SACKS Date: August 10, 2000 By: LJ L::J LeRoy Smigel, Esquire !.D. # 09617 Ann V. Levin, Esquire !.D. # 70259 2917 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Plaintiff "~,... ~ ~ ~ c .. .;: "\ '~" ~~ 1;i---__n'-'iO;;' ..~ ~9 f COMMO~WEALTH OF PENNSYLvANIA COUNTY OF YORK -"" . ".. TERESA M, STAFFORD, Plaintiff VS, WfLLIAM R. STAFFORD, Defendant } fN THE COURT OF COMMON PLEAS OF } YORK COUN1Y, PENNSYLVANIA } } } } } NO. 94-SU-0279S-02-D DECREE IN DIVORCE BY THE COURT, ~ '" , /) iLULut E E "f-- 1::: ~ I~ ~ 0 ~ ~(.~ (). . ( ,... ~ ;?; 1 r\ ) ~I~ AND NOW, \,~\ \ Lt :7-1 , 1995, it is ordered and decreed that ..r~~EAESA M. STAFFOR~, Plaintiff, and WILLIAM R. STAFFORD, Defendant, are divorced o. . ,f~ from the bonds of matrimony, ~ ; ~ The attached Separation and Property Settlement Agreement dated May 8, 1995 shall ~ ' o '1~ ~~be incorporated but shall not merge in this Decree in Divorce. }~ t; ., i ~ ~ .c 0 E ~ ~1) ~' ;.. '" ~ :.:.l ';: \ Judge 1995 ----/ I ft) Prothonotary - ~~ -~"'Mil-irrlilW<M,': Separation and Property Settlement Agreement Page 6 to indemnify, defend and hold Wife harmless for the same, including actual counsel fees incurred by Wife to enforce this provision in the event of breach by Husband. Wife hereby agrees to sign any title or other documents necessary to transfer ownership of said vehicle upon Husband's refinancing. 8. Alimony. Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them, and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either rnay now or hereafter have against the other for support, maintenance or alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to seek from the other any payment for support or alimony. Each party shall indemnify, defend and hold the other harmless against any future action for either support or alimony brought by or on behalf of the other, such indernnity to include the actual counsel fees of the defendant in any such future action. 9. Custody. Physical custody of the minor children, subject to Husband's right to temporary physical custody, as follows: A. Alternate weekends from Saturday at 11:00 a.m. until Sunday at 7:00 p.m. B. One weeknight on either Tuesday or Wednesday, providing Husband notifies Wife on or before Sunday of the preceding week (at least 48 hours notice) of his choice from 5:00 p.m. until 8:00 p.m. In the event Husband cannot make it on either Tuesday or Wednesday, another night of the week may be chosen upon 48 hours advance notice by agreement of the parties. In the event Wife cannot have the children available for visitation on either Tuesday or Wednesday, she shall provide Husband with 48 hours advance notice of her need to reschedule the visitation, and the parties shall agree to either another night of that week or an additional night to be. added to a subsequent week. C. Alternating holidays consisting of Easter, Memorial Day, July 4, Labor Day, and Thanksgiving Day from 11:00 a.m. until 7:00 p.m. Husband shall enjoy Easter of 1995. D. The Christmas Holiday shall be divided into two segments and alternated annually by the parties, with Husband hav'Jlg Segment A and Wife having Segment B for 1995 and alternating thereafter, said segments being as follows: '~ - -""< I.~" ~'1 '~ . Separation and Property Settlement Agreement . Page 7 i) Segment A - from December 24 at noon until December 25 at noon; and ii) Segment B - from December 25 at noon until December 26 at noon. E. The above alternating temporary visitation schedule shall be a minimurn visitation schedule, and the parties may agree to alternate or additional visitation periods from time to time. The above schedule is based and dependent upon the parties' work schedules, and it may be subject to change by mutual agreement in the event of a change in such scheduling. 10. Support. Husband shall pay to Wife for the maintenance, education and support of their minor children such sums as may be determined by the Court of Common Pleas in accordance with the Order of Court dated September 13, 1994, and docketed to No. 1682-SA-I994 in such Court. The parties understand that the support payment is based upon the circumstances now known to the parties, and they acknowledge that, as those circumstances change, one party's ability to pay and the other party's need for payment may also change. Consequently, this Agreement shall not bar either party from adjusting the term or amount of support due hereunder, either by negotiation with the other party, or, if necessary, by resort to a court of proper jurisdiction. In the event an order of support is entered by a court of appropriate jurisdiction,' which makes adequate provision for the support of the person or persons covered by this paragraph, this Agreement shall not have any continuing independent effect, but shall be deemed to have merged into, and been replaced entirely by, the obligation to pay support pursuant to said court order. 