HomeMy WebLinkAbout01-05610
SEP ~~~2009
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FAMILY COURT DIVISION
RENEE R RIDOLFI
vs.
JAMES PATRICK RICHARDS
ORDER
AND NOW, to wit, this
No. O 1 ~ 56 ~ ~
IN CUSTODY
~ ~ day of Oc~u/n,,. 2001, based upon the
Stipulation of the Parties, it is hereby ORDERED and DECREED as follows::
1. Mother and Father shall share joint legal custody of their minor child. Michael James Ridgy.
Mother and Father shall have an affirmative obligation to consult with one another on major
decisions affecting the Child agreeing that the Child's best interest shall be their paramount
wncern. It is understood that joirrt legal custody includes the right of each parent to have access to
all the Child's medical, dental and educational records and participate actively in the Child's life
events.
2. Mother shag have primary physical custody and Father shall have partial physical custody ofthe
child according to the following schedule:
a. Altenutte weekends from Friday at 6:00 p.m. until Sunday at 4:00.
b. In odd numbered years, Mother shall have the child from New Years Eve at noon through
New Years Day at noon, Easter, Fourth of July, Thanksgiving, and Christmas Day at noon
through pecember 26~' at noon. In odd numbered years, Father shall have the child
Presidents Day weekend, Memorial Day weekend, Labor Day weekend and Christmas Eve
at noon through Christmas Day at noon. The scheduled would be reversed during even
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numbered years. The holiday weekends shaft be defined at Friday at 6:00 p.m. through
Monday at 4:00 p.m. Arrangements for holiday times not defined herein shall be by
agreemenrt of the parties at least twenty-four (24) hours in advance.
c. Father shall have the child on Father's birthday and Father's Day; Mother shall have the
child on Mother's birthday and Mother's Day. Father and Mother shall each have quality
time with the child on the child's birthday. Times for partial custody on Mother's Day,
Father's Day and birthdays shall be arranged by agreement of the parties at least twenty-
four (24) hours in advance.
d. ffno agreement is reached in advance, the default holiday times, not otherwise defined
herein, shall be from 9;00 a.m. to 7:00 p.m.
e. Beginning when the child starts school, the parents will split the Christmas and spring
school vacations with each parent having that portion of the school vacation that coincides
most closely with the Christmas Day and Easter holidays as described herein.
f Both parents shall have up to four (4) weeks of custody time with the child duxing each
calendar year with a maximum of two (2) weeks being consecutive. Notice of such times
shall be communicated to the other parent at least thirty (30} days in advance. Unused
vacation time shall not be carried over into the next calendar year.
g. Other periods of partial custody may be arranged by agreement of the parties at least
twenty-four (24) hours in advance.
h. Pickup and drop off of the child for transfer of custody shalt be at either the Shrewsbury
exit on Route I-83 or the Reading exit (Exit 21) on the Pennsylvania Turnpike, the exact
Iocation to be communicated to Mother at least twenty-four (24) hours in advance.
3. As appropriate to the age of the child, each patent shall have liberal and reasonable mail and phone
,'
access to the child while in the custody of the other parem. Otherwise, telephone contact betw~n
the pazents concerning the child shall be reasonable and, except in emergencies, confined to the
hours of 9:00 a.m. to 9:30 p.m. Each parent will keep the other advised at all times of their current
address and phone number. Both pazents shall provide an itinerary of any planned vacation with
the child, including specific destinations, phone members, means of travel, departure and arrival
times, to the other pazent at least two (2) weeks prior to said vacation.
Notice of any planned relocation out of the county of each parent's currern residence shall be
4.
provided to the other pazent at least sixty (60j days prior to the a~icipated move, in writing by
certified mail, to the other parent.
The parents agree to cooperate with each other in the fullest in the upbriugiug of their child, and
further agree to foster a good relationship between the child and the other parent and that parent's
extended family. Mother and Father shall neither alienate nor attempt to alienate or destroy the
affection of the Child for each other or any other person to whom the Child is related by blood or
marriage, bui shall instead exert every reasonable effort to foster a feeling of affection between the
Child and each other or any other related person.
In the eves one of the pazerrts dies before the child reaches his majority, the other pazent shall have
full guardianship of the child. to the event both parents die before the child reaches his majority,
the parents have designated the child's maternal grandparents as guardians of the child, and, if they
are unable or unwilling to assume said guardianship, the pazeuts have designated the child's
paternal grandparents as guazdians of the child.
6.
