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HomeMy WebLinkAbout07-1847IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DENNIS M. STUMP, JR., Plaintiff Vs. LESLIE STUMP, NO-= D'7 - ! PW7 CIVIL ACTION -LAW CUSTODY ~~,L`f~ Defendant COMPLAINT FOR CUSTODY Plaintiff, Denis M. Stump, Jr. by and through his attorney, L. Rex Bickley, Esquire, respectfully sets forth the following: 1. Plaintiff is Dennis M. Stump, who presently resides at 155 Northcrest Dr., York Haven, York County, PA 17370. 2. Defendant is Leslie Stump, who currently resides at 1145 East Columbia St., Enola, Cumberland County, PA 17025. 3 . The parties are the natural parents of Kacey Stump, born in Camp Hill, PA on August 23, 2000 and Kylie Stump born in Camp Hill, PA on September 17, 2001. 4. The parties were married sometime in February 2000 and divorced sometime in June, 2006. 5. For the past five (5) years the children have resided with the following persons at the following address: Mother 142 East Columbia St. 2/20/05 to present Enola, PA 17025 Mother and Father 2 East Pine St. Enola, PA 17025 Mother and Father 1400 Yocumtown Rd. Etters, PA 17319 Mother and Father 7/3/03 through 2/20/05 6/14/01 through 7/3/03 142 Meadowbrook Ct. 8/23/00 through 6/14/01 New Cumberland, PA 17070 5. Father has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 6. Father 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. 7. The Father seeks joint legal and physical custody of his children. 8. The best interest and permanent welfare of the children will be served by granting the relief requested because Father is in a position to provide love, support and care for his children. WHEREFORE, Plaintiff requests the court to grant primary physical custody of the children to Plaintiff. YC~I°~ Harrisburg, PA 17101 (717) 234-0577 (717) 234-7832 FAX Respectfully submitted, L. REX BICKL 114 South Str t VERIFICATION I, Dennis Stump, Jr. hereby verify that the information contained in the foregoing document is true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904 relating to unsworn falsification to authorities. Date: ~ ~ `J O ~ Dennis Stump, Jr. ' ' ` ~ ~' ~, (/~ _ `~ r_ L`t N C' ~--~ "T,3 ti t W '~ N c.a ~~ _~ _;_7 t Ld _~ 7 ~~ -< DENNIS M. STUMP, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA v. LESLIE STUMP Dt~~F~.NDANT • 07-1847 CIV[L ACTION LAW [N CUSTODY ORI)F,12 OF COURT AND NOW, 4 Tuesday, April 10, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. ,the conciliator, at 39 West Mam Street, Mechanicsburg, PA _17055 on Thursday, May 10, 2007 at 9:00 AM for aPre-l~~Iearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define a~~ld narrow the issues to be heard by the court, and to enter into a temporary order. All children ale 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/ _ Dawn S. Sunda Es ~ Custody Conciliator "I'he Court of Common Pleas of Crnnberland 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 ofCce. All arrangements must be made at ]east 72 hours prior to any hearing or business before tl~e 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 FORTI-1 BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 3? South Bedford Street Carlisle, Permsylvania 17013 Telephone (717) 249-3166 ~ ~~ ~~ ~ co h .h ~yv 2 ~„ .,,_l{ ,. ~ >r^~, ~~'~~ ~`'~~ i~ r~~;'~~ k•.1 AIAY 1420D7pi~ DENNIS M. STUMP, JR. Plaintiff vs. LESLIE STUMP Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 07-1847 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ~ ~ t~ day of ~. o. 2007, upon consideration of the attached Custody Conciliation Report, it is or ered and directed as follows: 1. The Father, Dennis M. Stump, 3r., and the Mother, Leslie Stump, shall have shared legal custody of Kasey Stump, born August 23, 2000 and Kylie Stump, born September 17, 2001. 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 their health, education and religion. Each parent shall be entitled to have equal access to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children beginning Friday, May 11, 2007, from Friday at 4:30 p.m. through Sunday at 5:00 p.m. 4. The parties shall share or alternate having custody of the Children on holidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall run from Christmas Day at 12:00 noon through December 26th at 12:00 noon. In odd-numbered years, the Mother shall have custody of the Children during Segment A and the Father shall have custody during Segment B. In even-numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. B. New Years: In every year, the Father shall have custody of the Children from New Year's Eve at 12:00 noon through New Year's Day at 2:00 p.m. C. Thanksgiving: In every