11. Medical Insurance. In addition to the support payments provided for herein, Husband shall provide, at his sole expense, medical and hospitalization insurance, or its reasonable equivalent (such as will pay benefits equivalent to those currently provided by the medical and hospital insurance now provided by Husband's employer as of the date of this agreement), for the said children, as provided for in the existing Court Order for Support. This obligation may be modified by the Court or through the Domestic Relations Office should he be unable to provide such insurance. Husband shall provide Wife with notice of such inability as soon as he reasonably learns of sarne so that Wife rnay cover the children to avoid a gap in such coverage. ~ - IlLJ~f, . . VERIFICATION I, Teresa M. Kanev, verify that the statements contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Date: 'Y -/0- ciJ ~ JJ;~ 'I'Ilresa M. Kanev / s ~,;'l~_ i, ^~l1mlJ$J[w1I~I!.!:iIiJ , ' .e~' -O'jittllilil' ~~ A " ,:,,; il.Iim._~~ A ,~ ~ ~_c _ ~~_,. lJ ~ ~ ti ~ t., ...o?-J 0 ..Jr _ I ~ ~ ~ ---J ~ ~ ,," . .. >",' , .., -{q fi)0~ \ \ .~ ~ 0 ("\ I () \J ~ 7- "~"<i>'~'.rilIiIiif ' (') c <:: -Off'. mr,j :c: ~'J) -7r- ~~~ ~c._ i;.() ~f-j Pc Z :<! ...' .. ,., o a .". () '';"'1 ~-,i ~;~ ;:..,'; I ~3~ -'--1"1 p~,) '~rn <...: -I ="" ::0 -< C') CJ "'D ~'J)"T ,,-~ r::- :::t .c- - ~;--'" ,-- ," , ; , ,. TERESA M. KANEV, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW WILLIAMR. STAFFORD,: Defendant NO. 00-5566 CIVIL TERM ORDER OF COlJRT AND NOW, this 15th day of August, 2000, upon consideration of Plaintiffs Emergency Petition for Modification of Custody, a hearing is scheduled for Thursday, the 31st day of August, 2000, at 8:30 a.m., in Courtroom No. I, Curnberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, rJ;~ J, esley Ole LeRoy Smigel, Esq. Ann Levin, Esq. 2917 North Front Street Harrisburg, P A 1711 0 Attorneys for Plaintiff ~ L ~i.lt..ir>l , "'t- William R. Stafford 584 Madison Avenue York, PA 17404 Defendant, Pro Se :rc fi ,,:'. ,; :'" ":ilfllit:.,l;l;:~......iaJj.~ ~'.""';';";''''';''';''';''-i~!<;;'' ~~'\'tf , ~'"" , " "." " - ~ <, ,- '"..~~~'^ -, , " ~",<,",,~ ^' ~ - v\N'<J1\lASNN3d i.J.NnCO Ol':~T\!:r:jS\'Iln8 '0' II\''' L : fl'~ S \ f.lf\~ GO I\'t]\!\(":- ",' ..,,' " , v' ',\)'. "....' " \ ) ~, ',~, 1 ._ . -.I' ,..;..,..l.~'" -' ,- 3~\:bD-{\~n\~i J:' .--,'-... ... ~, , I~,~ j , ,~ , . 'N '^ " 'C --~,,,' - 5546-1-4 TERESA M. KANEV, PLAINTIFF v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V AN1A NO. 06- SSr..fc. CO.-Cr,VZ..n.Z CIVIL ACTION - CUSTODY WILLIAM R. STAFFORD, DEFENDANT ORDER AND NOW, this day of ,2000, upon consideration of the attached Emergency Petition for Modification of Custody, it is hereby ordered and decreed as follows: 1. Defendant's periods of visitation shall be suspended pending further order of court; 2. Defendant shall attend and provide records of regular attendance at AA meetings on an on-going basis; 3, Defendant shall submit to random urinalysis on an on-going basis; and 4. Defendant shall submit to breath alcohol testing if Plaintiff or the parties' minor children suspect that he has been using alcohol. BY THE COURT: J. ;" ~ 'IL, -" '" , "--')" "'- - "'~ /AVUkIdI/Emergency Petition for Modification of Custody/August 10, 2000 2:34 PM TERESA M. KANEV, PLAINTIFF v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. M-..5S?t 8;;y-r..u-. WILLIAMR. STAFFORD, DEFENDANT CIVIL ACTION - CUSTODY EMERGENCY PETITION FOR MODIFICATION OF CUSTODY AND NOW, comes Teresa M. Kanev, by and through her counsel, Smigel, Anderson & Sacks, and avers as follows: 1. Plaintiff is Teresa M. Kanev who currently resides at 2610 Waterford, Camp Hill, Peunsylvania 17011. 2. Defendant is William R. Stafford who currently resides at 584 Madison Avenue, York, Pennsylvania 17404. 3. The parties are the parents of Matthew Stafford, date of birth June 5, 1989, and Kelsey Stafford, date of birth, July 12,1992. 4. The parties were divorced on June 21,1995. 5. Custody provisions for the parties' children were addressed in paragraph 9 of the parties' May 8, 1995 Separation and Property Settlement Agreement. A copy ofthe relevant portions of the Agreement are attached hereto as Exhibit "A." 6. Defendant was incarcerated in York and Adams County from approximately April, 1998 through April, 1999 as a result of charges arising from Defendant driving while intoxicated. 5546+4 ";,,,--, '-' -;',--.." :O:'<"""',;;;_n, ,;,'.,'"" L ',,,; "j 7. On March 24, 1999, in anticipation of Defendant's release from prison, prior counsel for Plaintiff forwarded correspondence to Defendant regarding Plaintiff s serious concerns about future periods of visitation. (See March 24, 1999 letter attached as Exhibit "B.") 8. Defendant voluntarily agreed to be evaluated by an independent psychologist. Dr. Stanley Schneider was obtained to evaluate Defendant. 9. Pending the results ofthe psychological evaluation by Dr. Schneider, Defendant agreed that his visitation periods with the children would be supervised by his mother. (See attached Exhibit "C.") 10. April, 1999. 11. 12. 13. 14. Defendant's visits have been supervised by either his mother or fiance since Defendant is without question an alcoholic. Defendant has had periods of sobriety but has a long history of relapses. Defendant also has a history of depression and suicidal ideations. Defendant has been in and out of rehabilitation centers due to his inability to maintain sobriety. 