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HomeMy WebLinkAbout00-07823 . BRIAN C. COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW SHELLEY R. COYLE, Defendant NO. 00-7823 CIVIL TERM ORDER OF COURT AND NOW, this 6th day of November, 2000, upon consideration of Plaintiffs Motion for Special Relief, following a conference in chambers in which Plaintiff was represented by Taylor P. Andrews, Esq., and Defendant was represented by Thomas Diehl, Esq., and pursuant to an agreement of counsel, it is ordered and directed as follows: 1. Neither party shall remove the parties' child, Amanda M. Coyle (d.o.b. June 17, 1990), from the jurisdiction ofthe court. 2. The Court Administrator is requested to expedite the scheduling of the custody conciliation conference on Plaintiffs complaint so that the conference is held within the next 30 days. BY THE COURT, ,[J. ~ t~'$'OO , ~K~ J Taylor P. Andrews, Esq. 78 West Pomfret Street Carlisle, PA 17013 Attorney for Plaintiff Thomas Diehl, Esq. I West High Street Suite 208 Carlisle, PA 17013 Attorney for Defendant '''''-' " '_~_O: ,-" - - .__~ e". , , . !"IO\iIlIO!QU~_ijlliIJ*,~~~~ L -Hill' 1"'"''''I!ii'!il;':!!\l~;;!~IllilIr.itIiJ?ili.l-~<itUi~'rIt J ~ '~~:'-' ~,(,,- I'"~ ---.:~;.-",\....''v_''''l\ .\\ \ ',,:S)"':::~;,:';;~y\)\r"" Q 7" ('\- ~- .. \ ~ -. \,\'i . II ~ \ . l\'l 00 \\\1". f"O\)~ ;j\J 1""':"\\ \.-i 1\ _,'0'))1'" 'l,~\r' ,,;,-,y\ I (':"{0- OS~\?t~'\-\';) -~, "e;!~-' ~'''''iAl ~ ~, II 11 I" ,'I II I: I I " I J , r II ~j ~I ',1 ,I " ~ ! I i I \ i I --', c ~ Court Administrator .- h M J / / -7 -Of) i1-<:./' :rc ^ ,,-,' -" ~~ BRIAN C. COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : CUSTODYNISITATION : NO. 00- 7'8?- 3 CIVIL TERM SHELLEY R. COYLE, Defendant ORDER AND NOW this day of November, 2000, in consideration of the attached Motion for Special Relief seeking an order of temporary custody for the Plaintiff until the conciliation conference, it is hereby ordered as follows: Legal custody of Amanda M. Coyle, age 10 shall be shared by Plaintiff, Brian Coyle and Defendant, Shelley R. Coyle; Pending the conciliation conference, primary physical custody of Amanda M. Coyle is awarded to Plaintiff, Brian Coyle subject to partial custody by Defendant, Shelley R. Coyle on alternate weekends from Friday evening until Sunday evening, and on two weekday evenings per week, to be selected by Defendant, Shelley R. Coyle, with 48 hours notice to Plaintiff. This partial custody shall be expanded by mutual consent of the parties. BY THE COURT: J. 'i'-!:",.,."," 1~_--.-',," , , -, " BRIAN C. COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : CUSTODY!VISITATION : NO. 00- {BZ3 CIVIL TERM SHELLEY R. COYLE, Defendant MOTION FOR SPECIAL RELIEF FOR TEMPORARY CUSTODY WITH LffiERAL PARTIAL CUSTODY PENDING THE CONCILIATION CONFERENCE Plaintiff, Brian C. Coyle, through his counsel, Taylor P. Andrews, Esq. respectfully represents as follows: 1. Plaintiff has filed a Complaint for Custody the same date that this motion is filed. A copy of the Custody Complaint is attached hereto for convenient reference as Exhibit 1. 2. Plaintiff hereby incorporates all the averments of his Custody Complaint herein by reference. 3. The subject of this custody proceeding is Amanda M. Coyle, date of birth, 6/17/90 [10 years and 5 months of age], hereinafter referenced as Amanda. 4. For the past five weeks Defendant, Shelley R. Coyle, has been receiving treatment for severe depression at the Holy Spirit Hospital. This treatment has entailed medication and attendance at the daytime partial hospitalization program. The treatment is expected to extend for several more weeks. 5. Defendant's illness has impaired her ability to provide care for Amanda. 6. Plaintiff seeks custody of Amanda, and by this Motion seeks to maintain the status quo pending the conciliation conference on Plaintiffs complaint. OIl,_ _ __,~ ",_, ,-",t:,,'O-"~'" '~"f,' .y, ,,_,__',_ ,-,.."". , , '" 7. Plaintiff has been the primary provider of care for Amanda since the onset of Defendant's depression. 8. Plaintiff agrees that Defendant shall have liberal partial physical custody of Amanda pending the conciliation conference. 9. Plaintiff seeks to avoid conflict between the parties involving custody of Amanda pending the conciliation conference. Such conflict would traumatize Amanda and possibly interfere with her consistent enrollment in her 5th grade class in the South Middleton School District. WHEREFORE, Plaintiff prays your Honorable Court to temporarily award primary physical custody of Amanda M. Coyle to Plaintiff, Brian C. Coyle, with liberal partial custody by Defendant, Shelley R. Coyle, which shall be alternate weekends and two evenings per week and such other times as the parties shall agree. Respectfully submitted, ANDREWS & JOHNSON r P. drews, Esquire ey for Plaintiff est Pomfret Street Carlisle, P A 17013 Telephone: (717) 243-0123 Supreme Court ID No. 15641 By: ~ - ^ ~~- J _,,~, ~ .,~ " , , COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. DATE: /FZ~()o &,uc. 4<- Brian C. Coyle, Plaintiff .'^ _",7'<__,. " ,,--, .--'"Z"--- ," Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA BRIAN C. COYLE, v. : CIVIL ACTION - LAW : CUSTODYNISITATION SHELLEY R. COYLE, Defendant : NO. 00- CIVIL TERM ORDER OF COURT AND NOW, , 20-, 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 o'clock, _om., 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 1HE COURT: By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE 1HE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 EXHIBIT b " D a / -,jo.., ,,~ -,~~- ~~ '1 ~,- ,~ BRIAN C. COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : CUSTODYNISITATION SHELLEY R. COYLE, Defendant : NO. 00- CIVIL TERM COMPLAINT FOR CUSTODY I. The Plaintiff is Brian C. Coyle, residing at 702 Sandbank Road, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. The Defendant Shelley R. Coyle currently resides at 702 Sandbank Road, Mt. Holly Springs, but she has signed a lease and announced her intention to move on the weekend of November 4th to Hill Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 3. Plaintiff seeks custody of the following child: NAME RESIDENCE DOB AGE Amanda M. Coyle 702 Sandbank Road Mt. Holly Springs, P A 17065 June 17, 1990 10 yrs 5 months The child was not born out of wedlock. The child is presently in the custody of Brian C. Coyle. During her life, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATES Brian C. Coyle and ShelleyR. Coyle 13 Butler Street Mt. Holly Springs, P A 17065 June 17, 1990 to December 1997 -.