year, the Mother shall have custody of the Children on Thanksgiving Day unti12:00 p.m. and the Father shall have custody of the Children from Thanksgiving Day at 2:00 p.m. through the following Friday at 2:00 p.m. D. Easter: In every year, the parent who has custody of the Children over Easter under the regular alternating weekend schedule shall have custody of the Children on Easter Sunday until 2:00 p.m. and the other parent shall have custody of the Children on Easter Sunday from 2:00 p.m. unti17:00 p.m. E. July 4~' : In odd-numbered years, the Father shall have custody of the Children on July 4th from 12:00 noon until after the fireworks and in even-numbered years, the Mother shall have custody of the Children for July 4th during the same time period. F. Mother's Dav/Father's Day: In every year, the Mother shall have custody of the Children on Mother's Day and the Father shall have custody of the Children on Father's Day from 11:00 a.m. until 7:00 p.m. G. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. The Father shall be entitled to have custody of the Children for 3non-consecutive weeks during the summer vacation each year upon providing at least 30 days advance notice to the Mother. The Father shall schedule his vacation periods under this provision to include his regular alternating weekend periods of custody. The Mother shall schedule any vacation periods to include her regular weekend periods of custody. The parent who provides notice first shall be entitled to preference on his or her selection of vacation dates. 6. Unless otherwise agreed between the parties, the parent receiving custody of the Children shall be responsible to provide transportation for the exchange of custody. 7. In the event either party intends to remove the Children from the Commonwealth of Pennsylvania for an overnight period or longer, that parent shall provide advance notice to the other parent of the address and telephone where the Children can be contacted. 8. The parties shall ensure that the Children are supervised at all times during his or her periods of custody and shall ensure that responsible individuals provide care for the Children whenever childcare is necessary. The Father shall not leave the Children in the care of their stepsister, Chelsea for a period in excess of one hour. 9. The non-custodial parent shall be entitled to have reasonable and liberal telephone and email contact with the Children. 10. Each parent shall ensure that the Children engage only in age appropriate activities during his or her periods of custody. 11. Each party shall ensure that the Children are transported in age appropriate car restraints during his or her periods of custody. 12. Each parent shall ensure that the Children attend all regularly scheduled activities during his or her periods of custody. 13. Neither party shall do or say anything which 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. Both parties shall ensure that third parties having contact with the Children comply with this provision. 14. 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, ~.~ ~~ cc: Rex Bickley, Esquire -Counsel for Father .~ ~acy Wolf, Esquire -Counsel for Mother /1.... G ~l ~ ~ I ~~~ ~ ~ 1~.~~1s~ ~~ ll DENNIS M. STUMP, JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 07-1847 CIVIL ACTION LAW LESLIE STUMP Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kasey Stump August 23, 2000 Mother Kylie Stump September 17, 2001 Mother 2. A custody conciliation conference was held on May 10, 2007 with the following individuals in attendance: the Father, Dennis M. Stump, Jr., with his counsel, L. Rex Bickley, Esquire, and the Mother, Leslie Stump, with her counsel, Stacy Wolf, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date -~ Dawn S. Sunday, Esquire Custody Conciliator r JUN 1110D~f DENNIS M. STUMP, JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 07-1847 CIVIL ACTION LAW LESLIE STUMP Defendant IN CUSTODY ORDER OF COURT ~th AND NOW, this _~ day of ~y ~ ~ 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Dennis M. Stump, Jr., and the Mother, Leslie Stump, shall have shared legal custody of Kasey Stump, born August 23, 2000 and Kylie Stump, born September 17, 2001. 