15. Defendant has been in the following programs or counseling: (a) Chit-Chat-Caron Foundation (b) Colonial House, Inc. (c) White Deer Run (d) "Sees the Day" Recovery House (e) Philhaven Hospital (f) Stepping Stone (g) Family Service of York t ~ - ,- '-'~- 5546-1-4 16. On or about June 15,2000, current counsel for Plaintiffreceived Dr. Schneider's report. (A copy is attached hereto as Exhibit "D.") 17. Dr. Schneider clearly recommends what Defendant needs to do to establish sobriety on an on-going basis: - submission of attendance records from AA meetings; and - submission to random urinalysis on an on-going basis. 18. Plaintiffs counsel requested that Defendant voluntarily agree to Dr. Schneider's recommendations in correspondence dated July 25, 2000. (A copy is attached hereto as Exhibit "E.") 19. Defendant telephoned Plaintiffs counsel on Augnst 3, 2000. 20. Defendant refused to agree to Dr. Schneider's recommendations. 21. Defendant, by his own admission, does not attend AA meetings anymore. 22. Defendant stated that "to be quite honest," he had not attended any AA meetings "for quite some time." 23. Defendant told Plaintiff s counsel that his girlfriend is not always present to supervise his visits with the children. 24. Defendant indicated that there was no court order requiring his visits to be supervised. 25. Defendant also told Plaintiffs counsel that a court order would be required before he would agree to Dr. Schneider's recommendations. 26. Plaintiff has no means to confirm whether Defendant continues to use alcohol. 27. Plaintiff fears for the safety of her children if they are left with Defendant unsupervised. Iii ",- A"," ","- '.' , .aJ~~s 5546-14 . ' 28. The children are at risk, physically and emotionally, if Defendant consumes alcohol while the children are in his care. 29. Defendant believes he can maintain sobriety on his own. 30. Plaintiff knows that Defendant cannot maintain sobriety on his own based on his history. Defendant has difficulty remaining sober even with assistance from outside sources. 31. Plaintiff knows of no person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. WHEREFORE, it is respectfully requested that: (a) Defendant's periods of visitation be suspended pending further order of court; (b) Defendant be ordered to attend and provide records of regular attendance at AA meetings on an on-going basis; (c) Defendant be ordered to submit to random urinalysis on an on-going basis; (d) Defendant be ordered to submit to breath alcohol testing if Plaintiff or the parties' minor children suspect that he has been using alcohol; ( e) In the alternative, that Defendant's periods of visitation be supervised at all times by either Defendant's mother, Judith Stafford, or Defendant's fiance, Melissa. Respectfully submitted, Date: August 10, 2000 SMIGEL, ANDERSON & SACKS By: ,Lv Z;::J LeRoy Smigel, Esquire I.D. #: 09617 Ann V. Levin, Esquire LD. #: 70259 2917 North Front Street Harrisburg, P A 17110 (717) 234-2401 Attorneys for Plaintiff . . '- ,,' ,~< "" """"1'^'llr~,AW4",: .!!~ - _.9 f COMMO~VVEALTH OF PENNSYLvANIA COUNTY OF YORK ......' TERESA M. STAFFORD, Plaintiff VS. WILLIAM R. STAFFORD, Defendant i::' . ." } IN THE COURT OF COMMON PLEAS OF } YORK COUNlY, PENNSYLVANIA } } } } } NO. 94-SU-02795-02-D DECREE IN DIVORCE BY THE COURT, ," i1 ')1J1d! \ " I " ~ cUlad:. ~ e c-{"'.,;:, ~r-16 U1 AND NOW, (~; i H J I , 1995, it . o_ed ood d""ed !hot ,~~~ERESA M. STAFFOR~, Plaintiff, and WILLIAM R. STAFFORD, Defendant, are divorced n. . ~~ from the bonds of matrimony. " " ~ ~ The attached Separation and Property Settlement Agreement dated May 8, 1995 shall g '1~ ~~be incorporated but shall not merge in this Decree in Divorce. }~ .. ~; : i ~ ~ .c 0 ~~ ;;- " -0 ~11 i:J ~' i- ~ ~ Judge CERTIFIED 1995 --i) Prothonotary / > ~ -~, Separation and Property Settlement Agreement Page 6 to indemnify, defend and hold Wife harmless for the same, including actual counsel fees incurred by Wife to enforce this provision in the event of breach by Husband. Wife hereby agrees to sign any title or other documents necessary to transfer ownership of said vehicle upon Husband's refinancing. 8. Alimony. Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to thern, and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to seek from the other any payment for support or alimony. Each party shall indemnify, defend and hold the other harmless against any future action for either support or alimony brought by or on behalf of the other, such indemnity to include the actual counsel fees of the defendant in any such future action. 9. Custody. Physical custody of the minor children, subject to Husband's right to temporary physical custody, as follows: A. Alternate weekends from Saturday at 11:00 a.m. until Sunday at 7:00 p.m. B. One weeknight on either Tuesday or Wednesday, providing Husband notifies Wife on or before Sunday of the preceding week (at least 48 hours notice) of his choice from 5:00 p.m. until 8:00 p.m. In the event Husband cannot make it on either Tuesday or Wednesday, another night of the week may be chosen upon 48 hours advance notice by agreement of the parties. In the event Wife cannot have the children available for visitation on either Tuesday or Wednesday. she shall provide Husband with 48 hours advance notice of her need to reschedule the visitation, and the parties shall agree to either another night of that week or an additional night to be added to a subsequent week. C. Alternating holidays