~,-,c~ ~ ~ , Brian C. Coyle and Shelley R. Coyle 702 Sandbank Road Mt. Holly Springs, P A 17065 December 1997 to present The mother of the child is Shelley R. Coyle. See paragraph number 2 above for her address. She is married. The father of the child is Brian C. Coyle, currently residing at 702 Sandbank Road, Mt.Holly Springs, Pennsylvania. He is married, 4. The relationship of the Plaintiff to the child is that of Father. The Plaintiff currently resides with the following persons: Amanda M. Coyle, daughter 5. The relationship of the Defendant to the child is that of Mother. The Defendant will reside with the following persons at her new residence: NONE 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concernillg the custody of the child in this or another court. Plaintiff ha$ no information of a custody proceeding concerning the child pending in ~urt of this Commonwealth. Plaintiff 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 for the following reasons: A. Plaintiff is best able to provide the care and nurture which the child needs for healthy development; and B. Defendant is currently suffering from severe depression and her ability to exer~ise custody is impaired; and C. Mother has moved to a different school district from that which the child has attended since the 2"d grade. ''''"''''^,,'f'f.,. -P"!",,A,^,," . n ~..,..., ~ .- 8. Each parent whose parental rights to the child have not been tenninated and the person who has physical custody of the child have been named as parties to this action. 9. Plaintiff continues to maintain the family household for the child that has been maintained since December 1997. The Defendant is moving from the family residence into an apartment in Mt. Holly Springs, Pennsylvania. WHEREFORE, Plaintiff requests the Court to grant custody of the child to Plaintiff subject to partial custody by the Defendant Respectfully submitted, ANDREWS & JOHNSON By: I r P. Ari ews, Esquire ey for Plaintiff est Pomfret Street Carlisle, P A 17013 Telephone: (717) 243-0123 Supreme Court ID No. 15641 ~"--,:-,~;'"".,,^ ...,. ~ COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I verifY that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, ~4904, relating to unsworn falsification to authorities. DATE: IfZ~() 0 ~c;;e~ '''.F''''l-~ ~ l-- ~ BRIAN C. COYLE PLAINTIFF V. SHELLEY R. COYLE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-7823 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 8th day of November, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Snnday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on the 29th day of November ,2000, at 9:30 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme 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 Dawn S. Sunday.~ Custody Conclha ' r The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,_\-).-;~ --~<""',"-"' " 1~1~;~-' lBlt_~!t..<tlli~.mi~,""",..,*'~'''''''''''-''',,'''' _".i0-"!ci>l'";';'''-'''J.;"ob':i,11>7",,--;;,..iIL~~~I~'~''''~ "' ~_~~ill~~~ ~-' ~""'_.. ~-~~~"., ('1C -p l~'1 ~ . "_Ii cr, ~,-- ,,'~~C-L"-! \LLI(\~ ::':: ["':'o"-':;}': '....'::. ,';' ,,;~rIW'T'DY "-"',',.)ii--ill ,-n uu NOli -p C)"l ~ , ~\ I, ., OQ .. ..J- '. CUu",-,~" H'lwc::Hl2.:\1"" r-,r , " ,U L,uU' ITV PENN8YLVANL1\ N. jlfCM w'~~~~~ 9-4 ~ - /{{-t'tJ ~)U~ -~' ~~ " ~ - . Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA BRIAN C. COYLE, v. : CIVIL ACTION - LAW : CUSTODYNISITATION SHELLEY R. COYLE, Defendant : NO. OO-~..I3 CIVIL TERM ORDER OF COURT AND NOW, ,20_, 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 o'clock, .m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temponrry order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 Phone: (717) 249-3166 I" ~". ' ,'" -,': ^- ~t'-, .", " _ <'" <, ~" Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA BRIAN C. COYLE, v. : CIVIL ACTION - LAW : CUSTODYNISITATION : NO. 00- 1 r:l.3 CIVIL TERM SHELLEY R. COYLE, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Brian C. Coyle, residing at 702 Sandbank Road, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. The Defendant Shelley R. Coyle currently resides at 702 Sandbank Road, Mt. Holly Springs, but she has signed a lease and announced her intention to move on the weekend of November 4th to Hill Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 3. Plaintiff seeks custody of the following child: NAME RESIDENCE DOB AGE Amanda M. Coyle 702 Sandbank Road Mt. Holly Springs, P A 17065 June 17, 1990 10 yrs 5 months The child was not born out of wedlock. The child is presently in the custody of Brian C. Coyle. During her life, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATES Brian C. Coyle and Shelley R. Coyle 13 Butler Street Mt. Holly Springs, P A 17065 June 17, 1990 to December 1997 ''''"'l "-., ",~ , ~c_ " Brian C. Coyle and Shelley R. Coyle 702 Sandbank Road Mt. Holly Springs, P A 17065 December 1997 to present The mother of the child is Shelley R. Coyle. See paragraph number 2 above for her address. She is married. The father of the child is Brian C. Coyle, currently residing at 702 Sandbank Road, Mt. Holly Springs, Pennsylvania. He is married. 4. The relationship of the Plaintiffto the child is that of Father. The Plaintiff currently resides with the following persons: Amanda M. Coyle, daughter 5. The relationship ofthe Defendant to the child is that of Mother. The Defendant will reside with the following persons at her new residence: NONE 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a4urt of this Commonwealth. Plaintiff 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 for the following reasons: A. Plaintiff is best able to provide the care and nurture which the child needs for healthy development; and B. Defendant is currently suffering from severe depression and her ability to exercise custody is impaired; and C. Mother has moved to a different school district from that which the child has attended since the 2nd grade. "o,U_l!"",,, ",', - "-~ -,'"' -~~i,. . . , .~ - 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. 9. Plaintiff continues to maintain the family household for the child that has been maintained since December 1997. The Defendant is moving from the family residence into an apartment in Mt. Holly Springs, Pennsylvania. WHEREFORE, Plaintiff requests the Court to grant custody of the child to Plaintiff subject to partial custody by the Defendant Respectfully submitted, ANDREWS & JOHNSON By: T I r P. Ari ews, Esquire t ney for Plaintiff est Pomfret Street Carlisle, P A 17013 Telephone: (717) 243-0123 Supreme Court ID No. 15641 '<+,*,Uj,-4f1 ~, '1'-' -'"-". " -~ - I' . '.r COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. DATE: IlZ~() 0 ~c:~e~ ')'$\' .,-- -'-,' ~,' -, -. "_"J,_ ,>- 1- ~" -Brl' Cth Shelky c. Coy~( -p!ctt",-k In the Court of Common Pleas of Cumberland County, Pennsylvania vo. 1<. CoyJe J~~a,v.t '7 6 ~ 3 Civilri<T drYJO T", Cu~J,-/ ( No. fleuie._ \n~{f eiA,..(..--er l^^-\./ rbt~ +2,~ J.eJLci~",'{) ~d(-ev~. Covlp, ( t I ~O\N'4, S Dl'e--k ( I LA) { f-~~ sf-. {Yo ~ox: [;;)0[) (thr !ls,,{,f PA (7u{ "\ Cr;/7) :;)4D- 08:33 To AJ()J-lvt.hr {;;;; '1 v, 'c """ ~ - ,_. - -, ~ Prothonotary ahfJufl '!9'-':)09D 1 ---rJ.. (Y"\uJ. S:, .D CC- Attorney for f'~H."If ~e~JlA,,^,1- 11 I ~- ~. 'M ~<<.. "" ~'^' ~",,,,-,,,,,,,,,<,,-,~",,,O''''''''''r '.i'~'-r~lSn(1I1~'"-O-1n~":-~'-'~'''];nj;ijf';i FILED--OfFICE OF 1LJr' ['!J('!T'-'(')I~ln~IARY .I,L" i 'I.. I _ ../ I No, Term, 19 _ 00 tWV - 6 Pt1 2: l. 7 CUMBEFiLAND COUi~TY PENNSYLVAI~IA VS. PRAECIPE Filed 19 , Atty. 1 ~.,~ ~~""',,~ ~1fiIlil'~1'Qffl';E,_". ., ~-~-"_"_"""",,,,~\!!,_~_r;'Illl'l',i~Il\l-"~'~~,;'JiJ'~~.l'~~"T ~,' '~~,1fI\I~~~,,~~,!'!.J\.J , BRl:AN C. COYLE, : IN THE COURT OF COMMON PLEAS OF plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-7823 CIVIL TERM . . . SHELLEY R. COYLE, : CIVIL ACTION - LAW Defendant . IN CUSTODY . ORDER OF COORT AND lOl, this~ tl consideration of the attached and directed as follows: day of CUstody :pc (:(!.