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 their health, education and religion. Each parent shall be entitled to have equal access to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children beginning Friday, May 11, 2007, on alternating weekends from Friday at 4:30 p.m. through Sunday at 5:00 p.m. 4. The parties shall share or alternate having custody of the Children on holidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall run from Christmas Day at 12:00 noon through December 26~' at 12:00 noon. In odd-numbered years, the Mother shall have custody of the Children during Segment A and the Father shall have custody during Segment B. In even-numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. B. New Years: In every year, the Father shall have custody of the Children from New Year's Eve at 12:00 noon through New Year's Day at 2:00 p.m. C. Thanksgiving: In every year, the Mother shall have custody of the Children on Thanksgiving Day unti12:00 p.m. and the Father shall have custody of the Children from Thanksgiving Day at 2:00 p.m. through the following Friday at 2:00 p.m. D. Easter: In every year, the parent who has custody of the Children over Easter under the regular alternating weekend schedule shall have custody of the Children on Easter Sunday until ` en on Easter Sunday from 2:00 p.m• of the Clul~ Chil~en on anent shall have custody atlier shall have custody of the and the other p the F _numbered years, the Mother shall have 2:00 p'n'. tiered years, until ? :00 p •m• 4th In odd-num din even o f the E' Ju ~til after the fireworks ~ time period' ~ m 12:00 noon 4~ during the sam ear, the Mother shal n Farmer ss D y from July 4 fro e Children for July ather's Da : ~ every Y ° f the Children ° custody °f ~ F Mother s Da ~ over the regular s Day and the Father shall have Gusto y d take precedence Children on Mother ersede an 11:00 a•m• until? ~ The holiday custody schedule shall sup G consecutive weeks schedule. en for 3 non- other. custody °f the Childr s advance notice to the M on providing at least 30 day lar alternating he Father shall be entitled~tu have Gusto y vision to include his regu de her regular 5 • T der this pro eriods to incl during the summer vacation each ye eriods uri vacation p reference on his s vacation p The Mother shall schedule any of who provides notice first shall be entitle o The Father shall schcusto Y• weekend periods The parent weekend periods of custody. custody of the a es. the parent relinquishing or her selection of vacation between the parties, a of custody. (. Unless otherwise agreed s ortation for the eXChang onsible to provide trap p the Commonwealth of Children shall be resp intends to remove the C~ldren o° de advance notice to the other that parent shall p ~ • In the event either p p nod or longer ldren can be contacted. s lvania for an overnigh penny e address and telephone where the Chi n his or hWhenever anent of th a super~'ised at all times dung ldren p e Children ar rovide care f°r the Chs stet, Chelsea arties shall ensure that th onsible individuals p e of their step g. Thep and shall ensure that resp ods of custody ather shall not leave the Children m the c 1 pen The F d emai childcare is necessary. d liberal telephone ~ for a period in excess of one hOm' ent shall be entitled to have reasonable. an g. The non-custodial par • the Children. a only in age apprOpnate activities during contact with anent shall ensure that the Children engag restraints 10. Each p ropriate car his or her periods of custody. ldren are transP°rted in age app shall ensure that the Chi 11. Each party his or her periods of custody. end all regularly scheduled activities during during Each parent shall ensure that the Children a om the other 12. his or her periods of custody. a estrange the Children d natural an ping which rn y t or hamper the free ari e that tl 13. Neither party shall do or say yt' a oilier paten anent. Both parties shall ensur 'ure the opim°n °f the Children as to t for the other p parent, inJ 's love and resp rovision. 1 with this p development of the Children ies having contact with the Children comp y part 14. 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, ~~- cc: Rex Bickley, Esquire -Counsel for Father ~ ~8'tacy Wolf, Esquire -Counsel for Mother ~ ~ ~ ~~ ,.. "~'@~ IJ u t.. ~S .~ p~'d~ LJ i l it^ ~U~U .f. _ ...: DENNIS M. STUMP, JR. Plaintiff vs. LESLIE STUMP Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 07-1847 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kasey Stump August 23, 2000 Mother Kylie Stump September 17, 2001 Mother 2. A custody conciliation conference was held on May 10, 2007 with the following individuals in attendance: the Father, Dennis M. Stump, Jr., with his counsel, L. Re.c Bickiey, Esquire, and the Mother, Leslie Stump, with her counsel, Stacy Wolf, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~~/~~~7) '/ / " CC.tn L CO Date ~ ~ Dawn S. Sunday, Esquire Custody Conciliator 4. A Custody Order ("Order")was entered on June 18th, 2007 by the Honorable M.L. Ebert, Jr., clearly setting forth the physical custody of the children. A true and correct copy of the June 18th, 2007 Order is attached hereto and marked Exhibit "A". 