consisting of Easter, Memorial Day, July 4, Labor Day, and Thanksgiving Day from 11:00 a.m. until 7:00 p.m. Husband shall enjoy Easter of 1995. D. The Christmas Holiday shall be divided into two segments and alternated annually by the parties, with Husband hay;..ng Segment A and Wife having Segment B for 1995 and alternating thereafter, said segments being as follows: "." ~ 'lU~ .', ~ ~~~o Sepllration /lnd Property Settlement Agreement .Page 7 i) Segment A - from December 24 at noon until December 25 at noon; and ii) Segment B - from December 25 at noon until December 26 at noon. E. The above alternating temporary visitation schedule shall be a minimum visitation schedule, and the parties may agree to alternate or additional visitation periods from time to time. The above schedule is based and dependent upon the parties' work schedules, and it may be subject to change by mutual agreement in the event of a change in such scheduling. 10. Support. Husband shall pay to Wife for the maintenance, education and support of their minor children such sums as may be determined by the Court of Common Pleas in accordance with the Order of Court dated September 13, 1994, and docketed to No. 1682-SA-1994 in such Court. The parties understand that the support payment is based upon the circumstances now known to the parties, and they acknowledge that, as those circumstances change, one party's ability to pay and the other party's need for payment may also change. Consequently, this Agreement shall not bar either party from adjusting the term or amount of support due hereunder, either by negotiation with the other party, or, if necessary, by resort to a court of proper jurisdiction. In the event an order of support is entered by a court of appropriate jurisdiction, which makes adequate provision for the support of the person or persons covered by this paragraph, this Agreement shall not have any continuing independent effect, but shall be deemed to have merged into, and been replaced entirely by, the obligation to pay support pursuant to said court order. 11. Medical Insurance. In addition to the support payments provided for herein, Husband shall provide, at his sole expense, medical and hospita1ization insurance, or its reasonable equivalent (such as will pay benefits equivalent to those currently provided by the medical and hospital insurance now provided by Husband's employer as of the date of this agreement), for the said children, as provided for in the existing Court Order for Support. This obligation may be modified by the Court or through the Domestic Relations Office should he be unable to provide such insurance. Husband shall provide Wife with notice of such inability as soon as he reasonably learns of same so that Wife may cover the children to avoid a gap in such coverage. - ',~ .---- LAW OFFICES ./OllN \V. PURCELL HOWARO Il KRUG LEON I'. HALLER JOHN W. PURCELLJR, JILL r-.1. WINEKA BRIAN J. TYLER NICff()LE M. STALEY [JJJ~ ~ ff ~ 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TElEPHONE (717) 234-4178 FAX (717) 233.1149 HERSHEY (717)533-3830 JOSEPH NISSLEY (1910-1982) VALERIE A. GUNN OF COUNSEL March 24, 1999 Mr. William Stafford Adams County Prison 625 Biglerville Road Gettysburg, PA 17325 Dear Mr. Stafford: please be advised this firm represents your ex-wife, Teresa with respect to your continuing visitation with your children. My client has informed me of prior situations involving severe depression, leading to statements regarding suicide, and what appears to be unmanageable alcoholism. As a result of the former, it is my understanding that you were hospitalized for observation, anu as a result of the latter situation, you were ultimately incarcerated for DUI. As you are aware, my client encourages the children to maintain a relationship with you, as she believes it is in their best interest to have both a father and mother. On the other hand, suicidal ideations and alcoholism can ultimately lead to situations that negatively impact upon the good mental health of the children, and it is this factor that my client seeks to eliminate. Teresa has come to me for advice as to how to proceed. It is my recommendation that no further visitation be permitted until such time as an independent psychiatrist or psychologist has totally evaluated your records and, if necessary, you have been tested to determine whether there is any threat to the children. Basically, the entire situation would be left in the hands of a reputable professional who would be independent and only interested in the '-J: Mr, William Stafford March .24, 1999 Page 2 best welfare of the children. If that professional believes there to be no continuing future problem, then visitation would resume. If there is any issue, supervised visitation is a possibility, if recommended by that professional, We are currently looking at the possibility of either Dr. Stanley Schneider or Dr. Arnold Shienvold being the involved professional. From your end, you would obviously have to sign the necessary documents to release all of your records and actively participate in any face-to-face evaluations needed by the involved psychologist. Thus, I ask for your voluntary participation by executing all documents needed by the professional to secure documentation