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HomeMy WebLinkAbout01-1708 FX . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . Of. ,fdf,:f. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA, NJlNcr RCMll.1I1O, 2001 No. 1708 Plaintiff VERSUS MARC IXlNCAN 'l'IK1\IPSrn. Defendant AND NOW, DECREE IN DIVORCE ~Al~' -- , . , .... ?(;D' ,. IT is ORDERED AND DECREED THAT Nancy Ranano , PLAINTIFF, AND Marc Qmcan 'Ihanpson , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRiMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWiNG CLAIMS WHiCH HAVE BEEN RAiSED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None PROTHONOTARY ~ ~~ ~ ~ ~~~~ ~ . . . . , I ~, I ~ ,. .- r " ~ -~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . lW ~" "P"'." ,~., '''''rnlnl'-~im'il'illl.t'u'' f .~ ~ ~~!A /C?-/['-( 'X)$>. '!7- ~ ~ -7'9 /c;?> /rL ~ . -\.. " .. .. ~ ~ ! ,~, '~''''-< ~'-- ".' >~O"'-_~."<3"_, _"J_"",,"\'-"" ""',""'''',~_p -n t'-~"""'-~ " _...><ry- -","'"'< M~,~~~~!,.,~~I~~~'mm'~~'AAUI~jJf.l!~=~;,rr., !m~r-l""'~_'~~' f JUN 1 7 2002 ,,,w-- I NANCY ROMANO, RESPONDENT/PLAINTIFF V. MARC DUNCAN THOMPSON PETITIONERlDEFENDANT ) IN THE COURT OF COMMON PLEAS OF V ) CUMBERLAND COUNTY ) ) 2001-1708 ) ) CIVIL ACTION LAW ) ) ) IN CUSTODY ORDER OF COURT You, Nancy Romano, Respondent, have been sued in court to modify custody, of the following children: Andrew Roman Thompson, and Connor Adam Thompson born September 26, 1996 and October 10, 1998 You are ordered to appear in person at , on , 2002, at .M.,for , ~j :~ j ,j ;1 (-I o a conciliation and mediation conference. o a pretrial conference o a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. ." !1 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 Telephone (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 ;\ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. " '}; " ,-, l "~-I ;;~-'=9- "-<"",+'_ c"_.-._ _" I ..0' 0, ~~_I_'_r~" "_~'''''''' 1-- - -~, ~", - ," y' . . , MAR 2 6 ZU01tP v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION-LAW DIVORCE, CUSTODY NANCY ROMANO, Plaintiff MARC DUNCAN THOMPSON, Defendant NO, 01- no? CIVIL TERM 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 .7 on the _ day of ,200_, at m, for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to 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: Custody Conciliator 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 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities andreasonable 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. ",~ ! M ,_'. , ~-. --,~ I.~ ~I 1"-- r, '~' I " -,-'; , ~ . .' y, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE, CUSTODY NANCY ROMANO, Plaintiff MARC DUNCAN THOMPSON, Defendant NO, 01- /loB CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or armulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff You may lose money or property or other rights important to you, including custody or visitation of your children, When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO,OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court You must attend the scheduled conference or hearing. >f!. ,_ , --'.-.-Ji_." _.' I . ',"1-,-',_'-"I-r-. " , 1_ " ~_"-I - ;- _ r " r - t ~ NANCY ROMANO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION-LAW DIVORCE, CUSTODY MARC DUNCAN THOMPSON, Defendant NO. 01- /70F" CIVIL TERM DIVORCE COMPLAINT WITH CUSTODY COUNT The plaintiff, Nancy Romano, by her attorneys, the Family Law Clinic, sets forth the following cause of action: COUNT I. DIVORCE UNDER 23 Pa,C.S, SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Nancy Romano, who currently resides at 102 Spruce St, Carlisle,PA 17013, since February 2000, 2. Defendant is Marc Thompson, who currently resides at 243 E, Main St, Shiremanstown, PA 17011 sinceJune 2000. 3, Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and defendant were married on July 30, 1996 in York County Pennsylvania, 5, Plaintiff and defendant have lived separate and apart since August 20, 1999, 6. There have been no prior actions of divorce or for armulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that plaintiff may have the ~.