-, f ..x-) Conciliation Report, , 2000, upon it is ordered 1. The prior order of this Court dated November 6, 2000, is vacated and replaced with this order. 2. The Father, Brian C. Coyle, and the Mother, Shelley R. Coyle, shall have shared legal custody of Amanda M. Coyle, born June 17, 1990. 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. 3. The parties shall have physical custody of the Child in accordance with the following schedule: A. The Mother shall have custody of the Child on alternating weekends from Friday after school through Sunday at 7:00 p.m., beginning Friday, December 1, 2000. B. The Mother shall also have custody of the Child every week on two weekdays from after school until 8:30 p.m. The Mother' s weekday periods of custody shall take place on Mondays and Wednesdays unless the Mother provides reasonable advance notice to the Father of her selection of alternative days. C. The Father shall have custody of the Child at all times not otherwise specified for the Mother in this Order. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. CHRISTMAS: In even numbered years, the Father shall have custody of the Child from Christmas Eve at 1:00 p.m. through Christmas Day at 1:00 p.m. and the Mother shall have custody from Christmas Day at 1:00 p.m. through the evening before school resumes after the holiday at 7:00 p.m. In odd numbered years, the Mother shall have custody of the Child :r "_.40 -i i#~wiW1Jllj'I~~i.'~,"k110-_-l1l,i~51\.~,,.,~'1ia-\l,,,,,,,,,.1;,,,,;,,,,"''''''''''J;1;,;;'';';i!l\~$1.1.'!~"~~_.~'m~,,[UlIIlli~~$t~""'~'1I _jlfll.t~. "<p=-:",- -~ ''"'''~~IiIIIi''fl FiLED-OFFKlE O~ '" I~ D"''''''''~''''^-I'Any Ir !ie I {'\Vii .Ul~U I'V1 " 00 DEe -4 PM 3: 3S CUMBERLANO COUffIY ' , PENNSY!.VANtA. J!l.m~ ~ < '~i!lW'I!li:-' ~ from Christmas Eve at 1:00 p.m. through Christmas Day at 1:00 p.m., the Father shall have custody from Christmas Day at 1 :00 p.m. through December 26 at 1 :00 p.m., and the Mother shall have custody from December 26 at 1:00 p.m. through December 3l at 1:00 p.m. B. THANKSGIVING: The Thanksgiving holiday period of custody shall run from after school on the last day of school before the holiday through 7:00 p.m. on the day before school resumes after the holiday. The Mother shall have custody of the Child over the Thanksgiving holiday in even numbered years and the Father shall have custody of the Child over the Thanksgiving holiday in odd numbered years. C. EASTER: The Easter holiday shall run from after school on the last day of school before the holiday through 7:00 p.m. on the day before school resumes after the holiday. The Mother shall have custody of the Child over the Easter holiday in odd numbered years and the Father shall have custody of the Child over the Easter holiday in even numbered years. D. MarBER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day from 10:00 a.m. until 7:00 p.m. and the Father shall have custody of the Child every year on Father's Day from 10:00 a.m. until 7:00 p.m. E. MEMClUAL DAY/LABOR DAY: In every year, the Mother shall have custody of the Child over the Memorial Day weekend from Friday after school through Memorial Day at 7:00 p.m. In every year, the Father shall have custody of the Child over the Labor Day weekend from Friday after school through Labor Day at 7:00 p.m. F. JULY 4TH: In even numbered years, the Mother shall have custody of the Child on July 4th from 10:00 a.m. until after the fireworks and in odd numbered years, the Father shall have custody of the Child on July 4th from 10:00 a.m. until after the fireworks. G. CHILD'S BIRTHDAY: The parties shall share having custody of the Child each year on the Child's birthday so that each party has an equal period of time with the Child. The specific times for exchanges of custody on the Child's birthday shall be arranged by agreement of the parties. The custody arrangements stated in this provision for the Child's birthday shall take precedence over the Father's Day custody arrangements in the event of a conflict. Neither party shall schedule his or her periods of vacation custody to interfere with the other party's period of custody on the Child's birthday. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. ~"l. I' " I. In the event the Mother I s holiday custody period falls irranediately preceding or following her regular period of custody, the period of holiday/regular custody shall run continuously without interruption. 5. Each party shall be entitled to have custody of the Child for three non-consecuti ve weeks during each summer school break upon providing at least 30 days advance notice to the other party. The party providing notice first of his or her selection of dates under this provision shall be entitled to preference on his or her selection. In the event a party exercising a period of custody under this provision remains in the local area with the Child, the other party shall be entitled to have custody of the Child for two evenings during the week from 4:30 p.m. until 8:30 p.m. 6. Each party shall notify the other party of any injuries, illnesses or: medical problems involving the Child during his or: her period of custody. 7. The parties shall cooperate with each other in creating an atmosphere of mutual respect and consideration in coparenting their Child. 8. Neither party shall do or: say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall take all reasonable steps to ensure that third parties having contact with the Child comply with this provision. 9. This order is entered pursuant to an agreement of the parties at a Custody conciliation Conference. The parties may modify the provisions of this Order by IIRltual consent. In the absence of IIRltual consent, the terms of this Order shall control. BY THE COURT, " J. a t~ -fY)aJl ):1.,.5-00 RKs J. cc: Taylor P. Andrews, Esquire - Counsel for Father Thomas Diehl, Esquire - Counsel for Mother ~'t'!!i ,_ _," " " '" ~-, ~ ' . ~ ,- - BRIAN C. roYLE, . IN THE roURT OF roMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-7823 CIVIL TERM : SHELLEY R. roYLE, . CIVIL ACrrON - LAW . Defendant . IN CUSTODY . PRIOR JUDGE: J. wesley Oler I Jr. CUS'.lOOY CQilCILIATICJiI SUMMARY REPORT IN ACXDIDANCE WITH ClJMBERLAND COONTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Amanda M. Coyle June 17, 1990 Father 2. A COnciliation COnference was held on November 29, 2000, with the following individuals in attendance: The Father, Brian C. Coyle, with his counsel, Taylor P. Andrews, Esquire, and the Mother, Shelley R. Coyle, with her cousel, Thomas Diehl, Esquire. 3. The parties agreed to entry of an Order in the form as attached. J{~ eJ,9 ~C> Date . , tQ~.