HomeMy WebLinkAbout00-06884
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
COMMONWEALTH OF PENNSYLVANIA
DONALD RATEL,
Plaintiff,
v.
No. 00 - Lf!P!/.
Cu,'L~~
LORI A. RATEL,
Defendant
Civil Action - Custody
ORDER
AND NOW, this /211, day of (jch~ , 2000, upon presentation of the
foregoing Stipulation For Entry of an Agreed Order of Custody, it is hereby Ordered that,
DONALD RATEL, hereinafter referred to as ("Father") and LORI A. RATEL hereinafter
referred to as ("Mother") shall each have JOINT PHYSICAL CUSTODY of their minor
child by the name of Alisha M. Ratel.
IT IS FURTHER ORDERED THAT:
1. This agreement shall replace all any and all other previous Orders issued by this or any other
Court relating to the Custody of the aforementioned child.
2. The parties shall have shared Legal Custody of the children.
3. Both mother and father shall have Joint Physical Custody of the Child.
4. Both mother and father shall have Joint Physical Custody of the child as they may agree
based upon what each of their schedules will allow at any given time within each months,
5. Both parents will cooperate with the other in establishing reasonable dates, and times so as to
comply with the Joint Custodial Arrangement established within the Agreement of Custody,
6. All holidays shall be shared as between the parties on an alternating basis or shall be split as
the parties may agree at any given time prior to the holiday.
7. Both Mother and Father shall be entitled to two (2) consecutive weeks of custody with the
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child during their summer vacation. If either the Mother or Father intends to remove the
child from the Commonwealth of Pennsylvania, they agree to provide the other parent with
the name, address, and telephone number of their place of destination prior to their
departure.
8. The non-custodial parent shall have reasonable telephone contact with the child during the
child's absence at appropriate times of the day or evening.
9. Neither party shall remove the child from the Commonwealth of Pennsylvania without the
other parent's consent, except for summer vacation, and then only if that parent provides the
other parenr willi advance notice as to the name, address, and telephone number of the
destination to the non-custodial parent,
10. The party receiving custody of the child shall provide transportation commencing his or her
periods of custody with the child.
BY THE COURT,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
COMMONWEALTH OF PENNSYLVANIA
DONALD RATEL,
Plaintiff,
No. rJ1I- {,ffl-l ~ ~
v.
Civil Action - Custody
LORI A. RATEL,
Defendant
STIPULATION FOR ENTRY OF A CUSTODY ORDER
TEllS STIPULATION AND AGREEMENT entered into this _ day of
2000, by and between LORI A. RATEL, (hereinafter referred to as
" Mother") and DAVID RATEL, (hereinafter refereed to as " Father").
NOW THIS AGREEMENT WITNESSETH THAT:
WHEREAS, the Mother and Father are the natural parents of child, by the name of
Alisha M. Ratel (hereinafter "Child"), and
WHEREAS, the parties wish to enter into a Stipulation Agreement, relative to the custody of
the aforementioned child and have the same entered and enforced as an Order of Court.
NOW, THEREFORE, in consideration of the mutual promises, covenants and agreements
as hereinafter set forth and intending to be legally bound, the parties hereto stipulate as to the
custody of their children, as follows:
1, The parties shall have shared Legal Custody of the children.
2. Both mother and father shall have Joint Physical Custody of the Child.
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3. Both mother and father shall have Joint Physical Custody of the child as they may agree
based upon what each of their schedules will allow at any given time within each months.
4. Both parents will cooperate with the other in establishing reasonable dates, and times so as
to comply with the Joint Custodial Arrangement established \\ithin the Agreement of
Custody.
5. All holidays shall be shared as between the parties on an alternarin~ basis or shall be split as
the parties may agree at any given time prior to the holiday.
6. Both Mother and Father shall be entitled to two (2) consecutive weeks of custody with the
child during their summer vacation. If either the Mother or Fath..'"l' intends to remove the
child from the Commonwealth of PeniIsy1vania, they agree to provide the other parent with
the name, address, and telephone number of their place of destination prior to their
departure.
7. The non-custodial parent shall have reasonable telephone contaCt with the child during the
child's absence at appropriate times of the day or evening.
8. Neither party shall remove the child from the Commonwealth of Pennsylvania without the
other parent's consent, excePt for summer vacation, and then only if that parent provides
the other parent with advance notice as to the name, address, and telephone number of the
destination to the non-custodial parent.
9. The party receiving custody of the child shall provide transportation commencing his or her
periods of custody with the child.