~ "" --- ~" , ,~- , '^ . ---" " , ~I--'c- ~'I- " " "I 'I c right to request that the court require the parties to participate in counseling. WHEREFORE, plaintiff requests the court to enter a decree in divorce dissolving the marriage, COUNT II. CUSTODY 9. Plaintiff repeats and realleges paragraphs one through eight. lQ, Plaintiff seeks custody of the following children: Name Andrew Roman Thompson Connor Adam Thompson Present Address Age 102 Spruce St Carlisle, PA 17013 4 years 102 Spruce St. Carlisle, PA 17013 2 years The children were born in wedlock, The children are presently in the custody of Nancy Romano, who resides at 102 Spruce St, Carlisle, Permsylvania, During the past five years, the children have resided with the following persons and at the following addresses: Persons Nancy Romano Andrew Roman Thompson Connor Adam Thompson Nancy Romano Maryarm Romaoo Paul Romano Andrew Roman Thompson Connor Adam Thompson ~">:ll~~rlt "or I Addresses Dates 102 Spruce St. February 2000-Present Carlisle, PA 17013 1471 Kulm Rd, August 1999-February 2000 Boiling Springs, PA 17007 2 - :F'U . ", Nancy Romano Marc Thompson Andrew Roman Thompson Connor Adam Thompson 112 W. Coover St. June 1999-Augl!st 1999 Mechanicsburg, PA 17055 Nancy Romano Marc Thompson Andrew Roman Thompson Connor Adam Thompson (from 10/10/98) The mother of the children is Nancy Romano, currently residing at 102 Spruce St, 528A Chestnut Grove Rd Dillsburg, PA 17019 September 1996-June 1999 . Carlisle, Pennsylvania. She is married. The father of the children is Marc Thompson, currently residing at 243 E. Main St, Shirernanstown, Pennsylvania. He is married. 11, The relationship of the plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: Name Relationship Andrew Roman Thompson Connor Adam Thompson Son Son 12. The relationship of defendant to the children is that of father. The defendant currently resides alone. 13. The plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a 3 4! ~ .-.-, - "':' r:.}"-I- ~ I, ,., . , , court of this Commonwealth or any other state, Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 14. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiff has been primary caretaker of the children since birth; b) Plaintiff provides the children with a home with adequate moral, emotional and physical surroundings as required to meet the children's needs; c) Plaintiff is willing to accept custody of the children; d) Plaintiff continues to exercise parental duties and enjoys the love and affection of the children. 15. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. 4 '" ~~r .1" " <,'=~. . .. WHEREFORE, plaintiff requests the court to grant her shared legal and primary physical custody of the children, Date 3/J,J./ & I , , ~.~ Steven T, Boell Student Attorney c;;r:J:; M~~d/ ROBERT E. RAINS TERI 1. HENNING Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 5 ''''-~ I ,. ~'I' 'I r' . ,'''I ~ ' ~ :... ~ . ';""~")T;:'~~- - VERIFICATION I verify that the statements made in the foregoing Divorce Complaint with Custody Count are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S, ~4904, relating to unsworn falsification to authorities. Date: ) - f)~ 0 ( Nancy Romano '-"-_"',-,"'"_':-'-~- c,"",_,,"..,,- "__"-"r-'_"_I'"r<:,_', --.,~I_r_, ",,_<'P,_'_' -01-,'-','_ ,r~,-- , .-,,_, '1'--,., -",,- '-, -'~__'_'-.C = 'I ,r" - " "'? iill f~if '':1 "~'. ~ ,."" .~ - ~ ~ -8 t9 ~ Y ~ \fl ~ < c -~~, 'A' ^ --- "' ,. ..~ ~ ., ,-~~ .^' ")' .' ( 0 CO) (" C -, ..,-, "'t-" :-:rr. L~ r",L' - ~"'" tT: r~' . ::,;''::1 ~ :-,.. .c~. i- t",) ;-:q (i~ ^'" ,,,, - U ~~ C , ~.::::~ --'-; o:i;"-" n -."". CO'S j;. C' f'd (-) r " ~ , ):--: =2 - :J:J <".:) -< 1IJftlI. ~",~',.IIIt'"fi~!l1f;I~-%iW\";W)"Wf"!'f*"'F>IT;f-'W<l'jJ~Ifl!'l~~fIl~~~H1:ii~~~1 MAR 2 6 2001 \ NANCY ROMANO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA y, CIVIL ACTION-LAW DIVORCE, CUSTODY MARC DUNCAN THOMPSON, Defendant NO. 01- nO;) CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Nancy Romano, Plaintiff, to proceed in forma pauperis. I, Steven Boell, Certified Legal Intern in the Family Law Clinic, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party, The party's affidavit showing inability to pay the costs of litigation is attached hereto, ~;1:)(tJl Date ~~ Steven Boell Certified egal Intern L RT E. RAINS THOMAS M, PLACE TERI 1. HENNING Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 " ',C_:_I '1-"-' '<'1- " - - _->~I -- -i _". I ". _""'_<'_"'" -; '",' ,--1 NANCY ROMANO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA y, CIVIL ACTION-LAW DIVORCE, CUSTODY MARC DUNCAN THOMPSON, Defendant NO. 01- CIVIL TERM AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1, I am the Plaintiff in the above matter and because of my fmancial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2, I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation, 3, I represent that the information below relating to my ability to pay the fees and costs is true and correct (a) Name: Nancy Romano Address: 102 Spruce St; Carlisle, PA 17013 Social Security No,: 193-60-2297 (b) Employment If you are presently employed, state Employer: West Shore YMCA Address: Fallowfield Rd,; Camp Hill, PA 17011 Salary or wages per month: $800,00 Gross Type of work: Massage Therapist If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: ( c) Other income within the past twelve months Business or profession: Massage Therapist (home business) Other self-employment: Interest: Dividends: $300,00 per month _d 1',";",'" 1-'- r" - I~ , 1 . 7-'>__'1_"' ~'" Pension and annuities: Social security benefits: Support payments: Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: Other: (d) Other contributions to household support (Wife)(Husband) Name: If your (wife)(husband) is employed, state Employer: Salary or wages per month: Type of work: Contributions from children: Contributions from parents: Other contributions: Property owned Cash: Checking account: $35,00 Savings account: Certificates of deposit: Real estate (including home): Motor vehicle: YW, Yangon Cost ,Amount Owed $2000,00 Stocks; bonds: Other: Debts and obligations Mortgage: 374,00 per month Rent: Loans: 94,00 per month Other: Phone: Electric: Food: Oil Heat: Cable: Gas: (e) (f) $25,00 $75,00 $400.00 $75,00 $12,00 $100,00 (g) Persons dependent upon you for support Name: Children, if any: Name: Andrew Roman Thompson -1'>>"'-" ,. " "I ,- -- ;-.-' .'"'- ~ -- 1- ~ Age: 4 years -T<"" "'., "',' ,-- " " - Relationship: 4. I understand that I have a continuing obligation to inform the court of improvement in my fmancial circumstances which would permit me to pay the costs incurred herein, 5, I verify that the statements made in this affidavit are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa,C,S. 4904, relating to unsworn falsification to authorities, Date )-( :)-0 ( L-- A'1I!l. .~. ~ ~""~'H_""';'''' ~-,'-- "~ ,1__ ~-" f ,-- ',-,,;; ~-I ;'" ,~, _ _ _ I-~~',-." -,-, -~,_" . ': .""no I ,- - . ,e"" _,_ r__"....'C,c .' ~,' ,-". !1ij ~ i' - - - ~,~,-- ~~ ,;". r:r,_lfg;r.~.1W1 ~"" .~~., ~. ~.~" ,~^ "If ; 0 (::'.' ':) f€ . I ~ ~, :::!: 6'1 ,c< po: ;<J ;:~ 'T - . :? ~~ f'.} , i---:t ~~ 1'".:.-, C? ) (~) r::.: .- , 3;: - _c_ -, - -'2 -q ;~ ,'" ,:~ :f.' .~ N C) " :~-.: r.- :::;:~ '-; :0 '-<; .~ -< __.Hili1!f'$If'*",U.~~,;I[~~~'~"ll~~~.~~~~~,...,~: .,S~ b_' '1:-,Jl~ NANCY ROMANO PLAINTIFF V. MARC DUNCAN THOMPSON DEFENDANT IN TIlE CbURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-1708 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, March 30, 2001 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumherland County Courthouse, Carlisle on Wednesday, May 02, 2001 at 8:30 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, The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Jacqueline M. Vernry. Esqty7 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 atrangements 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 ATIORNEY AT ONCE. IF YOU DO NOT HA VB AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE 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 -'-"'~ -- ~ -' ~1iill~~illl~~N~~tlil;lil#_llJiilit.l,"",~"I;ili",""'~""h~';~_~'-""~",i;,-"-,;,,,_.,;,;,,;_,,:.,_~-"-"i>'l._~_,glll~_~ll!!lllllil"l lf~{)( !/;:H)/ LI;)!)/ ;'~h,.""!",qr.1,,flllill!lJJl]J[J.'!Ir Ill, '" . "-"".., ". .. .. .". .,,". '~~1llBffiliiIl M'''~'_ ^ ~ fJ l j\PR -:.2 F.':-~, I: n2 CUjv;Sd'!:~;:1!--';~ COU]\JTY F'E!\INSYlVA!