to commence his study. please understand that my client's interest is only that of the children, You are currently leading separate lives as a result of the divorce, and she intends to maintain that status, She has no personal animosity toward you whatsoever. However, if you refuse to voluntarily participate in what I have suggested and we have no answer from you within ten (10) days from the date of this letter, I will have no choice but to file the necessary custody Petitions with the Court in order to maintain what we believe to be in the best interest of the children. As part of the custody process, you would have to be evaluated, and it can certainly take much longer than the process I have outlined in this letter. It is not my client's desire to have this matter extended or delayed, as such is certainly not in the best interest of the children. I look forward to receiving your written response to this letter within ten (10) days from the date hereof. Should I not receive it within that period of time, we will take all necessary protective action thereafter in the best interest of the children, Sincerely yours, Howard B. Krug HBK/cdv cc: Ms. Teresa Stafford , '" c_ ~ '" _ -". -~! ~aW' DffiC!Ej, '0( {!a~olyn d. ~aj,k!:J CAROLYN S. LASKY ANN MARIE McELWEE KATHLEEN l. PRENDERGAST II EAST MARKET STREET YORK, PENNSYLVANIA 17401,1227 TELEPHONE (717) 846.2270 FAX (717) 848.3291 PARALEGALS, KIMBERLY J. DIRCKS DAVID W. ROMEO II CLIENT LIAISON, SHIRLEY A. MCCAUSLIN April 9, 1999 Harold B. Krug, Esquire PURCELL, KRUG & HALLER 1719 N. Front Street Harrisburg, PA 17102-12j92 RE: Stafford vs. Stafford Dear Attorney Krug: As we discussed on the phone, I have spoken with Mr. Stafford, and we are making the following proposal: I. He will agree to participate in the psychological evaluation with Dr, Stanley Schneider at your client's expense. 2. We are providing a letter from the counselor whom he met at Adams County prison to address your concerns short term. 3, Mr. Stafford's mother will supervise all of his custody and visitatIOn pending the outcome of the evaluation and recomrnendations of Dr. Schneider. This letter is also to notifY you that Father intends to exercise his weeknight custody on Tuesday evenings each week until further notice. He would like to begin his weekend visits starting the weekend of April ] 7 - 18, 1999. All other custody will be subject to the terms of the existing agreement. Could you please review these terms with your client and get back to me if you have any questions or concerns. Cordially, LAW OFFICES OF CAROLYN S. LASKY !Zb{;Jjt,/L/ Kathleen J. Prendergast, Esquire KlP/dwr cc: William Stafford 1 0, ~J.~ ~ i\gU~ ,.,.. -- ~GUIDANCE . . ASSOCIATES OF . .l' PENNSYLVANIA 55'11,-1-1 . r -: '"""L ' ~ ",-. . \. MAIN OFFICE 412 Erford Road Camp Hill, PA 17011 Stanley E. Schneider, Ed.D. Director April 5, 2000 Camp Hill: (717) 732.2917 Hershey: (717) 533-4312 Carlisle: (717) 245.2289 Chambersburg: (717) 263-9392 FAX: (717) 732-5375 Mr, William R. Stafford C/O Peter C. Farese,LSW Family Service of York 1 Market Way West York, PA 17401 Dear Mr, Stafford: I am sending you a summary of my findings obtained from my evaluation of June 1999. In addition to your interview, I reviewed a number of documents reflecting your successfully completin[. ;~ substance abuse treatment, attorney correspondence, contact with Lori Barton, your children's ~. therapist, and copies of your lab reports reflecting negative findings concerning alcohol use for May and June of 1999. Through mid summer 1999 it appears that you have been successfully working on your sObriety with no evidence of any relapse. Results of your child management questionnaire reflects that you would engage in appropriate, relevant, and meaningful disciplinary techniques with your children should the situation arise. In that regard, the major concern brought to" my attention was the potential of you possibly relapsing. Results of your personality profile (MMPI-2) were valid. Your personality/behavioral characteristics are consistent with those people who have a lot of drive and energy. Minor problems with society's rules is sometimes seen. Scores reflect underlying competitiveness, opportunism, verbal fluency and difficulty delaying gratification. Certain questions were answered in a way that indicates that you may not blame anyone for trying to get what they can. Further, you endorsed items that reflect a lack of anxiety around interpersonal initiative. The findings reflect that you would be comfortable in social situations, would argue your position if needed. Other findings suggest that you tend to feel misunderstood by others, may feel resentment toward those who keep you from fulfilling your agenda. This is understood and is consistent with and reflective of your reported experiences regarding difficulty having access to the children. On the positive side, you present feelings of guilt and self blame expressing regrets in what you have done, much like alcoholic remorse. As noted, the major concern brought to my attention during my invqlvement in 1999 relates to your history of relapses. Should you remain clean and sober, I could' not identify any reasons why you could not have partial physical custody of your children without superVision. It would be appropriate to ease the children into this slowly to allow for their adjustment. c=:----..... -- . cerely, Stanley . Schneide, d.D., CAC Psychologist, Certified Addictions Counselor SES:sm Comprehensive Psychological Services . Drug and Alcohol Treatment - L. "' ~. '~, - - ~t MAIN OFFICE , ,,' .,,412 Erford Road . Camp Hill, PA 17011 Stanley E. Schneider, Ed.D. Director (;GUIDANCE , ~SSOCIATES OF "'PENNSYLVANIA Camp Hill: (717) 732-2917 Hershey: (717) 533-4312 , , " . Carlisle: (717) 245-2289 Chambersburg: (717) 263-9392 FAX: (717) 732-5375 '" ;.:~ '_.'''''r~o/~~:.