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IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms
hereof, set forth their hands and seals the day and year herein set forth.
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Donald G. Rate!
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND : s.s
BE IT REMEMBERED, that on this ()fiQ day of,fu"TIl~. ,2000 personally
appeared before me the Subscriber, a Notary Public for the State and County aforesaid, Donald
G. Rate! party to this Agreement, known to me personally to be such, and she acknowledged the
act of signing this Agreement.
Sworn to and subscribed before me the day, month and year aforesaid
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NOTARIAL SEAL
.lUD1TH ANN VAlENTINE, Notary PldJJic
CalIIsle, CumbenandCOUnty
My Convnlsslon Expirus Nov. 12. 2002
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IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms
hereof, set forth their hands and seals the day and year herein set forth.
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'-.tOri A. Ratel
COMMONWEALm OF PENNSYLVANIA : s.s.
COUNTY OF CUMBERLAND
BE IT REMEMBERED, that on this~, day of, od
2000, personally
appeared before me the Subscriber, a Notary Public for the State and County aforesaid, Lori A.
Rate! party to this Agreement, known to me personally to be such, and he acknowledged the act
of signing this Agreement
Sworn to and subscribed before me the day, month and ye
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NOTARV:":.~EA'. tv Public
D''''N .... "HUG;..""'." Nota.
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Carlis.le,Gu::,be~:n~o' 28.2002
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IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms
hereof, set forth their hands and seals the day and year herein set forth.
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Donald G. Ratel
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND : 8.S
BE IT REMEMBERED, that on this c9'3lO day of,0Q.,-m~. , 2000 personally
appeared before me the Subscriber, a Notary Public for the State and County aforesaid, Donald
G. Ratel party to this Agreement, known to me personally to be such, and she acknowledged the
act of signing this Agreement.
Sworn to and subscribed before me the day, month and year aforesaid
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NOTARIAL SEAl
JUDITH ANN VALENTINE, Notary Public
Carll$le, Cumberland CountY
My Commission expires Nov, 12, 2002
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IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms
hereof, set forth their hands and seals the day and year herein set forth.
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ori A. RateI
COMMONWEALTH OF PENNSYLVANIA : s.s.
COUNTY OF CUMBERLAND
BE IT REMEMBERED, that on this~, day of, Oc....f-.
2000, personally
appeared before me the Subscriber, a Notary Public for the State and County aforesaid, Lori A.
RateI party to this Agreement, known to me personally to be such, and he acknowledged the act
of signing this Agreement
Sworn to and subscribed before me the day, month and ye aforesaid
NOTARIAL SEAL ,
UGHART Notary Public
DAWN M. SH ' d County
Carlisle, cumbe.r\an N 28 2002
MY Commission Expires ov. ,
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DONALDRATEL
PLAINTIFF
V.
LORI A. RA TEL
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-6884 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 8th day of December, 2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Melissa P. Groevy, Esq. , the conciliator,
at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the lo<tlay of January, 2001 , 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: Isl
Melissa P. Greev 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 TIllS PAPER TO YOUR AITORNEY AT ONCE. IF YOU DO NOT
HAVE AN AITORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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DONALD RATEL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000-6884 CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
v.
LORI A. RATEL,
Defendant
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.lP.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
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
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DONALD RATEL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 2000-6884
CIVIL TERM
LORI A. RATEL,
Defendant
CIVIL ACTION-LAW
IN CUSTODY
COMPLAINT FOR CUSTODY
1. Plaintiff is Donald Ratel, an adult ,individual, currently residing at 140 A
Street, Carlisle, Cumberland County, Pennsylvania, 17013.
2. Defendant is Lori A. Ratel, an adult individual, currently residing at 931
Hamilton Street, Carlisle, Cumberland County, Pennsylvania, 17013.
3. Defendant seeks custody of the following child:
Alisha M. Ratel, age 6, born 8/31/94.
Alisha was born in wedlock.
The child is presently in de facto primary custody of Lori Rate!.
During the past five years the child has resided with the following persons at the
following addresses:
(a) From birth to the September 2000, with the parties at 140 A Street,
Carlisle, PA 17013,
(b) From September, 2000, primarily with the Mother and the maternal
Grandfather, Donald Barrick and the maternal Great Grandmother, Marie Barrick at
931 Hamilton Street, Carlisle, PA 17013.
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The natural mother of the child is Lori A. Rate\.
She is presently married but her husband has filed a no fault divorce
action.
The natural father of the children is Donald Rate\.
He is married and separated.