\I!f\ M-~ ~ -t d/. YIdiP twi.ld 'J djI- ~~~4~# II< v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE, CUSTODY Nancy Romano, Plaintiff Marc Duncan Thompson, Defendant NO, 01-1708 CIVIL TERM PROOF OF SERVICE I, Steven T, Boell, hereby certify that I served a true and correct copy of the Divorce Complaint on Marc Duncan Thompson, residing at 102 Spruce St, Carlisle Pennsylvania, by US, mail, certified, restricted delivery, return receipt requested, postage prepaid, Service was complete upon receipt by Marc Duncan Thompson on or about the 27fu day of March 2001, as evidenced by his signature on the attached green card, ~~ Certified Legal Intem FAMILY LAW CLINIC 45 N, Pitt St Carlisle, PA 17013 717-243-2968 . 1"- H,_,5,""___, ","'__'.' _ '_"~___,"_ ,~._~'r_','k'>:":"'-''--''l>~' -'~'_,",' .0, ''''--r---'' ,_ <" ,,~ r"-'" . ~-',1 " ~ ,~ . - ~..~ ~ ~, fR1I1~_ ,-__,,~~ r._ _~_~ .,~, _ , .". "o_~~~_, ""n"niDT '''i .,-...", ~"(-,: -'-" U"; , -~ .;, -," _lIli;i1J.ll~~~;-i!'ID%"~~~~I~.~..."J'I!I. ~c" '-r'-"~,~- __._,,~ . .~ item.'. 2. ""cI$. .. ollmi>lete item 411 Restricted Delivery Is desired, . Print your name and address on the reverse ,...."at we can return the card to you. ~Eh this card to the back 01 the mailplece, X r on the front if space permits. rU;;re~::elfN IhOWf60l. ,;. l/ 3 E. /11. Itl /1/ S t,eHT '~~~' [!hlte-rwlndDuJJ1lfJJ4 /10 ( o Agent o Add DYes o No 'j6..ves 2. Article Number (Copy from service labeO 6 1'>8 Form'j8~ 1', ,JulY 11199 ' 102595-99-M-H89 Ir" Ir" J:] f"- Postage $ .., r'l f"- Ir" -" Ir" Ir" ,:t" Certified Fee Return Receipt Fee CCI , (Endo~ement Required) r'l CJ Restricted Delivery Fee CI '. (EndorS"lment Required) c ~ Total Postage & Fees J:] ,:t" ", -""'~~ I " ~J 'rI1".'1_ ~ " ,-rCI"'~"""'I,.,rr;~'= ~ JUN 0 1 2001 f/J I NANCY ROMANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDCOUNTY,PENNSYLVANIA V. : NO. 2001-1708 CIVIL TERM MARC DUNCAN THOMPSON, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this -70 day of ~~ ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The Mother, Nancy Romano, and the Father, Marc Duncan Thompson, shall have shared legal custody of Andrew Roman Thompson, born September 26, 1996 and Connor Adam Thompson, born October 10, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. The Mother shall have primary physical custody of the children. 3. The Father shall have the following periods of partial physical custody: A. Beginning June 9, 2001, alternating weeks from Saturday at 9:00 a.m. to Thursday at 9:00 a.m. 4. Each party shall have custody of the children for one week during the summer, provided they give thirty (30) days prior notice. 5. Neither party shall take the children out of state without prior notice to the other party. Said notice shall include the dates, times, location and telephone number where the children can be reached. 6. The party receiving custody shall provide transportation. 7. In the event that either parent is in need of babysitting services for longer than three hours during their period of custody, the custodial parent shall contact the other parent with the opportunity to provide care for the children before arranging for a third party to baby sit. .~~ ~~.r'""' , I T" ~~ ~ f 8. The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the children and shall further take any necessary steps to ensure that the health and well being of the children is protected. During such illness or medical emergency, both parents shall have the right to visit the child as often as he/she desires consistent with the proper medical care of the child. 9. Neither parent shall do or say anything nor let anyone in the children's presence to say or do anything that may estrange the children from the other parent, injure the opinion of the children as to the other parent or hamper the free and natural development of the children's love and respect for the other parent. 10. Both parents shall have liberal and reasonable telephone contact with the children when the children are in the custody of the other parent. I I. This Order shall be considered an interim Order. Either party may contact the Conciliator for another conference within sixty days of this Order. If neither party contacts the Conciliator within sixty days, the Conciliator shall relinquish jurisdiction. Thereafter, either party may file for a modification of the order. 12. 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. cc: Jennifer Garrison, certified legal intern, Family Law Clinic, for /ther - COP,! M~~ be Teri 1. Henning, Esquire, Counsel for Mother ' Michael S. Travis, Esquire, Counsel for Father - Cory I"Y\ l:l \'l~ l.../~11 0 I ~ 1. 