~ Dawn S. Sunday, EsquJ.re ( Custody Conciliator '~'! ,- ' ~ . BRIAN C. COYLE PLAINTIFF V. SHELLEY R. COYLE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA 00-7823 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, April 05,2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawu S. Sunday, Esq. . the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, May 09, 2001 at 9:00 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if tbis cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furuish auy and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunday. Esq.1JO 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 baving 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 1HIS 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 FOR1H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 .~~, , ".', ,',U " , ,_~~tB~~ill~~,,"~;a,,,-__~,';;l>Iil&~"'~>BJ,,i;;,,,,.5"'-'ii"~Ml:,~~kl1B,nlL~~iII;:WStI~_.. 4/;'(}1 '1v~/ if.(p .tJ / lJ!l!ll. ."._ _,_.,_ ..~, "l-~lI>.-illWllijf"iil\iiffdll!lllW"""''''"' J~> , Li ~ J f-'! i ,2': [:-3 CUtV;:2.f~dL<i.\i:.) CCUi\JTY f'-":-,I\lj\!,l"'/L" ill1\Jit ,- ~ ~'.i I "'1",1' 1/4, &d-. ~ ~ -d; 5~ 7?~~ ~4~ ~ M~~4~ U"~, ii\I ~~ -" r;: Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA BRIAN C. COYLE, v. : NO. 00-7823-CIVIL TERM SHELLEY R. COYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this _ day of ,2001, 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 , 2001, at _m., for a Pre-Hearing Cnstody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cnmberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE TIllS PAPER TO YOUR LA WYERAT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION TWO LmERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 1-800-990-9108 ,,^,<",,jjlfflW"'J~I~ ~ ~ '" ~^'_o~ . BRIAN C. COYLE, : IN THE COURT OF COMM:ON PLEAS Plaintiffi'Respondent : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-7823 CNIL TERM SHELLEY R. COYLE, : CIVIL ACTION - LAW Defendant/Petitioner : IN CUSTODY PETITION TO MODIFY CUSTODY I. The Petitioner, SHELLEY R. COYLE, respectfully represents that on December 4, 2000, an Order of Court was entered for custody of AMANDA M. COYLE, born June 17, 1990. A true and correct copy of the said Order is attached hereto and marked as Exhibit A. 2. This Order should be modified so that the child maximizes the amount of time spent with parent and reduces the amount of time spent with a non-parent. Additionally, Petitioner, SHELLEY R. COYLE, is now able to resume her primary parental obligations to the child. WHEREFORE, Petitioner requests that the Court modify the existing Custody Order because it will be in the best interest of the child. Respectfully submitted, By ~lIti'I1)d~ Jenmfer L. Lehman, Esquire 27 South Arlene Street P.O. Box 6130 Harrisburg, PA 17112-0130 (717) 671-1200 LD. No. 52784 DATED: April 3, 2001 :i;\1.,,,,, ,~ "'-- " ~ " 1 ~ . VERIFICATION I verify that the statements made in the foregoing Petition to Modify Custody Order are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. CoSo 94904 relating to unsworn falsification to authorities. ~ \Z ~~/ Shelley R. co~e Date: lJ-:;? - 0/ ! ",,- " "'_0. , ' .,~.,_7' "",,_~,_. ,,_, ,~ ,,~ ~i":' ~__~_,_.,",,'_o< - .' " . f"-'''~> " ~, _ 'c' '.' --" ,'_.?'"_"<,_,,....,~"C' , ,"~~' -', ~,,,_,, ., ",I~'" " 9'" ,,' ".". '"_' " Iltrl"'" '. ..lVED ....r:r O 2'" .; ;"''';'.! --~ Plaintiff : IN TIlE CXXJRT OF CXXoIMal PLEAS OF : CUMBERLAND a:vNTY, PENNsn VANIA BRIAN C. CDYLE, . . vs. : NO. 00-7823 CIVIL TERM . . Defendant : CIVIL ACTIal - LAW : IN CUSTODY SHELLEY R. CDYLE, AND !Of, this LJfh consideratioo of the attached and directed as follows: ClUl!R a! CDRr day of ~~e.""be.~ Custody COnciliation Report, , 2000, upon it is ordered 1. ~e prior Order of this Court dated November 6, 2000, is vacated and replaced with this order. 2. ~e Father, Brian C. Coyle, and the Mother, Shelley R. Coyle, shall have shared legal custody of Amanda M. Coyle, bom June 17, 1990. 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 regardin; her health, educatioo and religion. ' 3. ~e ,parties shall.have physical custody of the Child in-- accordance with the following schedUle:' '. A. ~e Mother shall have custody of the Child on alternating weekends fran Friday after school through SUnday at 7:00 p.m., beginning Friday, December 1, 2000. B. ~e Mother shall also have custody of the Child every week. on two weekdays from after school until 8:30 p.m. The Mother's weekday periods of custody shall take place on i Mondays and Wednesdays unless the Mother provides reasonable i advance notice to the Father of her selection of alternative: days. C. ~e Father shall have custody of the Child at all times not. otherwise specified for the Mother in this order. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. ~: In even numbered years, the Father shall have custody of the Child from Christmas Eve at 1:00 p.m. through Christmas Day at 1:00 p.m. and the Mother shall have custody from Christmas Day at 1:00 p.m. through the evening before school resumes after the holiday at 7:00 p.m. In odd numbered years, the' 'Mother shall have custody of the Child EXHIBIT A 'l_ ;,jlr _~, ~. , ~-, " 7 T_. If 111-'1 from O1ri.stmas Eve at 1:00 p.m. through Christmas Day at 1:00 p.m., the Father shall have custody from Christmas Day at l:OO p.m. through December 26 at 1:00 p.m., and the Mother shall have custody from December 26 at 1:00 p.m. through December 3l at l:oo p.m. B. mANltSGIVING: The ThanksgiviD;l holiday period of custody shall run from after school CX1 the last day of school before the holiday through 7:00 p.m. CX1 the day before school resumes after the holiday. '!he Mother shall have custody of the Child over the Thanksqi viD;l holiday in even l1UIItlered years and the Father shall have custody of the Child over the ThanksgiviD;l holiday in odd mmtlered years. c. EAS'Jm: '!he Easter holiday shall run from after school CX1 the last day of school before the holiday through 7:00 p.m. on the day before school resumes after the holiday. '!he Mother shall have custody of the Child over the Faster holiday in odd' numbered years and the Father shall have custody of the Child over the Faster holiday in even nl.lllbered years. ' D. ~'S IlAY/FATfIBR'S DAY: '!he Mother shall have custody of the Child every year CX1 Mother's Day from 10:00 a.m. until 7:00 p.m. and the Father shall have custody of the Child every year on Father's Day-from 10:00 a.m. until 7:00 p.m. E. MI!IDmIL DAY/LABCR DAY: In every year, the Mother shall have custody of the Child over the Memorial Day weekend from Friday after school through Memorial Day at 7:00 p.m. In every year, the Father shall have custody of the Child over the Labor Day weekend from Friday after school through Labor Day at 7:00 p.m. F. JULY 4TH: In even numbered years, the Mother shall have custody of the Child on July 4th from 10:00 a.m. until after the fireworks and in odd numbered years, the Father shall have custody of the Child on July 4th from 10:00 a.m. until after the fireworks. G. CHILD'S BIRl'BDAY: The parties shall share having custody of the Child each year on the Child I s birthday so that each party has an equal period of time with the Child. The specific times for exchanges of custody on the Child's birthday shall be arranged by agreement of the parties. The custody arrangements stated in this provision for the Child I s birthday shall take precedence over the Father I s Day custody arrangements in the event of a conflict. Neither party shall schedule his or her periods of vacation custody to interfere with the other party's period of custody on the Child's birthday. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. =,~ , , I. In the event the Mother I s holiday custody period falls iIrmedi.ately pr~ or following her regular period of custody, the period of holiday/regular custody shall run continuously without interruption. 5. Each party shall be entitled to have custody of the auld for three non-consecuti ve weeks during each SUlllller school break upon providing at least 30 days advance notice to the other party. '!he party providing notice first of his or her selectioo of dates under this provision shall be entitled to preference on his or her selection. In the event a party exercising a period of custody under this provisioo remains in the local area with the auld, the other party shall be entitled to have custody of the Child for two evenings during the week fran 4:30 p.m. until 8:30 p.m. 6. Each party shall notify the other party of any injuries, illnesses or medical problems involving the Child during his or her period of custody. 7. '!he parties shall cooperate with each other in creating an atmosphere of IllUtual respect and consideration in coparenting their Child. 8. Neither party shall do or say anything which my estrange the Child fran the other parent, injure the opinioo of the Child as to the other parent, or hamper the free and natural developnent of the Olild's love and respect for the other parent. Both parties shall take all reasonable steps to ensure that third parties having contact with the Child comply with this provision. 9. '!his Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties my modify the provisions of this Order by mutual consent. In the absence of IllUtual consent, the terms of this Order shall control. BY THE o::xJRT, J. cc: Taylor P. Andrews, Esquire - Counsel for Father Thomas Diehl, Esquire - Counsel for Mother TRUE C01>Y FRC;\1 RF.~::CRl) In Testimony 'ii~2r,cf i here 0~t0 Set rr.y hand an~ t 5 cf sa' (ccrt ~isle, Pa. Thl ................. day of;...... ..............f+l' . . ..I.. . .. ...,.. f Prothonotary .~,,; 'I BRIAN C. conE, . IN THE a:xJRT OF c:xx.Ii'Ql' PLEAS OF . Plaintiff . CUMBERLAND CCXlN'lY, PENNSYLVANIA . . . vs. . NO. 00-7823 CIVIL TERM . . . SHELLEY R. conE, . CIVIL ACl'I~ - LAW . Defendant . IN aJSroDY . PRICR JllDGB: J. wesley aler, Jr. UJl:l'.lUJt' CXJlCILIATrQII SMtAR!' RBPCRr IN ACXX:RDllI!iICB wrm cnmERLAND CXDf.l'Y RllLE CP CIVIL IWJo ....._ 1915.3-8, the undersigned CUstody COnciliator submits the following report: 1. The pertinent infocnatioo concerning the Child who is the subject of this litigation is as follows: NllIIE DM:'B OF BIRl'B- UJtCl(1UY'1" .v lR u.E::i'.I.'U.J.I: c:. Amanda. M. Coyle June l7, 1990 Father 2. A Conciliation COnference was held 00 Noveul:ler 29, 2000, with the following individuals in attendance: The Father, Brian C. Coyle, with his counsel, Taylor P. Andrews, Esquire, and the Mother, Shelley R. COyle, with her cousel, Thanas Diehl, Esquire. /{ J'I/i-<.e.....,...he. de; ~ c-) Date ' , 3. The parties agreed to entry of an Order in the form as attached. a~,-JLL ~rJl~.~ Dawn s. Sunday, Esquire I Custody Conciliator 7 , ,"eli',,,, , ;r , , 'r CERTIFICATE OF SERVICE I, Jennifer L. Lehman, Esquire, hereby certify that on this 3'd day of April 2001, I served a true and correct copy of the foregoing Petition for Modification of Custody Order by depositing the same in the United States mail, first class postage prepaid, addressed as follows: Taylor P. Andrews, Esquire Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013-3216 "':'-, - --"--," >---,.. - , "'" . =" !"" '"'- . ~J~ J nmfer L. Lehman, Esqurre P.O. Box 6130 27 South Arlene Street Harrisburg, PA 17112 (717) 671-1200 , " ,,'- . - ~ <-I 121 ,,=, ~,_lt~,~!~ J;1f!1_~_~~~ ._>F,r_!"'l"'~~~:"_ ~ 0"' "'T (J 0 () 10 ~ ~ -'i-; ~ ,~ ---I -ocr -'0 r IT'll" :-:-:.7 () Z.:J L:::"C- ~ (j) ,'- 0) --<_d ~~;, ..,~"'" --;;, ..... " 0 ~ r 5>t: \:.0 ,in \ ~ Z _:A) -r:: ~ :,1:; I"- -< -..J r, ~ f' .--...( _~~",,~MilIlIfM.~-'l,\'J~~;j'A~~!<l~_l!@Jim'~~~I"~1lItl~~""'""''''-''~~.llI!IOO!''1'1' BRIAN C. COYLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-7823 CIVIL TERM . . . SHELLEY R. COYLE, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . aIDER OF <nJRT AND NOW, this ~ 0 ~ day of W/17 ':7 consideration of the attached Custody Conciliation and directed as follows: , 2001, upon Report, it is ordered l. The prior order of this COurt dated December 4, 2000 shall continue in effect as modified by this order. 2. The parties shall submit themselves, their minor Child, and any other individuals deemed necessary by the evaluator, to a custody evaluation to be performed by Arnold Shienvold, PhD. or other professional selected by agreement of the parties and counsel. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best serve the interests of the Child. The parties shall sign all authorizations which are necessary for the evaluator to obtain additional information pertaining to the parties, the Child, or additional individuals participating in the evaluation. The parties shall equally share the costs of the evaluation with the exception that each party shall be individually responsible for the costs of the participation of any additional individuals in his or her household. 3. The parties shall have custody of the Child during the summer school break in 2001 on an alternating weekly basis with the exchange of custody to take place every Friday at 6:00 p.m. The parties agree to adjust the exchange time as necessary to accommodate the parties' work schedules. The alternating weekly schedule shall begin with the Father having custody of the Child on June 8, 2001. 4. The Father shall have custody of the Child on June 17, 2001, which is the Child's birthday and also Father's Day, from 1:00 p.m. until 8:00 p.m. 5. The non-custodial parent shall be entitled to have daily telephone contact with the Child of reasonable duration. Both parties shall ensure that the Child returns telephone calls to the noncustodial parent when that parent has left a message. 6. Within 60 days of receipt of the evaluator's written custody recommendations, counsel for either party may contact the Conciliator to schedule an additional CUstody COnciliation COnference, if necessary. ;>:;~"-j- ~ \ .,-, . '" - 7. This Order is entered pursuant to' an agreement of the parties at a CUstody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE CDURT, J. J cc: Taylor P. Andrews, Esquire - Counsel for Father Jennifer L. Lehman, Esquire - Counsel for Mother ",,;:;'" 'c_ ~ ' plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA BRIAN C. COYLE, : vs. : NO. 00-7823 CIVIL TERM . . SHELLEY R. COYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley 01er, Jr. CUSTODY CD!ICILIATION SUMMARY REPORT IN A<XnIDANCE WITH CUMBERLAND COONTY RULE OF CIVIL PROCEOORE 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 QlRRBNTLY IN CUS'lOOY OF Amanda M. Coyle June 17, 1990 Father 2. A Conciliation Conference was held on May 23, 2001, with the following individuals in attendance: The Father, Brian C. Coyle, with his counsel, Taylor P. Andrews, Esquire, and the Mother, Shelley R. Coyle, with her counsel, Jennifer L. Lehman, Esquire. 