4. The relationship of the Defendant to the child is that of natural mother.
5. The relationship .of the Plaintiff to the child is that of natural father.
6. Defendant has participated as a party concerning the custody of the child
in this Court. The parties entered imto an agreement in reference to their child which
has not worked out as the Defendant had anticipated.
Defendant does not 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 mother has been the primary caretaker of the child since her birth
and is capable of providing the care the child needs.
(b) The Defendant supports that the Father should have regular and
frequent periods of partial custody as the parties reside close to on another.
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.
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NAME
ADDRESS
BASIS OF CLAIM
None
WHEREFORE, the Defendant requests your Honorable Court to:
A) grant primary custody of the child to the Defendant;
B) set a reasonable and realistic arrangement which will adequately
foster an ongoing relationship between the child and her Father;
C) grant such other relief as is just and in the best interest of the
Ghild.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Date: II {2.."1 ~
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Robert L. O'Brien, Esquire
17 West South Street
Carlisle, PA 17013
(717) 249-6873
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VERIFICATION
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. S 4904, relating to unsworn falsification to authorities.
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Lori A. Ratel
DATE: \\\:2.\ \co
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DONALD RATEL
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANlA
V.
No. 00-6884 Civil Action - Law
LORlA.RATEL,
Defendant.
In Custody
ORDER OF COURT
AND NOW, this 16TH day of January, 2001, the Conciliator, being advised by Plaintiffs
counsel that the parties have reached an agreement and signed a Stipulation, hereby relinquishes
jurisdiction in this case.
FOR THE CO T,
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CUM8Ei1;'AiJj COUNTY
PENNSYLVANIA
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DONALD RATEL,
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LORI A. RATEL,
AND NOW, this
Plaintiff
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000-6884 CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
ORDER OF COURT
day of
is hereby made an Order of Court.
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, 2001, the attached agreement
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DONALD RATEL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000-6884 CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
Plaintiff
v.
LORI A. RATEL,
CUSTODY AGREEMENT
The parties hereto, Lori A. Ratel and Donald Ratel, are the parents of Alisha M.
Ratel, age 6, born 8/31/94. The parties will share legal custody ofthe child so that they
both have input in major decisions regarding the child and equal access to medical,
school ete.records. The parties shall share physical custody of Alisha with Alisha being
in iMother's custody except as set forth in the following schedule. The parties, by
agreement, may vary the schedule set forth herein, Mother and Father agree that they
will not seek to change this schedule except for extraordinary circumstances. Father
agrees that his decision to work overtime hours shall not constitute extraordinary
circumstances unless the overtime is required by his employer. In the event the Father
decides to not exercise any of his times of partial custody, for whatever reason, the
parties agree that Mother shall be given the first option of caring for Alisha during that
time. If Father seeks to change the time of pick up or delivery of Alisha and it doesn't
suit Mother's schedule, Father realizes that the revised scheduling shall be directed by
Mother's schedule and not Fathers. The Father's custody schedule shall be
determined according to his current work schedule and Alisha's school schedule.
When Alisha's school schedule changes, the parties agree that they will rework this
currently agreed to schedule. Based on the current shift work, Father's schedule shall
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be:
A. Week One Schedule: During the weeks the Father works the shift
from 6:30 a.m. to 2:30 p.m., he shall have custody of Alisha from 3:30 p.m. to 8:00 p.m.
on Monday thru Thursday, and shall pick her up after school or at the Mother's
residence. Mother will pick Alisha up at Father's home at 8:00 p.m. each day. This
shall follow with Father's weekend when he shall pick Alisha up at 10:00 a.m. on
Saturday and Mother will pick her up at Father's home at 7:00 p.m, on Sunday.
D. Week Two Schedule: This week Father is off Monday thru
Wednesday. He shall pick Alisha up at 3:30 p.m. at Mother's home on Monday.
Mother will pick Alisha up at Father's home at 7:00 p.m. on Wednesday. He shall pick
her up at 8:00 a,m. on Thursday and Friday and bring her to school each day or Mother
will pick her up at 1 :30 p.m. at Father's home if it is not a school day. The following
weekend is Mother's weekend from Friday after school or 1 :30 p.m., if not a school day,
thru Monday at 8:00 a.m., and this leads into the week three schedule.