0,,,.,., ',~ 1'- - II -..,...... .. "ill ,~"'" "''''''.,^",,,,,, 'U"'I~~lllliffiniIJU "11111!il11Ft'I" . VlNrl/\lASNN:ld '''Inr-,", ~'" .." '-'W!n~ I\..U~ i'..),) ~J.' ',1 ":'!:':~''i\,:J '1 Z :8 Wi j Z iJiW 10 Al:I\flOi 3:)JJjO" u:; li-j ~. ~ """l~'o' ",,~lJl[llll~~~~~1!iil!~~-,~_,~"~~ _~f'!1'l4ge-!l''''''if"~'':-''F'''''''!'-'''--'--''''f--''",,''-'''-,,~m~~f,",~Rt'I'.:P.r.~'n'WWlli;f1l!!l'iIi";ili'1#!I!IlI:-fl.f!t~~~jIJfffl~~'i . I NANCY ROMANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA V. 21101-1708 CIVIL TERM MARC DUNCAN THOMPSON, Defendant CIVIL ACTION - LAW IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Andrew Roman Thompson Connor Adam Thompson September 26, 1996 October 10, 1998 Mother Mother 2. A Conciliation Conference was held in this matter on May 30, 2001, with the following individuals in attendance: The Mother, Nancy Romano, with her counsel, Jennifer Garrison, certified legal intern and Teri L. Henning, Esquire, Family Law Clinic, and the Father, Marc Duncan Thompson, with his counsel, Michael S. Travis, Esquire. 3. The parties agreed to entry of an Order in the form as attached. S -3/ -0 I Date ~'!!:~~ Custody Conciliator -- r , ~ *' v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NANCY ROMANO, Plaintiff MARC DUNCAN THOMPSON, Defendant NO, 01-1708 PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1, Ground for divorce: irretrievable breakdown under * 3301 ( c) of the Divorce Code, 2. Date and manner of service of the complaint: March 27, 2001 bv U. S, mail. certified, restricted delivery. return receipt requested, postage prepaid, 3, Date of execution of the affidavit of consent required by * 3301(c) of Divorce Code: by plaintiff Julv 10,2001 ; by defendantJulv 17,2001, 4, Related claims pending: None. 5, Date plaintiff's Waiver of Notice was filed with the prothonotary: Julv 30, 2001, 6, Date defendant's Waiver of Notice was filed with the prothonotary: July 30, 2001, July 30, 2001 ~~^ ~.fi J nifer G 'son Certified Legal Intern 7 L;f I ~ / T S M PLACE V' ROBERT E. RAINS TERI L HENNING Supervising Attorneys FAMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Attorneys for Plaintiff, Nancy Romano ':;" 'r .', -",",-,T"(-'_""""'h'~r'!~".",~1_"'___:-_' ,"~-,-l ~'-'l'I""':fr~,,-,-"',r-'1'I""'\'--' c_',_",,;_ _ _~o_ ,." ~T-;I:, ~ "_,:>': ,~-_-,',;:''<ll;,; ~ ' --,-, ,",' I . .-,-- - l'r-'f'" NANCY ROMANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY , PENNSYLVANIA v, : CIVIL ACTION - LAW . : IN DIVORCE : NO. 01- 1708 CIVIL TERM MARC DUNCAN THOMPSON, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on March 22, 2001. 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a fmal decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, ~4904, relating to unsworn falsification to authorities. Date 7- / IF () I -,".-,-,-?""-"._" " '!'I_C'-" '''I ":'--- -'--"1--,1' ,,, 0, -I NANCY ROMANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION -LAW : IN DIVORCE : NO, 01- 1708 CIVIL TERM MARC DUNCAN THOMPSON, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER S3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree of divorce without notice, 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary, I verify that the statements made in this affidavit are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa.CS, 94904 relating to unsworn falsification to authorities. Date: 7-/(j, () ( :1~,~ '~~:,"f'_,,,,_ - ,-_';"'_P'~__,,2,_ r.' ','_oJ,,,, . '"'1"-"'- e. '~I' ""l.- '''''';"_,_''.d",', ;d~L.-1--'-""-":" I:': .",-, ---~" -, . <, C' "'''''-1- --y-- c,"-'. NANCY ROMANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 01- 1708 CIVIL TERM MARC DUNCAN THOMPSON, Defendant AFFIDAVIT OF CONSENT L A Complaint in Divorce under ~3301(c) of the Divorce Code was f1led on March 22, 200t. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a fmal decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit 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 i J/ ) jJ ) I Marc D can Thompson, Defendant RECEIVED JUl 1 9 2081 ...-q-__',,-C",'.<--- - 1-' I ' ., ..," ". '" _'"1'-1 ,~ , I . I NANCY ROMANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA y, : CIVIL ACTION - LAW : IN DIVORCE : NO, 01- 1708 CIVIL TERM MARC DUNCAN THOMPSON, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE 1, I consent to the entry of a fmal decree of divorce without notice. 