3. The parties agreed to entry of an Order in the form as attached. (ho(' d- ~ d-cJ() I Date d1.~~d~ Dawn S. Sunday, Esquire Custody Conciliator ~" ~. -,- ^ ~I > vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :~ 00 : $-7823 CNIL ACTION LAW BRIAN COYLE, Plaintiff SHELLY COYLE, Defendant IN CUSTODY ORDER OF COURT AND NOW, this (b 14 day of :r 2 ~ \J 2> ~ ' 2002, upon consideration of the attached Custody Conciliation Report, it is order d and dIrected as follows: 1. The parties shall engage in a course of counseling (for a minimum of 6 sessions) with a professional selected by agreement of the parties and counseL The purpose of the counseling shall be to assist the parties in developing sufficient communication and cooperation to enable them to effectively co-parent their Child. Within two weeks of the date of the Conciliation Conference, the parties shall select and contact the counselor to schedule the first session. All expenses of counseling not covered by insurance shall be shared equally between the parties. The parties shall follow the recommendations of the counselor with regard to the frequency and duration of counseling. 2. Pending participation in counseling and the additional Custody Conciliation Conference, the parties shall alternate having custody of the Child on a weekly basis with the exchange to take place each week on Fridays after schooL The non-custodial parent shall have custody of the Child from after school on Tuesday through Wednesday morning before school, or during another week night as selected by agreement of the parties. The alternating weekly schedule shall begin with the Father having custody ofthe Child on Friday, January 4,2002. The Mother's first midweek overnight period of custody shall take place on Tuesday, January 8, 2002. 3. In the event the custodial parent is unavailable to provide care for the Child for a three hour period or longer, that parent shall first contact the other parent to offer the opportunity to provide care for the Child before contacting third party caregivers. 4. The non-custodial parent shall be entitled to have telephone contact with the Child one time per day, unless there is an emergency requiring additional contact. 5. The parents shall share legal custody of their Child. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and . --:~ _:- - , 1 ,~, j~I~;~~,~~~~~~-!!im"W'<<%"'&';'.Jl'>,;,"~!kii~li>;i!!..>iiQI&~"P,'Wl'~~" ...>:.-iliili,,, '1-"y'\\":N ,'II' . ",n' b" ,,~ "" u',~ .); ii:' C ~. ",? piA .:')' .-- ~ ,1 fe,: i\{\''< '... 1\\ ,,;,.-,:~~c.~U~:\-'~\) ,>,/ ...,: f' ~Ud"...I'-\ F' l('\I\Y l\~'U-\ ?t.\,,>i'V \ .' . - .~, ~~"'~~~ .* --_..._~~ -'lIIIiiiiii ~"-, Si c' information pertaining to the Child including, but not limited to, school and medical records and information. 6. The parties and counsel shall attend an additional Custody Conciliation Conference in the office of the Conciliator, Dawn S. Sunday, on April 4, 2002, at 8:30 a.m. 7. This Order is entered ,pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. cc: Taylor P. Andrews, Esquire - Counsel for Father Jennifer L. Lehman, Esquire - Counsel for Mother )cr ~ /_/1-()L 9- '8i ~ "11 1'1 ~" BRIAN COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-7823 CIVIL ACTION LAW SHELLY COYLE, Defendant IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Amanda M. Coyle June 17, 1990 Father 2. A Conciliation Conference was held on January 3,2002, with the following individuals in attendance: The Father, Brian Coyle, with his counsel, Taylor P. Andrews, Esquire, and the Mother, Shelly Coyle, with her counsel, Jennifer L. Lehman, Esquire. 3. The parties agreed to entry of an Order in the form as attached. j~ 7, ..1ntJd.- ~r>> Dawn S. Sunday, Esquire (j Custody Conciliator Date ~"'''~if;!lo/ ~ ." ~, " , - , , . BRIAN COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vS. OD-7823 CNIL ACTION LAW SHELLY COYLE, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ day of upon consideration of the attached Custody Conciliation Report, it is 2002, rdered and directed as follows: I. A Hearing is schedule in Court Room # I , of the Cumberland County Court House, on the a?5d:A., day of b ' 2002, at If': 31J o'clock, ~.m., at which time testimony I be en. For purposes of this Heanng, the Mother, Shelly Coyle, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the Hearing, and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten (10 ) days prior to the Hearing date. 2. The prior Order of this Court dated January 16, 2002 shall continue in effect as modified by this Order, with the exception of paragraphs 1 and 6 which are vacated. 3. The parties shall submit themselves and the Child to a supplemental custody evaluation to be performed by Arnold Shienvold, PhD. The purpose of the evaluation shall be to obtain custody recommendations based on updated information and circumstances which have become available since Dr. Shienvold's initial evaluation. Each party shall contact Dr. Shienvold within 2 weeks of the Custody Conciliation Conference in order to schedule his or her individual sessions and a session or sessions for the Child as recommended by the evaluator. All costs of the supplemental evaluation shall be shared equally by the parties. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. CHRISTMAS: In even numbered years, the Father shall have custody of the Child from Christmas Eve at 1:00 p.m. through Christmas Day at 1:00 p.m. and the Mother shall have custody from Christmas Day at 1:00 p.m. through the evening before school resumes after the holiday at 7:00 p.m. In odd numbered years, the Mother shall have custody of the Child from Christmas Eve at I :00 p.m. through Christmas Day at 1 :00 lr ~ , ~I _iijcliJ'1,i\t~~i~;~Il$iJ.~6i.'t',<JlEl!~.JJ,:,''t_Jja.4~,"",jillM>~"~",~"'"'1<I"''_-!'~"",'l~k,;;",,;.~-~,;;..~.g"'~~i!;'dl"~:~,ooal!~~~~~~~'-' FiLE[)-~OFF!CE OF "1'" F,:~,;:JCiO:OTi\FW 02 APR I 7 1);1; 1: 21 . I ,,~ .... CU"~C"" "'I' "'('IJNTY l\hbthLf~i'. u u,). , PENNSYLVANIA "~_~~I" ,[lJ ',,"<'~ ~ ,',_, '''''''".,~~",'.'"'-''~'> ~ "'"'" . "",; III p.m., the Father shall have custody from Christmas Day at 1:00 p.m. through December 26 at 1:00 p.m., and the Mother shall have custody from December 26 at 1:00 p.m. through December 31 at 1 :00 p.m. B. THANKSGIVING: The Thanksgiving holiday period of custody shall run from after school on the last day of school before the holiday through 7:00 p.m. on the day before school resumes after the holiday. The Mother shall have custody of the Child over the Thanksgiving holiday in even numbered years and the Father shall have custody of the Child over the Thanksgiving holiday in odd numbered years. C. EASTER: The Easter holiday shall run from after school on the last day of school before the holiday through 7:00 p.m. on the day before school resumes after the holiday. The Mother shall have custody of the Child over the Easter holiday in odd numbered years and the Father shall have custody of the Child over the Easter holiday in even numbered years. D. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day from 10:00 a.m. until 7:00 p.m. and the Father shall have custody of the Child every year on Father's Day from 10:00 a.m. until 7:00 p.m. E. MEMORIAL DAYILABOR DAY: In every year, the Mother shall have custody of the Child over the Memorial Day weekend from Friday after school through memorial Day at 7:00 p.m. In every year, the Father shall have custody of the Child over the Labor Day weekend from Friday after school through Labor Day at 7:00 p.m. F. JULY 4TH: In even numbered years, the Mother shall have custody of the Child on July 4th from 10:00 a.m. until after the fireworks and in odd numbered years, the Father shall have custody of the Child on July 4th from 10:00 a.m. until after the fireworks. G. CHILD'S BIRTHDAY: The parties shall share having custody of the Child each year on the Child's birthday so that each party has an equal period of time with the Child. The specific times for exchanges of custody on the Child's birthday shall be arranged by agreement of the parties. The custody arrangements stated in this provision for the Child's birthday shall take precedence over the Father's Day custody arrangements in the event of a conflict. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. '>~-1"I<!-ffiM,.-" . . 5. Neither party shall schedule periods of summer vacation during the other parties' alternating weekly period of custody without that party's consent. 6. The parties and counsel shall attend an additional Custody Conciliation Conference in the office of the Conciliator, Dawn S. Sunday, on Tuesday, June 18, 2002 at 8:30 a.m. BY THE COURT, ~ J. J cc: Taylor P. Andrews, Esquire - Counsel for Father Jennifer L. Lehman, Esquire - Counsel for Mother ~>1~ .i.f-/~;; Au ~~ "1_1'7,0.2.; ~ '''''''~'lI''''~...._ ="1'- BRIAN COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-7823 CIVIL ACTION LAW SHELLY COYLE, Defendant IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. 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 CUSTODYOF Amanda M. Coyle June 17, 1990 Father 2. A Conciliation Conference was held on April 4, 2002, with the following individuals in attendance: The Father, Brian Coyle, with his counsel, Taylor P. Andrews, Esquire, and the Mother, Shelly Coyle, with her counsel, Jennifer L. Lehman, Esquire. 3. This Court previously entered an Order in this matter dated January 16, 2002, following a Conciliation Conference, under which the parties had shared physical custody of the Child on an alternating weekly basis pending completion of a course of joint counseling. An additional Conference was scheduled following the counseling to review the custody arrangements. The Mother continues to seek primary custody of the Child. Although the parties agreed at the Conference to obtain a supplemental evaluation from Dr. Shienvold for the purpose of updating his recommendations, counsel requested that a Hearing be scheduled at the present time to avoid further delay in obtaining a final resolution in the event the parties are unable to agree after obtaining the updated recommendation. 4. The Mother's position on custody is as follows: The Mother believes that the Child should primarily reside with her as she has more time to focus on the Child's needs than does the Father. The Mother feels that the primary custody schedule would provide more stability for the Child than the alternating weekly schedule the parties had been following over the past 3 months. -,~,"". "" 5. The Father's position on custody is as follows: The Father stated that he believes the alternating weekly schedule has been working very well for the Child and that the Child has indicated her preference to continue spending equal time with both parties. The Father believes the parties can cooperate in adding some flexibility to the shared custody schedule to accommodate each party's needs when special circumstances arise. The Father believes that the Mother is failing to recognize the beneficial effects which the shared custody schedule has had on the Child and her relationship with both parents. 6. The Conciliator recommends an Order in the form as attached providing for a supplemental updated evaluation and scheduling a Hearing following receipt of those recommendations. Counsel for the parties request that the Hearing be scheduled in July to allow Dr. Shienvold sufficient opportunity to update his recommendations and to hold an additional Conciliation Conference thereafter in a final effort to resolve this matter. The Conciliator is hopeful that the Hearing will not ultimately be necessary in this case. Datf/lk~ Dawn S. Sunday, Esquire Custody Conciliator ~:~'_!lU"L, " , ~, BRIAN COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW SHELLY COYLE, Defendant NO. 00-7823 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 18th day of September, 2002, upon relation of Dawn Sunday, Esq., custody conciliator, that the parties in the above matter reached an agreement during a conciliation hearing, the hearing previously scheduled for September 25, 2002, is cancelled. BY THE COURT, /faylor P. Andrews, Esq. 78 W. Pomfret Street Carlisle, PA 17013 Attorney for Plaintiff " Jennifer L. Lehman, Esq. 27 S. Arlene Street Harrisburg, PA 17112 Attorney for Defendant ) :rc ,;',_, A" ~ _, '." _,~_., . _ ,. .-- ~',-- , " =-" <. , -'" '" - --, -, ^i1IJl:fBlri~d!.!IIlirW;l_IQ;a!lliilllt~I\~-m\<.m.~M\it#H-!.\i,"'it<L4i.~"~~jOi~i_futiii.~~~~~~~lMl~~...~~'!ioilOY~1I:lllfIJ1"*~- ~ ~ ." _.-, C): .... " :,\,.:\=\,('-,IC. \-,..y \..\.1<!\ ,~~ Ir\,\;'~'( ",~' _ -'''I~\}' \\,'\.i ,n, c;-n 'I q r; r. t.. ~ ~ UL .,,,'-"' q. r~ q. 'e\\ f_4 ,,;~ "1'/ " ,-,(\I\N,i "" \\:~~:",'t..\:::,,;.j<'.!',~_': .~:\{,~' (,\j,\,-, '\ '-'''\)1''"''-\ - Pc_N \';) I 1.._ " ":1.11"",, UUI!:IIIJI_ ~- -~ ~~---~=,= ~ - ,"~, II; BRIAN COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW SHELLY COYLE, Defendant NO. 00-7823 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 30th day of May, 2002, upon agreement of counsel, the hearing previously scheduled for July 25, 2002, is rescheduled to Wednesday, September 25, 2002, at 9:30 a.m., in Courtroom No.1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY TIIE COURT, Taylor P. Andrews, Esq. 78 W. Pomfret Street Carlisle, PA 17013 Attorney for Plaintiff Jennifer L. Lehman, Esq. 27 S. Arlene Street Harrisburg, PA 17112 Attorney for Defendant :rc ~ (>"'At>: Q",l, ,,-/a/o2.. >2,.1' -il~,_"", _, '_"_'_'''"'~.:~~'!'__, -!~ __ ._._~__, ~_'__,' ,~'.^ "~ ,,-- . ~ ., , "'-~ 1 " i_u'. ~1~,"-,,,,,,,-J,,"""~'~irMiM:U;i!ljW&llW~jjMt;.dllil~jljl~-liI<"lIl,,,imi;~~}~~~'-;6~i 1&lJ&-- . "-"'"" "''';'''if''''''''"" - ~~~lIiill!l~''';'''''''''''''''~'" --"-,,,--, , r ':',:',',':Ti\9Y l,/:t~ Y .'J I ,) \ n" ;' ~ '( :1: I! . " --" '- ,', ''''', ''''','"'''1 '\P'\! CU;\/;::.::.::.:-iLi",:\l.) \...A.:J; ~Il PENNSYLVj~NiA iJJUll!UlrL'LlLL~,,,U\,~,~J.,,,,,_ .,,,,,,,,, , " ",O/~__" ~~_o, ~ vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00 M-7823 CNIL ACTION LAW BRIAN COYLE, Plaintiff SHELLY COYLE, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ? - U day of ,r 2002, upon consideration of the attached ~nciliation Report, it s ordered and directed as follows: 1. All prior Custody Orders of this Court are vacated and replaced with this Order. 