C. Week Three Schedule: During the weeks the Father works the 2:30
p.m. to 10:30 p.m. schedule he shall pick Alisha up at 8:00 a.m. at Mother's home and
bring her to school, Monday thru Friday, if it is a school day. If it is not a school day
Mother will pick up Alisha at Father's home at 1 :30 p.m. The following weekend is
Mother's weekend and Mother shall have Alisha from after school Friday, or from 1 :30
p.m., if not a school day, thru Monday at 4:00 p.m. This leads into the week four
schedule.
D. Week Four Schedule: During the weeks the Father works the shift
from 10:30 p.m. to 6:30 a.m. the Father shall have custody of Alisha from 4:00 p.m. to
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8:00 p.m. on Monday thru Thursday. He shall have a weekend of custody that shall
begin at 10:00 a.m. on Saturday and continue thru 7:00 p.m. Sunday. The parties will
share transportation this week.
E. The holidays and vacation shall be as follows:
Every Mothers day with Mother and Father's day with Father, irrespective
of the weekend schedule, from 9:00 a.m, thru 5:00 p.m.
If it is not the parent's weekend when Easter falls, that parent shall have
Alisha from 1 :00 p.m. thru 5:00 p.m., irrespective of the weekend schedule.
Every Memorial day with Mother from 8:00 a.m. until 3:30 p.m., and the
weekly schedule shall control the morning time and the return time, for example, in
2001 it is Father's week two schedule so Alisha will have spent Sunday evening with
her Mother and when Father picks her up at 3:30, he shall keep her thru Wednesday at
7:00 p.m.
In odd numbered years Alisha shall spend July 4th with Father from 8:00 a.m.
thru 1 :30 p.m., with the regular weekly schedule dictating the prior evening and the
Mother having Alisha from 1 :30 p.m. thru the fireworks presentation, if it is the Father's
evening. In even numbered years Father shall have Alisha from 1 :30 p.m. thru the end
of the fireworks presentation, if it is the Mother's evening.
Labor Day will be spent with the Mother in odd numbered years and with Father
in even numbered years from 9:00 a.m. thru 4:00 p.m., irrespective of the weekly
schedule.
Thanksgiving with Father from 8:00 a.m. thru 4:00 p.m., irrespective of the
weekly schedule.
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With Mother on Christmas eve from 6:00 p.m. to 12.00 noon on Christmas day
and Father from 12:00 noon to 5:00 p.m., irrespective of the weekly schedule.
Each parent shall have two non consecutive weeks of vacation. They shall
arrange their weeks to include one of their scheduled weekends and a week shall be
from Friday evening to Saturday at noon. The parties will discuss and arrange the
vacation schedule on or before April 1 each year.
F. Father will arrange within seven days of the signing of this agreement to
furnish a room for Alisha in his home for the time she spends with him. He agrees it is
not appropriate for her to sleep on a couch.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have
hereunto set their hands and seals the day and year first above written.
WITNESS:
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
AND NOW, this f''t.'lday ofSa,.,0.4QN, 2001, before me, the undersigned
officer, personally appeared Donald Ratel known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that
he executed same for the purposes therein contained.
55.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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Not ry Public
Notanal seal
An!Iela F. Unger, Notary Public
CarlISle Bora, Cumberland Co1Jl!lY
My Commission Expires Oct. 7, ZlIll4
Member, PermsyivaniaAssoclattonOfNlllllilll
COMMONWEALTH OF PENNSYLVANIA
55.
COUNTY OF CUMBERLAND
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AND NOW, this F day ofJ'<Illuq,,/, 2001, before me, the undersigned
officer, personally appeared Lori A. Ratel, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that
she executed same for the purposes therein contained.
IN WITNESS WHEREOF. I hereunto set my hand and official seal.
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An\lela F. Unger, Notary Public
CarlISle Bora, Cumberiand County
My CommIssIOn Expires Oct, 7, 2004
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DONALD RATEL,
v.
LORI A. RATEL,
AND NOW, this
Plaintiff
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000-6884 CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
ORDER OF COURT
day of
is hereby made an Order of Court.
, 2001, the attached agreement
BY THE COURT,
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DONALD RATEL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000-6884 CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
Plaintiff
v.
LORI A. RATEL,
CUSTODY AGREEMENT
The parties hereto, Lori A. Ratel and Donald Ratel, are the parents of Alisha M.