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted, 3, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, g4904 relating to unsworn falsification to authorities. Date: //1 )/(JI ~- Marc can 2 Defendant "",I '0 ,~, . . > .- ,,',.'-j,,-'-,- ", ::-1:; ,-~ :rJ>._ - 11 . NANCY ROMANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW y, : IN DIVORCE, CUSTODY MARC DUNCAN THOMPSON, Defendant : NO, 01- 1708 CIVIL TERM CERTIFICATE OF SERVICE I, Jennifer Garrison, hereby certify that on this 30th day of July 2001, I am serving a true and correct copy of Plaintiff's Affidavit of Consent, Plaintiff's Waiver of Notice of Intention To Request Entry of a Divorce Decree Under ~3301(c) of the Divorce Code, Defendant's Affidavit of Consent, Defendant's Waiver of Notice of Intention To Request Entry of a Divorce Decree Under ~3301(c) of the Divorce Code, Praecipe to Transmit Record, and Vital Statistics Form upon the defendant, Mr, Marc Thompson, at 243 East Main Street, First Floor, Shiremanstown, P A 17011, by first class mail, postage prepaid, l. 0.. Y:> Leo l ~ FAMILY LAW CLINIC 45 N, Pitt St. Carlisle, P A 17013 717-243-2968 ''--'' "', ^ I," ':"1 j .~- ':'n~ -I' ", [' ,1 jl Ii II Michael S. Travis " Attorney at Law 4076 Market Street, Suite 209 Camp Hill,PA 17011 (717) 731-9502 NANCY ROMANO, RESPONDENT/PLAINTIFF V. MARC DUNCANTHOMWSON PETlTIONERlDEFENDANT ) IN THE COURT OF COMMON PLEAS OF ) CUMBERLAND COUNTY ) ) 2001-1708 ) ) CIVIL ACTION LAW ) ) ) IN CUSTODY PETITION FOR MODIFICATION OF PARTIAL CUSTODY 1. The petition of Marc D. Thompson respectfully represents that on June 20, 2001, an Order of Court was entered for partial custody, a true and correct copy of which is attached. 2. This Order should be modified because: a) Plaintiff has advised Defendant of her intention to home school the children Andrew Roman Thompson, and Connor Adam Thompson born September 26, 1996 and October 10, 1998; Defendant is opposed to home schooling and believes they should attend public school. Defendant is concerned that school registration deadlines will be missed. b) Defendant is moving to Georgia in August, 2002. A new schedule will be required. Defendant proposes that he should have custody in the summer together with substantial periods of custody during the holidays. WHEREFORE, Petitioner requests that the Court modify custody because it will be in the best interest of the childre l{isting Order for partial I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated?/fo/~1 ~ Marc D. Thompson ~" -'''';~'V_ ~ ''''r.--'~ ,~- ~_ ,,".~",, "~-IT''--7 ,- ,"--'I"-:;-'?"'">~",~?~'~_'" '.- -'1....'1 , 'j'-' '-'-I' 1-' ~~j JUN I) 1 lUll" I/} NANCY ROMANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA v. . . : NO.2001-1708 CIVIL TERM MARC DUNCAN THOMPSON, : CIVJ[L ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this .;)() day of ~,JJn ,S- ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: L The Mother, Nancy Romano, and the Father, Marc Duncan Thompson, shall have shared legal custody of Andrew Roman Thompson, born September 26, 1996 and Connor Adam Thompson, born October 10,1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. The Mother shall have primary physical~custody of the children. 3. The Father shall have the following periods of partial physical custody: A. Beginning June 9, 2001, alternating weeks from Saturday at 9:00 a.m.. to Thursday at 9:00 a.m. 4. Each party shall have custody of the children for one week during the summer, provided they give thirty (30) days prior notice. 5. Neither party shall take the children out of state without prior notice to the other party. Said notice shall include the dates, times, location and telephone number where the children can be reached. 6. The party receiving custody shall provide transportation. 7. In the event that either parent is in need of babysitting services for longer than three hours during their period of custody, the custodial parent shall contact the other parent with the opportunity to provide care for the children before arranging for a third party to baby sit. ,", ~ 1~-~ -~'"- ".,-.-, ,I - ..r. I , . 