2. In accordance with the recommendations of Arnold T. Shienvold, PhD., the parties shall obtain individual therapy for Amanda to provide a safe environment for the Child to' address her feelings concerning the divorce/custody situation. In addition, the parties shall resume their joint counseling for the purpose of developing sufficient c;ommunication and cooperation to effectively co- parent their Child. Each of the parties shall also participate in a course of individual counseling to obtain assistance in addressing unresolved issues c~ncerning the diVorce. The parties shall contact their individual counselors, the joint counselor and tJiJ,e Child's therapist within 2 weeks of the date of this Order to schedule their next or initial sessions. All expenses of joint counseling and counseling for the Child which. are not covered by i~surance shall .~:e .s~ared equa~ly .between the ~arties. Each party shall be responsible for the costs of his or her own mdivldual couns~lmg. The parties shall follow the recommendations of the counselors with regard to thd frequencyiand duration of sessions. 3. The Father, Brian Coyle and the Mother, Shelly Coyle, shall have shared legal custody of Amanda M. Coyle, born June 17, 1990. Each parent shall have an ~qual right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well- being including, but not limited to, all decisions regarding her health,: education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all re~Qrds and information pertaining to the Child including, but not limited to, school and medical records anil information. 4. The parties shall share having physical custody of the Child on an alternating weekly basis, with the exchange to take place every week on Friday after school or Friday afternoon, if there is no school, at a time to be arranged by agreement of the parties. 5. In the event the custodial parent is unavailable to provide care for the Child for a 3 hour period or longer, that parent shall first contact the other parentto offer the opportunity to provide care .,=l\v" , ' -- I , 'I 'i~!U"",,;;,,"-;;k,~)I(W~'ltill'i!;i~!Jl"Wl.ci$N~"'~'''''''''''' rn~~~ifuk;i\i1ili:Jhl3jL",,,,,,,,",,".,,,~,",,,,,,~~,,,;.i\'~"'IiiI-;,?-; lL,L", L~!!I._.",,,.,,,,__ <'''''_ ,,-~ ,=,,",""'_ ~_',,'.~o/_~,. . ,-",~- ., :B!iM:Jlkilii1~~~~iIiI~'-'~- , L", ~. -~, -. ~".~ F\Lr:~fn9E . IrE c,c(W-oCid01PR'I Of 02 SE? 30 Pr', 4: 20 CUMBlRUND cqUNT'< ?ENNS'(LVAN,f\ ~ for the Child before contacting third party caregivers. Neither party shall interpret this provision to prevent the Child from visiting with grandparents or other relatives when the other party is otherwise available during his or her periods of custody. 6. When the Father is working for any period of time on the weekend during his periods of custody, the Father shall offer the Mother the opportunity to have custody of the Child during his period of unavailability before contacting third party caregivers. The Father shall provide the Mother with as much advance notice as possible when he has to work on the weekend. 7. The parties shall share or alternate having custody ofthe Child on holidays as follows: A. CHRISTMAS: The holiday custody schedule shall be divided into Segment A, which shall run from Christmas Eve at 1:00 p.m. through Christmas Day at 1:00 p.m., and Segment B, which shall run from Christmas Day at 1 :00 p.m. through the evening before school resumes after the holiday at 7:00 p.m. In even numbered years, the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. In odd numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. B. THANKSGIVING: The Thanksgiving holiday period of custody shall run from after school on the last day of school before the holiday through 7:00p.m. on the day before school resumes after the holiday. The Mother shall have cust0dy of the Child over the Thanksgiving holiday in even, numbered years and the hther shall have custody ofthe Child over the Thanksgiving holiday in odd numbered years. C. EASTER: The Easter holiday shall run from after school on the last day of school before the holiday through 7 :00 p.m. on the day before school resumes after the holiday. The Mother shall have custody of the Child over the Easter holiday m odd numbered years and the Father shall have custody of the Child over the Easter' holiday in even numbered years. D. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day from 10:00 a.m. until 7:00 porn, and the Father shall have custody of the Child every year on Father's Day from 10:00 a.m. until 7:00 p.m. E. MEMORIAL DAYILABOR DAY: In every year, the Mother shall have custody of the Child over the Memorial Day weekend from Friday after school through Memorial Day at 7:00 p.m. In every year, the Father shall have custody of the Child over the Labor Day weekend from Friday after school through Labor Day at 7:00 p.m. F. JULY 4TH: In even numbered years, the Mother shall have custody of the Child on July 4th from 10:00 a.m. until after the fireworks and in odd numbered years, the Father shall have custody of the Child on July 4th from 10:00 a.m. until after the fireworks. G. CHILD'S BIRTHDAY: The parties shall share having custody of the Child each year on the Child's birthday so that each party has an equal period of time with the ""''''$'''''_, .,;( -," ~ , 1 ' I' ~~ Child. The specific times for exchanges of custody on the Child's birthday shall be arranged by agreement of the parties. The custody arrangements stated in this provision for the Child's birthday shall take precedence over the Father's Day custody arrangements in the event of a conflict. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 8. Neither party shall schedule periods of summer vacation during the other parties' alternating weekly period of custody without that party's consent. 9. The non-custodial parent shall be entitled to have telephone contact with the Child one time per day, unless there is an emergency requiring additional contact. Both parties shall ensure that the Child is permitted to contact either parent at any reasonable time. 10. The custodial party shall ensure that the other party is able to contact either the custodial parent or the Child in the event of an emergency by providing appropriate telephone numbers in advance. 11. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 12. The Custody Hearing previously scheduled in this matter for September 25, 2002 IS canceled. 13. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. J. cc: Taylor P. Andrews, Esquire - Counsel for Father Jennifer L. Lehman, Esquire - Counsel for Mother ~ ~ ID_I_tJ.J.., CJ...-, ~-p~, . ". I"~ ," I,' i'! ! ~! 't'=_~~.," BRIAN COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA cP M-7823 CIVIL ACTION LAW vs. SHELLY COYLE, Defendant IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Amanda M. Coyle June 17, 1990 Mother/Father 2. A Conciliation Conference was held on September 18, 2002, with the following individuals in attendance: The Father, Brian Coyle, with his counsel, Taylor P. Andrews, Esquire, and the Mother, Shelly Coyle, with her counsel, Jennifer L. Lehman, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date ~~ ..2,~ de:JcJd- (O~4 Dawn S. Sunday, Esquire Custody Conciliator > ~-