~° a.~d
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BY THE COURT:
STIPULATION FOR CUSTODY AND CHILD SUPPORT
AND NOW, to wit, this JT7H day of tJ G n. L , 2001, it is
Stipulated by and between JAMES PATRICK RICHARDS {"Father") and RENEE R. RIDOLFI
("Mother's that the parties to this Stipulation desire that their minor child, MICHAEL JAMES
RIDOLFI, born March 5, 2001 maintain a positive relationship with bath of their pazents, and to
further this goal, and intending to be bound thereby, the parties agree as follows::
CUSTODY
Mother and Father shall share joint legal custody of their minor child. Mother and Father shall
have an affirmative obligation to consult with one another on major decisions affecting the
Child agrceing that the Chdd's best merest shall be their paramount concern. It is understood.
that joint legal custody includes the right of each pazent to have access to all the Child's
medical, dental and educational records and participate actively in the Child's life events.
Mother shall have primary physical custody and Father shall have partial physical custody of
the child according to the following schedule:
a. Alternate weekends from Friday at 6:00 p.m. until Sunday at 4:00.
b. ~ In odd ttwnbered years, Mother shall have the child from New Years Eve at noon
through New Years Day at noon, Easter, Fourth of July, Thanksgiving, and Christmas
Day at noon through December 26`x' at noon. In odd numbered yeazs, Father shall have
the child Presides Day weekend, Memorial Day weekend, Labor Day weekend and
Chrishnas Eve at noon through Christmas Day at noon. The scheduled would be
reversed during even numbered years. The holiday weekends shall be defined at Friday
-1-
a
at 6:00 p.m. through Monday at 4:00 p.m. Arrangeme~s for holiday times not defined
herein shall be by agreemer of the patties at least rive~y-four (24) hours in advance.
c. Father shall have the child on Father's birthday and Father's Day; Mather shall have
the child on Mother's birthday and Mother's Day. Father and Mother shall each have
quality time with the child on the child's birthday. Times for partial custody on
Mother's Day, Father's Day and birthdays shall be arranged by agreement of the
parties at least tweffiy-four (24) hours in advance.
d. ff no agreement is reached in advance, the default holiday times, not otberwise defimed
herein, shall be from 9:00 a.m. to 7:00 p.m.
e. Beginning when the child starts school, the parents will split the Christmas and spring
school vacations with each parent having that portion of the school vacation that
coincides most closely with the Christmas Day and Easter holidays as described herein.
f. Both pareffis shall have up to four (4) weeks of custody time with the child during each
calendar year with a maximum of two (2) weeks being consecutive. Notice of such
times shall be communicated to the other parent at least thirty (30) days in advance.
Unused vacation time shall not be carried over into the next calendar year.
g. Other periods of partial custody may be arranged by agreement of the parties at least
twenty-four(24) hours in advance.
h. Pick up and drop off of the child for transfer of custody shall be at either the
Shrewsbury exit on Route I-83 or the Reading exit (Exit 21) on the Pennsylvania
Turnpike, the exact location to be communicated to Mother at leasttwenty-four (24)
hours in advance.
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3. As appropriate to the age of the child, each parent shall have liberal and reasonable mail aad
phone access to the child while in the custody of the other parent. Otherwise, telephone co~rtact
between the parents concerning the child shall be reasonable and, except in emergencies,
confined to the hours of 9:00 a.m. to 9:30 p.m. Each pazent will keep the other advised at all
times of their curretrt address and phone number. Bath parents shall provide an itinerary of any
planned vacation with the child, including specific destinations, phone numbers, means o£
travel, departure and azrivai times, to the other parent at IeasC two (2) weeks prior to said
vacation.
4. Notice of any planned relocation out of the coantY of each parent's curteirt residence shall be
provided to the other pazent at least sixty (60) days prior to the anticipated move, in writing by
certified mail, to the other paze~rt.
5. The pazerrts agree to cooperate with each other in the fullest in the upbringing of their child, and
further agree to foster a good relationship between the child and the other pazeirt and that
pazent's extended family. Mother and Father shall neither alienate nor attempt to alienate or
destroy the affection of the Child for each other or any other person to whom the Child is
related by blood or marriage, but shall instead exert every reasonable effort to foster a fceling of
affection between the Child and each other or any other related person.
6. The pares hereby confirm their intent and desire that in the event one of the parents dies
before the child reaches his majority, the other parent shall have frill guazdianship of the child.
In the evert both pazents die before the child reaches his majority, the pareirts hereby designate
the materrraF grandparents as guardians oftbe child; and, if they aze unable or umvilling to
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assume said guardianship, the pazerns hereby designate the paternal grandparents as guardians
ofthe child.
7. It is understood and agreed that the Custody provisions of this Stipulation shall be presented by
Mother to the Cumberland County Court of Common Pleas to be confirmed by Order of Court.