Rater. age 6, born 8131194. The parties will share legal custody of the child so that they
both have input in major decisions regarding the child and equal access to medical,
school etc. records. The parties shall share physical custody of Alisha with Alisha being
in MG,ther's custody except as set forth in the fOllowing schedule. The parties, by
agreement, may vary the schedule set forth herein. Mother and Father agree that they
will not seek to change this schedule except for extraordinary circumstances. Father
agrees that his decision to work overtime hours shall not constitute extraordinary
circumstances unless the overtime is required by his employer. In the event the Father
decides to not exercise any of his times of partial custody, for whatever reason, the
parties agree that Mother shall be given the first option of caring for Alisha during that
time. If Father seeks to change the time of piCk up or delivery of Alisha and it doesn't
suit Mother's schedule, Father realizes that the revised scheduling shall be directed by
Mother's schedule and not Fathers. The Father's custody schedule shall be
determined according to his current work schedule and Alisha's school schedule.
When Alisha's school schedule changes, the parties agree that they will rework this
currently agreed to schedule. Based on the current shift work, Father's schedule shall
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A. Week One Schedule: During the weeks the Father works the shift
from 6:30 a.m. to 2:30 p.m., he shall have custody of Alisha from 3:30 p.m. to 8:00 p.m.
on Monday thru Thursday, and shall pick her up after school or at the Mother's
residence. Mother will pick Alisha up at Father's home at 8:00 p.m. each day. This
shall follow with Father's weekend when he shall pick Alisha up at 10:00 a.m. on
Saturday and Mother will pick her up at Father's home at 7:00 p.m. on Sunday.
D. Week Two Schedule: This week Father is off Monday thru
Wednesday. He shall pick Alisha up at 3:30 p.m. at Mother's home on Monday.
Mother will' pick Alisha up at Father's home at 7:00 p.m. on Wednesday. He shall pick
her up at 8:00 a.m, on Thursday and Friday and bring her to school each day or Mother
will pick her up at 1 :30 p.m. at Father's home if it is not a school day. The following
weekend is Mother's weekend from Friday after school or 1 :30 p.m., if not a school day,
thru Monday at 8:00 a.m., and this leads into the week three schedule.
C. Week Three Schedule: During the weeks the Father works the 2:30
p.m. to 10:30 p.m. schedule he shall pick Alisha up at 8:00 a.m. at Mother's home and
bring her to school, Monday thru Friday, if it is a school day. If it is not a school day
Mother will pick up Alisha at Father's home at 1 :30 p.m. The following weekend is
Mother's weekend and Mother shall have Alisha from after school Friday, or from 1 :30
p.m., if not a school day, thru Monday at 4:00 p.m. This leads into the week four
schedule.
D. Week Four Schedule: During the weeks the Father works the shift
from 10:30 p.m. to 6:30 a.m. the Father shall have custody of Alisha from 4:00 p.m. to
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8:00' p.m. on Monday thru Thursday. He shall have a weekend of custody that shall
begin at 10:00 a.m. on Saturday and continue thru 7:00 p.m. Sunday. The parties will
share transportation this week,
E. The holidays and vacation shall be as follows:
Every Mothers day with Mother and Father's day with Father, irrespective
of the weekend schedule, from 9:00 a.m. thru 5:00 p.m,
If it is not the parent's weekend when Easter falls, that parent shall have
Alisha from 1 :00 p.m. thru 5:00 p.m., irrespective of the weekend schedule.
Every Memorial day with Mother from 8:00 a.m. until 3:30 p.m., and the
weekly schedule shall control the morning time and the return time, for example, in
2001 it is Father's week two schedule so Alisha will have spent Sunday evening with
her Mother and when Father picks her up at 3:30, he shall keep her thru Wednesday at
7:00 p.m.
In odd numbered years Alisha shall spend July 4th with Father from 8:00 a.m.
thru 1 :30 p.m., with the regular weekly schedule dictating the prior evening and the
Mother having Alisha from 1 :30 p.m. thru the fireworks presentation, if it is the Father's
evening. In even numbered years Father shall have Alisha from 1 :30 p.m. thru the end
of the fireworks presentation, if it is the Mother's evening.
Labor Day will be spent with the Mother in odd numbered years and with Father
in even numbered years from 9:00 a.m. thru 4:00 p.m., irrespective ofthe weekly
schedule.
Thanksgiving with Father from 8:00 a.m. thru 4:00 p.m., irrespective of the
weekly schedule.
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With Mother on Christmas eve from 6:00 p.m. to 12.00 noon on Christmas day
and Father from 12:00 noon to 5:00 p.m., irrespective of the weekly schedule.
Each parent shall have two non consecutive weeks of vacation. They shall
arrange their weeks to include one of their scheduled weekends and a week shall be
from Friday evening to Saturday at noon. The parties will discuss and arrange the
vacation schedule on or before April 1 each year.