8. The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the children and shall further take any necessary steps to ensure that the health and well being of the childten is protected. During such illness or medical emergency, both parentS shall have the right to visit the child as often as he/she desires consistent with the proper medical care of the child. 9. Neither parent shall do or say anything nor let anyone in the children's presence to say or do anything that may estrange the children from the other parent, injure the opinion of the children as to the other parent or hamper the free and natural development of the children's love and respect for the other parent. 10. Both parents shall have liberal and reasonable telephone contact with the children when the children are in the custody of the other parent. 11. This Order shall be considered an interim Order. Either party may contact the Conciliator for another conference within sixty days of this Order. If neither party contacts the Conciliator within sixty days, the Conciliator shall relinquishjurisdiction. Thereafter, either party may file for a modific;ation of the order. 12. 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 tenns of this Order shall control. BY THE COURT, 1/ P~..., g. ~~~ cc: Jennifer Garrison, certified legal intern, Family Law Clinic, for Mother Teri L. Henning, Esquire, Counsel for Mother Michael S. Travis, Esquire, Counsel for Father' TRUE COpy FROM RECORD III TIIlInony wMreoi. I here unto SIt my I\anlI .., ..~ . said ~ Canlste. Pa. - -~~ ~~-~~~f8~ ",- ,~- 'I ,- r-' r .r -f I " , I , , . NANCY ROMANO, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : 2001-1708 CIVIL TERM MARC DUNCAN THOMPSON, . : CIVIL ACTION - LAW Defendant PRIOR JUDGE: None : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME Andrew Roman Thompson Connor Adam Thompson DATE OF BIRTH CllRRENTL Y IN CUSTODY OF September 26, 1996 October 10, 1998 Mother Mother 2. A Conciliation Conference was held in this matter on May 30, 2001, with the following individuals in attendance: The Mother, Nancy Romano, with her counsel, Jennifer Garrison, certified legal intern and Teri L. Henning, Esquire, Family Law Clinic, and the Father, Marc Duncan Thompson, with his counsel, Michael S. Travis, Esquire. 3. The parties agreed to entry of an Order ihthe form as attached. S -3/-0 ( Date ,., 1'" ~J::!~ Custody Conciliator '[ - -'-',~-' '- ' I I" . " " i .' iii '~ -~"~~, - ".~ .. ". '" '--"---" ""~"..".... -rill I "rr' , . 0 a 0 {= r'.> -'1 p ~ :~ c_ ::ji ~ -r'i"''''' c:: n'o.ffh 'c-::----r'\ ~ 7,', Z , !'f-::::'::: 0 L- ~,' 0~;~ ,,- ~g8 8 -....0. Q(~ ~::~:. -0 --'';'' -~~..: ~'q ...... ...... "7'{-) ...,}/~ ";~~ ~ f=(~; -. Pr=":- ~ ~ .-'''1 C<J 0..' jI! ::0 .-<: '0 -< ~ ~~ 1hlr' ~,- _ ,,,,.,_~, ~_""'"""~If<l1!~'l!I!!"l,"~,,,,,,,,,, n_.~ !!il9I_lIm'>Il"ffl~_~!P"'T""""i!i!1'~,;-;""'-'>'r:'__"~I'Ii~'91~'I"I"7;;;C,,,,"!,!~'"'1:~;~(,n;I~Hf!~1'1'_1:(\\"'l~~I~i"",4H;I'-"'WW;;Z-~"1!!\'_~"'lif<'H~'!~~,",m:lr:r-' \ PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NANCY ROMANO v. 01-1708 CNILACTIONLAW MARC DUNCAN THOMPSON DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, Jnne 24, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqneline M. Verney, Esq. ,the conciliator, at 4th Floor, Cnmberland Connty Conrthonse, Carlisle on Tnesday, Jnly 16, 2002 at 2:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order, All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order, The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Jacqueline M. Verney. Esq. (i\iw 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. Y Oil 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 '<l"""f'" -".- ..., ,. ,,' " ,>L=~_M . ~~ ~ ~~ ~ ~p~-~~iL. ~r~~~~ ViNV/\!"SNN3d I 'I"n'. ,'-..' r'''I\!':'l'I:J:;::;li~r:8 1\.1.. '~l '., '., '- .' -, -_.} ~ . '""" "'1"\['''0 QU:t: ~'ld ~-:10h (, ,I' 'lCd"., ":.-"'IJ.' ::1'0 I'.CJV~~ 'I\j',-li"',..._\".(<~.l,_._ji; -'.1'")' I j,"':,-I' I':"'; IIJ :::'wl::J':"',\../ \,i,_J ..J -~. - r;:> c7- 5t'-"j e' r7 - -'i(', f N'5~ "l . ~-~~~~- =-.~" t "_~~!lI!I~#~~_"~~~ ,.,.,,_ ~. . .,ffi'IIffj!I~"~__"!)W)'lif'~"'~~""G"'1"F"""~-_"""T':"~W"';i'I'-':"'\:'-~-'""'i'~""'""",o.