CI3ILD SUPPORT
8. Father shall pay the sum of $400.00 per mornh for child support plus $500.00/mornh to
reimburse Mother for child care costs incurred during her hou~`r~s~°to~f employmern. ~,~
Paovl a4o fA7N4t cerorwrw ict /h07xct Fec -~1t OjfFtalt ~vn1`gicfJ PglO~ ~'LoTi~ Sx4LC lWy/yG 7yE
9. ' . M ~ provide to Father receipts for d fxsrl,
~ c,,vo Uwl~ CA2c CneoE} ~ • ``
care expenses upon request. ra -~nra, ~ E .~.r4l,~n . ~,
10. Mother will provide medical and dental insurance for the child Unreimbursed medical and
dental expenses, after r&e first $250.00 per calendar year to be home by Mother, shall be y
divided between the patties, Father paying 80% and Mother paying 20% thereof.
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11. It is understood and agreed that if Father fails to make child support payments as agreed herein,
Mother may seek enforcement of this agreement through her county's Domestic Relations
Court.
JABS PATRICK RICRIARDS, Father
N~Ov/TARIZED:
Sworn tm and eubsaibed before Erp
Uue~deyotJVl~E. vz~~b
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RE E R. RIDOLFI, Moth r
NOTARIZED: ~--~
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Notarial coal
tktk E. fernry~ Notary Public
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RENEE R. RIDOLFI IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
• 01-5610 CIVIL ACTION LAW
JAMES PATRICK RICHARDS
DEFENDANT IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, Ma Ol, 2002 ,upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, May 21, 2002 at 1:30 PM
for aPre-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: /s! Jacqueline M. Verne, Est ,nom
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 2990. 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
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F:\F-.ES\DATAFILE\Gendoacw'\10369-PET.1/tde
Created: 04/I V0203:26:59 PM ~
Rcnecd 04/29/02IL10:92 AM
RENEE R. RIDOLFI, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
v. NO.Ol-5610 -CIVIL ACTION -LAW
JAMES PATRICK RICHARDS,
Defendant/Petitioner IN CUSTODY
ORDER OF COURT
AND NOW, this _ day of ,upon consideration of the attached Petition
for Modification, it is hereby directed that the parties and their respective counsel appear before
,the conciliator, at
on the day of , at .m. for aPre-Hearing
Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter
into a temporary order. All children age five or older may also be present at the conference. Failure
to appear at the conference may provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
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 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
RENEE R. RIDOLFI,
PIaintiff/Respondent
v.
JAMES PATRICK RICHARDS,
Defendant/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5610 -CIVIL ACTION -LAW
IN CUSTODY
PETITION OF JAMES PATRICK RICHARDS TO MODIFY CUSTODY
AND NOW, comes the Defendant, James Patrick Richards, by and through his attorneys,
MARTSON DEARDORFF WILLIAMS & OTTO and files this Petition as follows:
1. Defendant, James Patrick Richards (herinafter "Petitioner"), is an adult individual
residing at 5752 Goldfinch Court, Ellicott City, MD 21043.
2. Plaintiff, Renee Ridolfi (hereinafter "Respondent"), is an adult individual residing
at 32 Scansdale Drive, Camp Hill, PA 17011.
3. The parties are the parents of Michael James Ridolfi, (hereinafter "Michael") born
March 5, 2001.
4. On October 1, 2001, this Court entered an Order of Court granting shared legal
custody of Michael between the parties, with Petitioner having partial physical custody, a copy of
said Order is attached hereto and marked as Exhibit "A."
5. Petitioner hasnowbecometheprimarycustodianofMichaelandisbetterabletoraise
Michael.
WHEREFORE, Petitioner, James Patrick Richards, prays your Honorable Court to issue an
Order amending the Order of October 1, 2001 wherein directing that he has primary physical custody
of the child, Michael James Ridolfi, and Respondent, Renee Ridolfi, shall have partial physical
custody as the parties may agree. The balance of the October 1, 2001 Order would remain in effect.
MARTSON DEARDORFF WILLIAMS & OTTO
By-~ - ° ACS ~.~
Thomas 7. Willi Esquire
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Defendant
Date: Apri129, 2002
~~P 2&'2101
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FAMILY COURT DIVISION
RENEE R RIDOLFI No. O / ' ~~ ~0
vs.
JAMES PATRICK RICHARDS
IN CUSTODY
ORDER
AND NO~'V, to wit, this ~ 5} day of C ~ 2001, based ups the
Stipulation of the Parties, it is hereby ORDERED and DECREED as follows::
1. Mother and Father shall share joint Legal custody of their minor child. Niched James Ridvlfi.
Mother and Father shall have an affimrative obligation to consult with one another ~ major
decisions affecting the Child agreeing that the Child's best interest shall be their paramoutrt
concern. It is understood that joint legal custody includes the right of each parent to have access to
all the Child's medical, dental and educational records and participate actively in the Child's life
evems.