F. Father will arrange within seven days of the signing of this agreement to
furnish a room for Alisha in his home for the time she spends with him. He agrees it is
not appropriate for her to sleep on a couch.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have
hereunto set their hands and seall; the day and year first above written.
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WITNESS:
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AND NOW, this f day ofJQ;oL{4ry, 2001, before me, the undersigned
officer, personally appeared Donald Rate! known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that
he executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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Not ry Public
Notarial Seal
~ F. Unger, Notary PUblic.
CartISkl 8oro, CUmbertand COul)lY
My CommIssion Elqlires Oct. 7, :I.OIl4
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COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF CUMBERLAND
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AND NOW, this P day of J'QIlUt:lf'l, 2001, before me, the undersigned
officer, personally appeared Lori A. Ratel, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that
she executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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DONALD RATEL,
v.
LORI A. RATEL,
AND NOW, this
Plaintiff
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.2000-6884 CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
ORDER OF COURT
day of
is hereby made an Order of Court.
, 2001, the attached agreement
BY THE COURT,
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DONALD RATEL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF '
CUMBERLAND COUNTY, PENNSYLVANIA
NO.2000-6884 CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
v.
LORI A. RATEL,
Defendant
CUSTODY AGREEMENT
The parties hereto, Lori A. Ratel and Donald Ratel, are the parents of Alisha M.
Ratel, age 6, born 8/31/94. The parties will share legal custody of the child so that they
both have ;input in major decisions regarding the child and equal access to medical,
school etc; records. The parties shall share physical custody of Alisha with Alisha being
in Mother's custody except as set forth in the following schedule. The parties, by
agreement, may vary the schedule set forth herein. Mother and Father agree that they
will not seek to change this schedule except for extraordinary circumstances. Father
agrees that his decision to work overtime hours shall not constitute extraordinary
circumstances unless the overtime is required by his employer. In the event the Father
decides to not exercise any of his times of partial custody, for whatever reason, the
parties agree that Mother shall be given the first option of caring for Alisha during that
time. If Father seeks to change the time of pick up or delivery of Alisha and it doesn't
suit Mother's schedule, Father realizes that the revised scheduling shall be directed by
Mother's schedule and not Fathers. The Father's custody schedule shall be
determined according to his current work schedule and Alisha's school schedule.
When Alisha's school schedule changes, the parties agree that they will rework this
currently agreed to schedule. Based on the current shift work, Father's schedule shall
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be:
A. Week One Schedule: During the weeks the Father works the shift
from 6:30 a.m. to 2:30 p.m., he shall have custody of Alisha from 3:30 p.m. to 8:00 p.rn.
on Monday thru Thursday. and shall pick her up after school or at the Mother's
residence. Mother will pick Alisha up at Father's home at 8:00 p.m. each day. This
shall follow with Father's weekend when he shall pick Alisha up at 10:00 a.m. on
Saturday and Mother will pick her up at Father's home at 7:00 p.m. on Sunday.
D. Week Two Schedule: This week Father is off Monday thru
Wednesday. He shall pick Alisha up at 3:30 p.m. at Mother's home on Monday.
Mother will pick Alisha up at Father's home at 7:00 p.m. on Wednesday. He shall pick
her up at 8:00 a.m. on Thursday and Friday and bring her to school each day or Mother
will pick her up at 1:30 p.m. at Father's home if it is not a school day. The following
weekend is Mother's weekend from Friday after school or 1 :30 p.m., if not a school day,
thru Monday at 8:00 a.m., and this leads into the week three schedule.
C. Week Three Schedule: During the weeks the Father works the 2:30
p.m. to 10:30 p.m. schedule he shall piCk Alisha up at 8:00 a.m. at Mother's home and
bring her to school, Monday thru Friday, if it is a school day. If it is not a school day
Mother will pick up Alisha at Father's home at 1 :30 p.m. The following weekend is
Mother's weekend and Mother shall have Alisha from after school Friday, or from 1 :30
p.m., if not a school day, thru Monday at 4:00 p.m. This leads into the week four
schedule.
D. Week Four Schedule: During the weeks the Father works the shift
from 10:30 p.m. to 6:30 a.m. the Father shall have custody of Alisha from 4:00 p.m. to
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8:00 p.m. on Monday thru Thursday. He shall have a weekend of custody that shall'
begin at 10:00 a.m. on Saturday and continue thru 7:00 p.m. Sunday. The parties will
share transportation this week.