5. Since entry of the June 18th, 2007 Order Mother has continually violated the physical custody mandates of this Court's Order. 6. Mother told Father that she would need to temporarily move to the state of Delaware in order to take care of her grandfather. However, it has come to Father's attention that Mother lied about caring for her grandfather, and in fact moved to Delaware with her paramour at the time, in which they shared a residence together. Mother did not inform Father of her current location and Father had no knowledge of the children's whereabouts. Only after an internet search was Mother's address revealed. Due to the long distance of the unauthorized move, Father has no way of exercising his partial custodial rights to children. Father called the Enola police in order to remedy the situation, but was told that there was nothing the police could do. 7. Since Mother's move out of state, Father has not been able to see the children in over three months, thus depriving Father of his custodial rights. 8. Mother did not provide Father with a current address where Mother or the children can be seen or contacted. 9. Mother's actions since entry of the last order concerning physical custody demonstrate her clear intent to willfully violate and disregard the provisions of the Order. 10. Father has incurred attorney fees and costs in preparation of this Petition and expects to incur additional attorney fees and costs to pursue relief on this Petition, totaling 2 approximately $1,000.00. Should this Court find Mother to be in contempt of the Court Order, Father requests an award of counsel fees for this Petition. 11. Father is also requesting primary physical custody of Kacey and Kylie to serve the best interest as well as the safety and welfare of the children. 12. Father believes the best interest of the children is no longer in the care of Mother's custody. The following is a summary of the events that occurred since the June 18tH, 2007 Order. a. Mother deceived Father by lying to him regarding the care of her grandfather. Through this deception, Mother was able to fraudulently move the children out of state. b. The move to Delaware has estranged Father from children and has hampered the free and natural development of the Children's love and respect for Father. c. The move to Delaware has interfered with the children's foundation and roots they have developed in the area. d. Since the move father has only been able to see the children once. This occurred around Christmas time when the children were brought to the house of Father's sister. Father was only able to see the children once his sister informed him that children were at her house. Mother never contacted or informed Father that the children were going to be there or were in fact there. e. The children are subjected to Mother's numerous paramours. Mother has several different men in and out of the residence since the move. The initial paramour was Marc Tisdale who moved into the Delaware residence. Mother then brought Anthony Conway into the marital residence and had the children 3 list Mr. Conway as their father on Facebook. Mr. Conway ended the relationship due to Mother's infidelity, at which time mother entered into a relationship with a third paramour. The third paramour was staying at the Delaware residence until he was arrested for attempted bank robbery, which can be confirmed by Mr. Tisdale. Mother is currently involved in a new relationship in which she goes out drinking on the weekends. Not only is this parade of paramours confusing to the children (who are being told other men are their father), but it also brings into question the safety and welfare of the children due to the character and criminal records of some of Mother's paramours. f. Finally, Mother's willful contempt for the June 18th, 2007, shows Mother's disregard for this Court and the best interest of the children. 13. There has been no evidence accepted by this Court on the record that demonstrates that Father is not a suitable choice to protect the welfare of the minor children pending a hearing in this case. Father is fully capable and prepared to assume primary physical custody of the children and protect them from harm. 14. Father is requesting that this Honorable Court enter an order transferring primary physical custody of the minor children to Father. 