~~'..:..;~~~jJ'~~-~~-?' Addendum to April 5, 2000 letter - .~", ! ; .-,~; ~\ . :- _oJ j ,; Mr. William R. Stafford c/o Peter C. Farese, LSW Family Service of York 1 Market Way West York, PA 17401 Dear Mr. Stafford: It strikes me that your burden of demonstrating continuing sobriety would be satisfied by submitting attendance records from your sponsor and/or other persons with whom you attend AA meetings. I would also suggest that you submit to random urinalysis on an on-going basis. I believe these steps would remove any continuing concerns related to your drinking. Stanley E. Schneider, Ed.D., CAC Psychologist, Certified Addictions Counselor Comprehensive Psychological Services . Drug and Alcohol Treatment -Iti ~ -'" jf;,: ., SMIGEL. ANDERSON & SACKS ATTORNEYS AT LAW LEROY SMIGEL C, LEE ANDERSON STUART S. SACKS .JOHN W. F'ROMMER .JOSEPH 8. D'AMICO ANN V, LEVIN HEATHER D. ROYER ERIC M. MORRISON .JUNE C. LEE 2917 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17110-1260 17171 234-2401 F'AX 17171 234~361f fiLENO, 5546-1-4 July 25, 2000 Mr. William Stafford 584 Madison Avenue York, PA 17404 Dear Mr. Stafford: We recently received a copy of Dr. Schneider's correspondence dated April 5, 2000 and the Addendum to that letter. I believe that we can take steps towards eliminating the requirement for supervised visits upon receipt of attendance records from AA meetings dating back to the summer, 1999. We will need an ongoing commitment from you to continue in counseling and to attend AA meetings, We will ask you to agree to provide proof of attendance upon request. We are also requesting that you submit to random urinalysis on an ongoing basis. Stepping Stones located at 1776 South Queen Street in York (843-8204) has a program called TASK that can assist in implementing this process. If for some reason it is suspected that you have been drinking alcohol (in between your random testing), we will ask you to stop at Concentra. They provide breath alcohol testing at two locations in Harrisburg and Mechanicsburg. These requests are made based upon Dr. Schneider's recomrnendations. I also believe they are consistent with what a court would recommend under the circurnstances. I would appreciate if you would let me know as soon as possible whether or not you are in agreement with the above suggestions. If so, I will prepare the appropriate documents for signature. I look forward to hearing from you. Very truly yours, .LIb Ann V. Levin A VL/kld cc: Teresa Kanev ~ Ii i.IIGmi~~, . . VERIFICATION I, Teresa M. Kanev, verify that the statements contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date: 7~/o~tJJ ~~~ LJjjj l.MJlillliJP ,"1 ,A "~,, " , ,:.,,,,~,r,,,.p,, ,''', , jJ1Ullr~~~~'~ 'oj']'" ,'0,"" - ~,' -,-, " ,,~~,.." '" ,,'<,,' ~'^' --',~.- ,,;,.,,:, (l ~~ -r- C1J n~f'i ~?:~ L,.t ~c.;_.~ ~e) :r?f...J !-::,-:;C) Pc: ::'S -< ..,"" ,~ '--..' (:"1 ~ :-::-.! jU ~ I :::J ~qt3 '~;,~~~ f;?o Om j! ::D -< ~ ;:;? <=> -D .--,,,. r- .::::> m i" ~':-.L ,~ - ~j TERESA M. KANEV, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW WIL,LIAM R. STAFFORD,: Defendant NO. 00-5566 CIVIL TERM ORDER OF COURT AND NOW, this 30th day of August, 2000, upon consideration of the attached letter from Ann V. Levin, Esq., attorney for Plaintiff, the hearing previously scheduled for August 31, 2000, is continued generally. COUNSEL ARE requested to contact the court if they desire to schedule a hearing in this matter. BY THE COURT, LeRoy Smigel, Esq. Ann Levin, Esq. 2917 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiff William R. Stafford 584 Madison Avenue York, PA 17404 Defendant, Pro Se ~ ~ ~.3('qo --rJ :rc ~ 01. " ~'~ ."~ ~~...~. ........'''MiLil ~, , " ~~Awarurl'~ 'r. ;",,",~.""'" ",~~u",-" ""' V!N\(\-/ASNN3d AiNiler) ",:f~~)::~:~t~~n8 ~ tl .:11 ; \1,-; L I "c ! C ~inu 00 AC'~~.c;\jCr :C. _'Ci- .1("] '".'-' ._, ,J:'1 , , " :",,~- 'or., :~ I ""- --- .~ - , ~ -~. .,..;iJi,; AUG-30-00 11 :44 FROM-SMIGEl,ANDERSON & SACKS 7172343611 7-66B P.Ol/ol F-m '- . Sll<UGEL, AND:B:;aSON &; SAoxs ATTORNEYS AT LAW LEROY SMIGEL. C. 1..1;.1: ....NOE:RSON STUART S. SACf(S .JOHN W. PROMME:R .JOSEPH ~. P'AMIQO 2917 NORTH rt:lONT STAE:E:.T HARRISBURG, PENNSYLVANIA 17110-1260 (717J 2.34-2401 FAX 17171 a~.3ell 5'~~1-4 ....NN \I. LEVIN I-lEATHti:R D. FilO"'~Fl IO:RIC M. ",",ORRISON ~uNE: C, LEE: August 30, 2000 FAX 240-6462 Honorable J, Wesley Oler, Jr. Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 Re: Teresa Kanev v. William Stafford Docket No. 00 - 5566 Dear Judge Oler: This will confirm my conversation with Ruth earlier this morning regarding the above- referenced case, During that conversation l indicated to Ruth that the parties were trying to negotiate a resolution to the pending petition and have agreed to continue the hearing scheduled for tomotrow, August 31, 2000, at 8:30 a,m. Ruth has indicated that will not be a problem and that a general continuance will be granted, If the parties are unable to resolve the pending matters, I have been advised that I should contact yot)]: office to reschedule. Please call if you have any questions. Thank you for your attention to this malter, X'D Ann V. Levin A VL/kld cc: Teresa Kanev William Stafford '~". TERESA M. KANEV, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. No. 00-5566 Civil Action - Law WILLIAM R. STAFFORD, Defendant. In Custody ORDER OF COURT AND NOW, this 20th day of November, 2000, the Conciliator, being advised by Plaintiff s counsel that the parties have reached an agreement reflected in a Stipulation which Plaintiff s counsel will file with the Court, hereby relinquishes jurisdiction in this case, FOR THE COURT, ( if UJlJZl3 Melissa Peel Greevy, Esquire Custody Conciliator ~ ~' ~1,;lt"lI:' NOV 22 2' .~ , , 'bl:~~liilIllilibllWld~'f "~.,I'- 'c<~""",~,'*J.,,~," <""'~' ."," p ~..lil.1tli~~iIillJJ\~~jW.J'S~il\li_$!!liil;i-~ ~ ' ".. , " ,'1" ...;--"< - ~i'_ .'.." ,- .....,..J~'"~......~~~lIiiilIl' ~~ ~~ - -oi:,-' cnr: ~-"-, ~.;~,- ~C-~: ~~ =i -< .~ C~, " C'- '-- ;'-."; ee, If? c:- "'_.I :.i ':,:) :.:;:,:-1 ~J5 -< ~ " ,'~, " ~~l . TERESA M. KANEV, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V AN1A v. NO. 00 - 5566 WILLIAM R. STAFFORD, DEFENDANT CIVIL ACTION - CUSTODY ORnER AND NOW, this 4. ~ day of t)1" (( -. ~c.r , 2000, having reviewed the parties' Stipulation in this matter, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the attached Stipulation for Custody are adopted as an Order of Court as if set forth herein at length. BY THE COURT: J. C o-p;. n 1f)~ I ~- ~ -00 R~ llitil:"Y1, .-", .In '.a:J;;!J u", -' ",--,,'" '-~"""'," ..' ,-~- ~l'!i~~~~~~' c /", ~ '-.,- _,,,0. (V" """. "'". ' 'i!\NVAlASNN3d )J.Nnm GNY1l:!3BV'lm U:; :E; f.ld ~- :)30 00 A\N10"" ",." ,",,, '0 .ov, i -,:UH.lf...i\JQ ;i1tl :J' 38I:HO-CJJ1\::l ?,,-- " 'jj,j. ~. -,,,' c iilIIliliiiiliiilli . !1 1'- ,,~.-- ~'-, C' _, _ ,',' ,'_' , >~ ~_.:"<' "', j . 5546-1-4/Stipulation/ A VUkld TERESA M. KANEV, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00 - 5566 WILLIAM R. STAFFORD, DEFENDANT CIVIL ACTION - CUSTODY STTPlTT ,A nON FOR CCnSTOnV AND NOW, this If) !A..,day of A!oo/'e;r1her ,2000, the parties hereto enter into a Stipulation for Custody as follows: WHEREAS, the parties hereto are Teresa M. Kanev and William R. Stafford who were divorced pursuant to a decree entered on June 21,1995 in the York County Court of Common Pleas; and WHEREAS, the parties are the parents of Matthew Stafford, date of birth, June 5, 1989 and Kelsey Stafford, date of birth, July 12, 1992; and WHEREAS, the parties have reached an agreement regarding the best interests of their minor children NOW THEREFORE, Plaintiff and Defendant do stipulate and agree that the best interests and welfare of their said; children will be served by the following: 1. Plaintiff is Teresa M. Kanev residing at 2610 Waterford, Camp Hill, Cumberland County, Pennsylvania, 2. Defendant is William R. Stafford, residing at 584 Madison Avenue, York, York County, Pennsylvania. 3. The parties have reached a custody agreement regarding their children's best interests. ';.;;..'.. <<, '~ ,.. ,.,' .';' ".'~~ 4. The parties agree to submit this Stipulation to the Court with the respect that the following terms be made part of an Order of Court for custody in the above-captioned matter: a. Legal custody of the children shall be shared by the parties. b. Primary physical custody of the children shall be enjoyed by Plaintiff, Teresa M. Kanev. c. Partial physical custody of the children shall be enjoyed by Defendant, William R. Stafford, for the purpose of visitation on the following schedule: 1. Alternate weekends from Saturday at 11 :00 a.m. until Sunday at 7:00 p.m. ii. Alternating holidays consisting of Easter, Memorial Day, Fourth of July, Labor Day, and Thanksgiving Day from 11:00 a.m. until 7:00 p.m. with Plaintiff having Easter for 2001. Plaintiff shall have Thanksgiving in 2000. 111. The Christmas holiday shall be divided into two segments and alternated annually by the parties, with Defendant having Segment B and Plaintiff having Segment for A for 2000 and altemating thereafter, said segments being as follows: Segment A - from December 24 at noon until December 25 at noon; and Segment B - from December 25 at noon until December 26 at noon. IV. The above schedule shall be a minimum visitation schedule, and the parties may agree to alternate or additional visitation periods from time to time. d. Defendant's periods of visitation with the minor children shall be supervised at all times. The parties agree that Defendant's fiance, Melissa Brenneman, is an appropriate supervisor. e. Defendant shall, upon Plaintiff s request, contact Concentra Medical Center and make arrangements for breathalyzer testing. Defendant agrees to pay for the cost of the testing if the result is positive. Plaintiff agrees to pay for the cost of the testing if I~ , -~',,,. )Jij~~' the result is negative. f. Defendant shall attend regular AA meetings. g. Defendant shall comply with all recommendations made by the Cove Forge Rehab Center upon his discharge in October, 2000. h. Defendant shall continue in counseling with Rick L. Klinedinst of Yorktowne Psychological Associates and comply with all recommendations made by the counselor. 