E. The holidays and vacation shall be as follows:
Every Mothers day with Mother and Father's day with Father, irrespective
of the weekend schedule, from 9:00 a.m. thru 5:00 p.m.
If it is not the parent's weekend when Easter falls, that parent shall have
Alisha from 1 :00 p.m. thru 5:00 p.m., irrespective of the weekend schedule.
Every Memorial day with Mother from 8:00 a.m. until 3:30 p.m., and the
weekly schedule shall control the morning time and the return time, for example, in
2001 it is Father's week two schedule so Alisha will have spent Sunday evening with
her Mother and when Father picks her up at 3:30, he shall keep her thru Wednesday at
7:00 p.m.
In odd numbered years Alisha shall spend July 4th with Father from 8:00 a.m.
thru 1 :30 p.m., with the regular weekly schedule dictating the prior evening and the
Mother having Alisha from 1 :30 p.m. thru the fireworks presentation, if it is the Father's
evening. In even numbered years Father shall have Alisha from 1 :30 p.m. thru the end
of the fireworks presentation, if it is the Mother's evening.
Labor Day will be spent with the Mother in odd numbered years and with Father
in even numbered years from 9:00 a.m. thru 4:00 p.m., irrespective of the weekly
schedule.
Thanksgiving with Father from 8:00 a.m. thru 4:00 p.m., irrespective of the
weekly schedule.
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With Mother on Christmas eve from 6:00 p.m. to 12.00 noon on Christmas day
and Father from 12:00 noon to 5:00 p.m., irrespective of the weekly schedule.
Each parent shall have two non consecutive weeks of vacation. They shall
arrange their weeks to include one of their scheduled weekends and a week shall be
from Friday evening to Saturday at noon. The parties will discuss and arrange the
vacation schedule on or before April 1 each year.
F. Father will arrange within seven days of the signing of this agreement to
furnish a room for Alisha in his home for the time she spends with him. He agrees it is
not appropriate for her to sleep on a couch.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have
hereunto set their hands and seals the day and year first above written.
WITNESS:
(SEAL)
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Lori A. Ratel
(SEAL)
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COMMONWEALTH OF PENNSYLVANIA
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AND NOW, this f day ofS""..wy, 2001, before me, the undersigned
officer, personally appeared Donald Ratel known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within iDstrument, and acknowledged that
he executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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Not ry Public
NOtalialSeal
~ F. Unger, N.OtaTy Public
CarlISle BolO, CUmberland CoUOlY
My CommIsSion Expires Oct. 7, 201M
Member, PeMSytveniaAssocia\1QnOl__
COMMONWEALTH OF PENNSYLVANIA
: SS.
COUNTY OF CUMBERLAND
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AND NOW, this P day ofJ"/Iluq,'f' 2001, before me, the undersigned
officer, personally appeared Lori A. Ratel, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that
she executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
~~&--
NOIaIial Seal
An!Iela F. Unger NOtaTy Public
C8JIliIe IIOro, cumooriarid County
My CQIrimIssloit Expires Oct. 7, 2004
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DONALD RATEL
PLAINTIFF
: COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
V.
: NO, 2000-6884 CIVIL TERM
LORI A. RATEL
DEFENDANT
: CIVIL ACTION-LAW
: IN CUSTODY
PRAECIPE TO WITHDRAW APPEARANCE
Please withdraw my appearance on behalf of Defendant, Lori A. Ratel (Barrick).
jo
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Robert L O'Brien, Esquire
PRAECIPE TO ENTER APPEARANCE
Please enter my appearance on behalf of Defendant, Lori A< Ratel (Barrick).
Law Office of James K. Jones, Esquire
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Dirk E. Berry, Esquire
7 Irvine Row
Carlisle, PA 17013
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DONALD RATEL
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2000-6884 CIVIL TERM
LORI A. RATEL (BARRICK)
Defendant
: CIVIL ACTION--LA W
: CUSTODY
CERTIFICATE OF SERVICE
I, Dirk E. Berry, Esquire, do hereby certifY that on this day Defendant's Petition for
Modification of a Partial Custody or Visitation Order was served by first class mail upon the
following persons:
Lee E. Oesterling, Esquire
Hazlett & Oesterling
22 South Market Street
Mechanicsburg, P A 17055
Date:
7-(t - 01
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Attorney for Plaint~ff
7 Irvine Row
Carlisle,PA 17013
(717) 240-0296
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DONALD RATEL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6884
vs.