4 WHEREFORE, Petitioner Dennis Stump, respectfully requests that this Honorable Court find Mother to be in Contempt of the physical custody provisions of the Court's Order and award Father his reasonable counsel fees and costs incurred in pursing this Contempt Petition. Father further requests that primary physical custody of the minor children Kacey Stump and Kylie Stump be transferred to Father. Respectfully submitted: HYNUM LAW Date: C-aAktAIM is ael A. Hynum, Esqui Attorney I.D. 85692 2608 N. Third Street Harrisburg, PA 17110 Tele: (717) 774-1357 Fax: (717) 774-0788 5 VERIFICATION I, Dennis Stump, do hereby verify that the facts contained in the foregoing Petition are true and correct to be best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. Dated. Dennis Stump, Petitioner CERTIFICATE OF SERVICE I hereby certify that on this ?--? day of February, 2012 I served the foregoing Petition for Contempt and Petition for Modification of Existing Custody Order, by first class mail, postage prepaid upon the individual(s) indicated below, addressed as follows: Leslie Hunn 25930 Atlas Street Millsboro, DE 19966 Date. Michael A. Hynum, Esq ire Attorney I.D. 85692 2608 North 3`d Street Harrisburg, PA 17110 (717) 774-1357 (717) 774-0788 - fax Attorney for Dennis Stump EXHIBIT A JUN 1 1 200! DENNIS M. STUMP, JR. Plaintiff vs. LESLIE STUMP IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 07-1847 IN CUSTODY Defendant ORDER OF COURT CIVIL ACTION LAW AND NOW, this -__t _U 1 . day of \ _ , 2007, upon consideratlUil O llr: attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Dennis M. Stump, Jr., and the Mother, Leslie Stump. shall have shared legal custody of Kasey Stump, born August 23, 2000 and Kyhe Stump, born September 17, 2001. 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 their health, education and religion. Each parent shall be entitled to have equal access to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children beginning Friday, May 11, 2007, on alternating weekends from Friday at 4:30 p.m. through Sunday at 5:00 p.m. 4. The parties shall share or alternate having custody of the Children on holidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B. which shall run from Christmas :Day at 12:00 noon through December 26th at 12:00 noon. In odd-numbered years, the Mother shall have custody of the Children during Segment A and the Father shall have custody during Segment B. In even-numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. B. New Years: In every year, the Father shall have custody of the Children from New Year's Eve at 12:00 noon through New Year's Day at 2:00 p.m. C. Thanksgivina: In every year, the Mother shall have custody of the Children on Thanksgiving Day until 2:00 p.m. and the Father shall have custody of the Children from Thanksgiving Day at 2:00 p.m. through the following Friday at 2:00 p.m. D. Easter: In every year, the parent who has custody of the Children over Easter under the regular alternating weekend schedule shall have custody of the Children on Easter Sunday until 2:00 p.m. and the other parent shall have custody of the Children on Easter Sunday from 2:00 p.m. until 7:00 p.m. E. July 4t° : In odd-numbered years, the Father shall have custody of the Children on July 4th from 12:00 noon until after the fireworks and in even-numbered years, the Mother shall have custody of the Children for July 4th during the same time period. F. Mother's Dav/Father's Day: In every year, the Mother shall have custody of the Children on Mother's Day and the Father shall have custody of the Children on Father's Day from 11:00 a.m. until 7:00 p.m. G. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. The Father shall be entitled to have custody of the Children for 3 non-consecutive weeks during the summer vacation each year upon providing at least 30 days advance notice to the Mother. The Father shall schedule his vacation periods under this provision to include his regular alternating weekend periods of custody. The Mother shall schedule any vacation periods to include her regular weekend periods of custody. The parent who provides notice first shall be entitled to preference on his or her selection of vacation dates. 6. Unless otherwise agreed between the parties, the parent relinquishing custody of the Children shall be responsible to provide transportation for the exchange of custody. 7. In the event either party intends to remove the Children from the Commonwealth of Pennsylvania for an overnight period or longer, that parent shall provide advance notice to the other parent of the address and telephone where the Children can be contacted. 