1. Defendant shall ensure that there are no alcoholic beverages at his residence. J. Defendant shall not operate a motor vehicle with the children until his operating privileges have been fully restored by the Commonwealth of Pennsylvania. k. The parties shall cooperate to the maximum extent possible to undertake their best effort to serve the best interest of the children in their parenting. L The holiday schedule shall always supersede the regular schedule of custody. m. Each of the parties shall permit reasonable telephone contact between the child and the non-custodial parent. n. Both parents shall refrain from making derogatory comments about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the children. Neither party shall discuss this matter with the minor children and shall prohibit third parties from discussing this matter with the minor children. o. Neither parent shall use drugs or smoke cigarettes in the same vehicle or household when they have custody of the children. -~I!l -"'- .- 'k" ~" JWi:1W, The Plaintiff and Defendant do verify that they stipulate as set forth above and that the statements herein are true and correct to the best of their knowledge and information and belief. Plaintiff and Defendant understand that false statements herein are made subject to the penalties of 18 Pa,C.S. 94904 relating to unsworn falsification to authorities. kcG1A-- j'~~\r- deresa M. Kanev, P . tiff "~ ~ [J J1I/Y1v-ll-,4 W William R. Stafford, De dant I, Melissa Brenneman, understand that I am to supervise all periods of visitation that William Stafford has with his minor children, Matthew Stafford and Kelsey Stafford. I agree to assume this responsibility. Date: -1\ /\ '3 /00 ~od,/;~a POJ1J)PI(jflO~{IV Melissa Brenn an '~ll~' w ....,~ '~, 1M( -jl . '_jjj""'c- '-,~; >~ "2 m;~'i'ft.l!d ~~ MUI__18r.lllili~M'ili fi: II') >- 0 Z ;S; .. :JS; WG - 8.~ t'.::J:Z x: ~'~ 0- , (?t~c . 1..._.-1 ~... 8';d: I !-.l.lW- W;.... --.J _ ~ " W ILl'- f.L:,,";c1 u.l ~. ' ~-= CJ u <0 ::> d <::> U - .." ,"'~,,', ~ ~'---'" .'-' , . ',,' ~. -"~ ..lIiII_B' " " . " 'I I' ,I I. 'I II I I , i i , I I I I I I I ! I I t- f I. . TERESA M. KANEV, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00 - 5566 WILLIAMR. STAFFORD, DEFENDANT CIVIL ACTION - CUSTODY ORnF,R AND NOW, this ~ ~ ~ '\ day of J ~ 0":>':.\ ' 2001, having reviewed the parties' Amendment to the Stipulation for Custody, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the attached Amendment to the Stipulation for Custody are adopted as an Order of Court as if set forth herein at length. 1. l~ \f;~ .1 ~~L~.t!r ,,- -~~~iNi.iW1Jl' !m~ar ~ H~ ~f~€'l~,liilM'i~~-;w'~~"""""" ., VI~N!\1ASNN3d I I ~ln!V'1 OJ, ",P' i"'CJ;/!'n"U ru..l, I'~/L~, ',~_','I' iC],~lLd~ """ 7!l 1 b I :!J ,'ie' 6- ~nv 10 Atf'ilCY.;:,); oJ :rJ!:J::::'.El: ," ,-~,. I ,~_ _ ^,- ",~' iii J .. - ~ ,-""" Oh '- , " ~ ~ .' 5546-1-4/Amendment to Stipulation! A VUkld TERESA M. KANEV, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00 - 5566 WILLIAM R. STAFFORD, DEFENDANT CIVIL ACTION - CUSTODY A MRNnMF,NT TO TIm STTPIJT ,A TION FOR CClJSTOnV AND NOW, this ---11- day of :5 u ~ Amendment to the Stipulation for Custody as follows: , 2001, the parties hereto enter into an WHEREAS, the parties hereto are Teresa M. Kanev (hereinafter "Plaintiff') and William R. Stafford (hereinafter "Defendant"); and WHEREAS, the parties wish to modify the November 18, 2000 Stipulation entered as an Order of Court on December 4, 2000 to authorize additional individuals who can supervise Defendant's visitation periods with the minor children. NOW THEREFORE, Plaintiff and Defendant do stipulate and agree that November 18, 2000 Stipulation shall be modified as follows: 1. Pursuant to paragraph 4(d) of the Stipulation, Defendant's visitation with the minor children l(f'J1'oU" It-W>V0llJ M.edl.l"~~) shall be supervised at all times by Melissa Brenneman. The parties agree that Jeff Brenneman and/or C~~4L>~J) Karen Brenneman may supervise Defendant's visitation with the children when Melissa Bre~ unavailable to do so. 2. All other provisions of the November 18, 2000 Stipulation shall remain in full force and effect. '. J. I '~r;, The Plaintiff and Defendant do verify that they stipulate as set forth above and that the statements herein are true and correct to the best of their knowledge and information and belief. Plaintiff and Defendant understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. lAJfi- ~ J!?esa M. Kan~y(aintiff Wf:!~~LdU? We, Jeff Brenneman and Karen Brenneman, agree to assume the responsibility of supervising Defendant's visitation with the minor children when Melissa Brenneman is unavailable to do so, \('{lOlOl~.u.. Wl.DI\.~..., v<>~) Date: 7flo/ /$1(~-rH-d?') ~renneman Date:~(lllol t<<'Ioa.J.) ~) Karen Brenneman ;\';..',,' 'ju,-"--';"':' ,~,=,-' ~ ljQ, 'I ^'.~ ' ifliU.~I!'~'~' '='~_il.mlP'''-'~''''; .,~ , ". .;',",., io-...;''';'~ >~. 0< l "'!II' :r ! ~ 0 0 0 C '-n s: .,.. -0 CO c::: ....n t:.f1rn Co' Z:I1 I ':';EJ zr,:- ~:2_ o~ .,-: , g~ ~c: ~ <,' ~o -'",' -0 ':? orn >'C ,,4 ~ i"> '.p,' :.Q -<- <.~~ ~'