LORI A. RA TEL,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
Hess, J. -
AND NOW, this z r- . day of September, 2001, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Legal Custody. The parties, Donald Ratel and Lori A. Ratel, shall have shared leglal
custody of the minor Child, Alisha M. Ratel, born August 31, 1994. 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. 95309, 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. Both parents shall be entitled to full participation in all educational and
medical/treatment planning meetings and evaluations with regard to the minor Child. Each
parent shall be entitled to full and complete information from any physician, dentist, teacher or
authority and copies of any reports given to them as parents including, but not limited to:
medical records, birth certificates, school or educational records, attendance records or report
cards. Additionally, each parent shall be entitled to receive copies of any notices which come
from school with regard to school pictures, extracurricular activities, children's parties, musical
pr~sentations, back-to-school night, and the like.
2. Physical Custody. Physical custody shall be shared by the parties as follows:
A. Effective September 18, 2001, Father shall have custody on Tuesdays
and Thursdays from 6:30 p.m. until 8:00 p.m. the weeks following his
custodial weekends.
B. Effective September 24, 2001, Father shall have custody on Mondays and
Wednesdays from 6:30 p.m. until 8:00 p.m. preceding his custodial
weekend.
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No. 00-6884 Civil Term
C. Effective September 28, 2001, Father shall have physical custody on
alternate weekends from Friday at 6:30 p.m. until Sunday at 7:00 p.m. In
the event that the Child is having substantial difficulty with tolerating
separation from Mother for the entire custodial period, Father shall have
the option of returning the Child to Mother to sleep at Mother'shome
during part of his custodial weekends.
D. Father shall have custody at other such times as the parties may agree.
E. At such times as the Child is not in the custody of Father, the Child shall
be in the custody of Mother.
3. Holidays. Holidays shall be arranged as follows:
A. Mother's Day/Father's Day. Each Mother's Day shall be with Mother and
each Father's Day shall be with Father, irrespective of the weekend
schedule. The custodial period for Mother's Day and Father's Day shall
be from 9:00 a.m. until 5:00 p.m.
B. Easter. If it is not the parent's weekend when Easter falls, that parent
shall have Alisha from 1 :00 p.m. through 5:00 p.m., irrespective of the
weekend schedule.
C. Memorial Day. Every Memorial Day shall be with Mother from 8:00 a.m.
until 3:30 p.m.
D. Independence Day. In odd-numbered years Father shall have custody
and in even-numbered years Mother shall have custody. The custodial
time for Independence Day shall be from July 4th at 8:00 a.m. until July 5th
at 8:00 a.m.
E. Labor Day. Labor Day shall be with Mother in odd-numbered years and
with Father in even-numbered years. The period of custody for Labor Day
shall be from 9:00 a.m. until 5:00 p.m., irrespective of the weekly
schedule.
F. Thanksgiving. Thanksgiving shall be with Father from 9:00 a.m. until 4:00
p.m., irrespective of the weekend schedule.
G. Christmas. Mother shall have custody from Christmas Eve at 6:00 p.m.
until Noon Christmas Day. Father shall have custody from Noon
Christmas Day until 5:00 p.m., irrespective of the weekly schedule.
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No. 00-6884 Civil Term
4. Vacation. Each parent shall have two non-consecutive weeks of vacation and shall
arrange their weeks to include one of their scheduled weekends. A week shall be defined to
be from Friday evening to Saturday at Noon.
5. In the event either party is unavailable to provide care for the Child for a period of
four hours or more during his or her period of custody, such as when Father is called into work
on his custodial weekend, that party shall first make a reasonable effort to contact the other
party to offer the parent the opportunity to provide care for the Child before contacting third-
party caregivers.
6. Transportation. The parties shall share transportation with the parent who is
beginning their period of custody providing the transportation incident to the custodial
exchange.
BY THE COURT,
;1L
Dist:
Donald Ratel, 151 W. Middlesex Drive, Carlisle, PA 17013
James K. Jones, Esquire, 7 Irvine Row, Carlisle, PA 17013.3019 . ~
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DONALD RA TEL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6884
vs.
LORI A. RA TEL,
Defendant
CIVIL ACTION - LAW
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 or
Alisha M. Ratel
August 31, 1994
Mother
2. A Custody Conciliation Conference was held on September 18, 2001, with the
following individuals in attendance: the Father, Donald Ratel, pro se; the Mother, Lori A. Rate,I,
and her counsel, James K. Jones, Esquire.
3. The parties reached an agreement in the form of an Order as attached.
~l>//)l
Ii sa Peel Greevy, Esquire
Custody Conciliator
Date