8. The parties shall ensure that the Children are supervised at all times during his or her periods of custody and shall ensure that responsible individuals provide care for the Children whenever childcare is necessary. The Father shall not leave the Children in the care of their stepsister, Chelsea for a period in excess of one hour. 9. The non-custodial parent shall be entitled to have reasonable and liberal telephone and email contact with the Children. 10. Each parent shall ensure that the Children engage only in age appropriate activities during his or her periods of custody. 11. Each party shall ensure that the Children are transported in age appropriate car restraints during his or her periods of custody. 12. Each parent shall ensure that the Children attend all regularly scheduled activities during his or her periods of custody. 13. Neither party shall do or say anything which may estrange the Children from the other parent. inure 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. Both parties shall ensure that third parties having contact with the Children comply with this provision. 14. 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, ? 14A. Ci . i ? ?' 1 cc: L. Rex Bickley, Esquire - Counsel for Father Stacy Wolf, Esquire - Counsel for Mother EVE COPY FROM RECORD 0 into set my hand a s/Ieo° o ; lisle P Pro 000tary c ?W ..nom IT Z Z? M Ck7 'L7 Hynum Law r--= -4 C?-' Michael A. Hynum, Esquire E:7 Attorney I.D. 85692 2608 North 3rd Street ? 3 "- ' Harrisburg, PA 17110 " t (717) 774-1357 C J i - (717) 774-0788 - fax Attorney for Dennis Stump DENNIS M. STUMP, JR. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW -v- : NO. 07-1847 LESLIE STUMP : IN CUSTODY Defendant PRAECIPE TO ENTER APPEARANCE To the Prothontary: Kindly enter my appearance for the above captioned case. Respectfully submitted: Date: By: ich el A. Hynu , I.D. No. 85692 Hynum Law 2608 N. Third Street Harrisburg, PA 17110 Tele: (717) 774-1357 Fax: (717) 774-0788 CERTIFICATE OF SERVICE On this jz day of February, 2012, 1 certify that a copy of the foregoing Praecipe to Enter Appearance was served upon Defendant by placing the same in the United States mail, first class, postage prepaid, addressed as follows: Leslie Hunn 25930 Atlas Street Millsboro, DE 19966 r Date: I f A 4,44:) Michael A. Hynum, s u e Attorney I.D. 85692 2608 North 3d Street Harrisburg, PA 17110 (717) 774-1357 (717) 774-0788 - fax Attorney for Dennis Stump DENNIS M. STUMP, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA 2007-1847 CIVIL ACTION LAWS rn--` _.r r- --o LESLIE STUMP --< N sp M C) IN CUSTODY t-a cz; ? - T DI FENDANT sa. CD , C, :;Z. c 1 {, ORDER OF COURT - : c.,? = AND NOW, Tuesday, Februar y 28, 2012 , upon consideration of the attached Complaint , it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at,---- 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, March 22, 2012 at 11:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ Daum S. Sunda Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association V16T4. ??? n'e?GEtZ ?eoP ? ,?,a?Ged 7'0 32 South Bedford Street Carlisle, Pennsylvania 17013 "Telephone (717) 249-3166 `U ?? ??'IUN? (-o' 17,4i1eyl? r a/ ? DENNIS M. STUMP, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2007-1847 CIVIL ACTION -- LAW LESLIE STUMP, IN CUSTODY Defendant ?ry - w -- M CD ,Yt r z ?0 xw :;;a i` -'j PRAECIPE FOR ENTRY OF APPEARANCE U') u: , CD C To David D. Buell, Prothonotary: .; ^ - Please enter my appearance on behalf of the Defendant, Leslie Stump (n/k/a? Leslie Hunn), in the above captioned case. n?7 Jessie of t, Es ire MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 Respectfully submitted, Date: ?? 12.. DENNIS M. STUMP, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2007-1847 CIVIL ACTION -- LAW LESLIE STUMP, IN CUSTODY Defendant CERTIFICATE OF SERVICE I, Jessica Hoist, Esquire, of MidPenn Legal Services, attorney for the Defendant, Leslie Stump (n/k/a Leslie Hunn), hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: U.S. First Class Mail, Postaize Pre-Paid Michael A. Hynum, Esquire Hynum Law 2608 North Third Street Harrisburg, PA 17110 Date: > > 1 i essi 11st, squire Mid enn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 DENNIS M. STUMP JR. Plaintiff vs. LESLIE STUMP Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007-1847 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ? th day of %'r 'r L? , 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall submit themselves, their minor Children, and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by a professional selected by agreement between the parties. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best meet the needs of the Children. The Father shall be responsible to pay all costs of the evaluation. The parties shall sign any authorizations deemed necessary by the evaluator in order to obtain additional information pertaining to the parties or the Children. The Mother shall schedule, attend and make the Children available for all evaluation appointments in a prompt manner in order to obtain the recommendations at the earliest possible date. 2. Pending completion of the custody evaluation and further agreement of the parties or Order of Court, the prior Order of this Court dated June 18, 2007 shall continue as modified by this Order. The Father shall have partial physical custody of the Children on alternating weekends from Friday at 8:00 p.m., when the parties shall exchange custody at the Rutter's store at the Newberrytown exit on Route 83, through Sunday at 5:00 p.m. when the parties shall exchange custody at the designated location at Colonial Park Mall. The Father's first weekend period of custody under this provision shall take place on March 30, 2012, the Father shall have the immediately following custodial weekend which begins on April 6 and on alternating weekends thereafter. 3. For the summer in 2012, the Father shall have custody of the Children beginning on the first weekend after the last day of school through the last weekend in July which ends on July 29 and the Mother shall have custody of the Children for the remainder of the summer school break. The parties shall continue the alternating weekend custody schedule throughout the summer. 4. The parties shall not discuss the details of the legal proceedings concerning custody with the Children. 5. Within 60 days of receipt of the written custody recommendations, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary. 6. 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, h M. L. Ebert Jr. J. cc: ?/ Eric J. Bialas Esquire - Counsel for Father Jessica Holst Esquire - Counsel for Mother - 0 1 P. C '. ?- DENNIS M. STUMP JR. Plaintiff vs. LESLIE STUMP Defendant : Prior Judge: M.L. Ebert Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007-1847 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kacey Stump August 23, 2000 Mother Kylie Stump September 17, 2001 Mother 2. A custody conciliation conference was held on March 22, 2012, with the following individuals in attendance: the Father, Dennis M. Stump Jr., with his counsel, Eric J. Bialas Esquire, and the Mother, Leslie Hunn, formerly Stump, with her counsel, Jessica Holst Esquire. 3. The parties agreed to entry of an Order in the form as attached. 1 Date Dawn S. Sunday, Esquire Custody Conciliator DENNIS M. STUMP, JR. Plaintiff -v- LESLIE STUMP Defendant z IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 07-1847 IN CUSTODY RULE TO SHOW CAUSE ti May AND NOW, this 3 day of-Arri}, 2012, upon consideration of the Petition to withdraw as Counsel, it is hereby ORDERED that a RULE is issued upon Leslie Hunn (Stump) and Dennis Stump to show cause, if any, within 2 0 days of service, why the requested relief in the Petition should not be granted. BY THE COURT: Distribution: ? Michael A. Hynum, Esquire, 2608 N. 3rd Street, Harrisburg, Pa 17110 Jessica Holst, Esquire, Mid Penn Legal Services, 401 E. Louther Street, Suite 103, Carlisle, PA 17013 Dennis Stump, 3130 Lewisberry Road, Yorkhaven, PA 17370. -x DENNIS M. STUMP, JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-1847 CIVIL TERM - LAW LESLIE STUMP, Defendant CUSTODY ANSWER TO PETITION FOR LEAVE TO WITHDRAW 1. Admitted. ?. C `'I 2 Admitted rn a -, . . 3. Admitted: ° ' ZZ 4. Admitted. a 31 '. r ti.a c..i 5. Admitted to parts (a) and (b). - , 6. Admitted. 7. Admitted. 8. It is unknown the circumstances under which Petitioner seeks to withdraw from this case. 9. Respondent does not have sufficient information to admit or deny this allegation. 10. Admitted. 11. Admitted. WHEREFORE, Defendant concurs with the withdrawal request of Michael A. Hynum, Esquire. Date: May 8, 2012 tted, , RNullj mi 3es a 1st, Esquire Mi enn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 DENNIS M. STUMP, JR. Plaintiff _v_ LESLIE STUMP Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 07-1847 IN CUSTODY ORDER 1%\ AND NOW, this 16 day of J %-L , 2012, upon consideration of the Petition to Withdraw as Counsel, the Motion to Make Rule Absolute, and noting that no party has filed an objection to the Petition, it is hereby ORDERED that the request is GRANTED. Hynum Law and Michael A. Hynum, Esquire are withdrawn as counsel for Dennis Stump in the above-captioned matter. BY THE COURT: Distribution: Michael A. Hynum, Esquire, 2608 N. 3rd Street, Harrisburg, Pa 17110 y Jessica Holst, Esquire, Mid Penn Legal Services, 401 E. Louther Street, Suite 103, Carlisle, PA 17013 Dennis Stump, 3130 Lewisberry Road, Yorkhaven, PA 17370. m f"-1 ?9 t. .