~S",,,,,/,,"~'''~~_'';'''-'''''~'>'''_I''_"',_'Jl-;;--_'J~"m';'''''~~i~ - AUG09m ,,,,kC NANCY ROMANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-1708 CIVIL TERM MARC DUNCAN THOMPSON, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDElR OF COURT AND NOW, this 9th day of August, 2002, the Conciliator being notified that the parties have signed a Custody Stipulation in the above matter, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, %' tit ustody Conciliator '-,,~~~~ - -1. -, ~,-_ -'."-.".-, - 'r '"" "I I "-' , I ~>: . ~"'""" ~~ '" 'v1NV^1J"SNN3d ALNn08 C1\l\fl~lj8il\ln:) SS :01 !.j~ 2 I ~il~ 20 1\'1-11('""/...",,., AG, ,-,1,....'/, 1.,;.'_"./1 :J8diO-(jj'.Ji:] :.10 ~ "" ~, I1t ~1'~"."ij'lf~Ill!I'l\'II_~li~ _ 1Il;,,~l\.iI> -~--""',W"_..M._"'-'-r(-~iiJr:I'u~lilf"1r '"'Jr 1--' r -r"w ,-~ ~, lIlt: ~ .,v-:-~l'IlIIIDm~""f1""""",w>,,,,,"'\:,"1""i~,,,IJ"'~,'1l~,,*~r'l".'~11~imiijll'!i~lIll Jj <" < ,~ NANCY ROMANO, RESPONDENT/PLAlNTIFF V. MARC DUNCAN THOMWSON PETITIONERlDEFENDANT ) IN THE COURT OF COMMON PLEAS OF ) CUMBERLAND COUNTY ) ) 2001-1708 ) ) CIVIL ACTION LAW ) ) ) IN CUSTODY CUSTODY STIPULATION AND AGREEMENT AND NOW, come the parties hereto, Plaintiff, Nancy Romano, ("Mother") and Defendant, Marc D. Thompson, ("Father") as said parties have reached mutual agreement as to the custody of their children Andrew Roman Thompson and Connor Adam Thompson, born September 26, 1996, and October 10, 1998, and hereby stipulate to the following changes to the Order of Court entered on June 20, 200 I: 1. Both children will remain in public school in the school district where Mother resides. 2. All other aspects of the Order of Court dated June 20, 2001, will remain unchanged. 3. The parties shall have the right to modify any provision of the custody schedule upon mutual agreement by both parties. In the event a proposed modification is not agreed to, the schedule as stated shall be complied with by the parties. The parties reserve the right to modify this Stipulation and Agreement through the court pursuant to Pennsylvania Law, as Cumberland County, Pennsylvania, shall retain jurisdiction. 4. It is the intention of the parties that this change be a modification of the Agreement of the parties, entered as an Order of Court, dated June 20, 2001. ~~--- Marc D. Thompson, Defendant D~ ~-~ ~ . fUj Ow Witness ..;""~,~ , ~ ; ,I< ._"_^.; ,,~. -, 1."-- '1'_1' , , ", _, .. ~ ,,~, _ ._ _ .f. . - T ' ~ . NANCY ROMANO, RESPONDENT/PLAINTIFF V. MARC DUNCAN THOMPSON PETITIONERlDEFENDANT ) IN THE COURT OF COMMON PLEAS OF ) CUMBERLAND COUNTY ) ) 2001-1708 ) ) CIVIL ACTION LAW ) ) ) IN CUSTODY CERTIFICATE OF SERVICE I, Michael S. Travis, certify that I have this day served a true and correct copy of the foregoing document by first class mail, postage prepaid, on the following person(s), addressed as follows: Bryon R. Kaster, CLI Family Law Clinic 45 North Pitt Street Carlisle, PA 17013-2899 Date: (l- 7- o:J-. chael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, P A 170 II (717) 731-9502 Attorney for Petitioner ',",- ",~'-' ""'~," , ,.- "'f"":'"-',' \-"---1;/1<-', '-'''_'",-_~_,"c,-~_,__",'';_-r-r,_I~- -"F' "." ,-, -1 ~ , Ii ~Lf . ~ " . .,~",~~ .,,,,,,,,,,,,,,'..n.,,',, 7,""__ -'.,.,'" , '~~_"7"~_F ~f'_'f'i"_"""-""~,,,._ "Ole :-~ .,-:< u_., _, o C -o[~ 'Tll~', Z:-T: 0~i- ~ .-,-, r~\ < <..... '-. ir~ --:'" :-3 -, n, -,.,-' In .'r;r''T o f'') ". ~ ~? o " .~ [ ,\~;g rn ;., (....:; '"to f-) ~:;;~~ 0' -., ~ s'::) ':'0 (0 ~~~1. ~__~I:IIWI.'\lll!'i~- _ ,_ . '~"1--, ,-,'- " "'- !!~i v '" (AUG 142002 NANCY ROMANO, RESPONDENT/PLAINTlFF V. MARC DUNCAN THOMPSON PETITIONERlDEFENDANT ) IN THE COURT OF COMMON PLEAS OF ) CUMBERLAND COUNTY ) ) 2001-1708 ) ) CIVIL ACTION LAW ) ) ) IN CUSTODY ORDE~:;;URT AND NOW, this ~ day of . '-=,2002, it is hereby ORDERED and DECREED that the attached Custody Stipulation is entered as an Order of this Court. u4 / ( J. / Distribution: Michael S. Travis, Attorney for Petitioner Bryon R. Kaster, CLI for Respondent ~ ~ f- / t) ,oJ.; Q- --",. .,..,~ , ~ 11- r 1 'I " .,." "" - ~,. -~-~ ~ >- 9;'; 1..'::::- u....!Q 0::-0:::- H:~~-': ;:'=,,:'- \y:-- 6c--;: ~J~:-_I _L l~-. 'L o tv ~" ~ ~ .-. ,- - -" ~"-~- ,~ 0J 0, i= '7 ~, 3~ C)~~" '" ::J-~' '~65 ,./o?; '~D~ cuiE ~ --) <:) s ;rr:; ""'1: 0" S? -' "" ",j o -~- ~'''~~"''f 'jlTilll<' 'ifmr'li1i1r' vvc-:W'liit """",.I]11ll:ll1'f'~~~~~L'l.~1fl~~'\I"iI.."'\i",,,,\,f,~""'_""_'1t"_i'1""'-;f"'_"h_"'" "-;'''''''j'''!,'';\'<-'Y'l!:?1T'"''''-l'''~']'!:'B~;t''"'"-'__'-";F.'ll'f''!%'lW'fW:!\Wf'!!"*~_1'!'#~!i\I~'I"