2. Mother she[[ have primary physics! custody and Father shat[ have partial physical eustaay of the
elilid according to the following schedule:
a. Alternate weekends tiom Friday at 6:00 p.m. until Sunday at 4:00.
b. 1n odd numbered years, Mother shall have the child from New Years Eve at noon through
New Years Day at noon, Easter, Fourth of July, Thanksgiving, and Chuistmas Day at noon
through December 26°i at noon. In odd numbered years, Father shall have the child
Presidents Day weekend, Memorial Day weekend, Labor Day weekend and Christmas Eve
at noon through Christroas Day at noon. The scheduled would be reversed during even
EXHIBIT "A"
numbered yeazs. The holiday weekends shall be defined at Friday at 6:00 p.m. through
Monday at 4:00 p.m. Arrangements for holiday times not defined herein shall be by
agreement of the parties at feasttwenty-four (24} hours in advance.
c. Father shall have the child on Father's birthday and Father's Day; Mother shall have the
child on Mother's birthday and Mother's Day. Father and Mother shall each have quality
time with the child on the child's birthday. Times for partial custody on Mother's Day,
Father's Day and birthdays shall be arranged by agreement of the parties at least twenty-
four (24j hours in advance.
d. If no agreement is reached in advance, the default holiday times, not otherwise defined
herein, shall be Snm 9:00 a.m. to 7:00 p.m.
e. Beginning when the child starts school, the parents will split the Christmas and spring
school vacations with each parent having that portion of the school vacation that coincides
most closely with the Christmas Day and Easter holidays as described herein.
f. Both parents shall have up to four (4) weeks of custody firm with the child during each
calendar year widr a martirnaur of two (2) weeks being consecutive. Notice of such times
shall be communicated to flu; other pazert at least thirty (30) days in advance. Unused
vacation time shall not be carried over into the next caierrdar year.
g. Qther periods of partial custody may be arranged by agreement of the parties at least
twerrty-four (24) hours in advance.
h. Pick up and drop off ofthe child for transfer of custody shall beat either the Shrewsbury
exit on Route I-83 or the Reading exit (Exit 21) on the Pennsylvania Turnpike, tha exact
location to be communicated to Mother at Leasttwenty-four (24) hours in advance.
3. As appropriate to the age of the child, each parem shall have liberal and reasonable mail and phone r
access to the child while in the custody of the other pazent. Otherwise, telephone contact between
the parems concerning the child shall be reasonable and, except in emergencies, confined to the
hours of 9:00 a.m. to 9:30 p.m. Each pazent will keep the oilier advised at all times of their current
address and phone number. Both parents shall provide an itinerary of any planned vacation with
the child, including specific destinations, phone numbers, means of travel, departure and amva!
times, to the other parent at least two (2) weeks prior to said vacation.
4. Notice of any planned relocation out of the county of each parent's current residence shall be
provided to the other parent at least sixty (60) days prior W the anticipated move, in writing by
certified mail, to the other parent.
The parents agree to cooperate with each other in the fullest in the upbringing of their child, and
further agree to foster a good relationship between the child and the other parent and that parerrt's
extended family. Mother and Father shall neither alienate nor attempt to alienate of destroy the
affection of the Child for each other ar any other person to whom the Child is related by blood or
marriage, but shall instead exert every reasonable effort to foster a feeling of affection between the
Child and each other or any other related person.
6. In the everrt one of the parents dies before the child reaches his majority, the other pazeffi shall have
full guardianship of the child. In the event both parearts die before the child reaches his majority,
the parents have designated the child's maternal grandparers as guardians of the child, and, if they
aze unable or unwilling to assume said guazdianship, the patents have designated the child's
paternal grandparents as guardians of the child.
BY THE COURT:
TRUE C®RY FROM RED^R®
In Testimony whereof, I here unfe-::t my hand
and se I of sai Court rli le, Pa.
f..~...... f...~..., ~.~
s 7.
STIPULATION FOR CUSTODY AND CRII.D SUPPORT
AND NOW, to wit, this 5-7H day of `/ G~,L 2001, it is
Stipulated by and between JAMES PATRICK RICHARDS ("Father's and RENEE R. RIDOLFI
("Mother's that the parties to this Stipulation desire that their minor child, MICHAEL JAMES
bom March 5, 2001 maintain a positive relationship with both of their parents, and to
further this goal, a~ intending to be bound thereby, the parties agree as follows::
SCU TODY
1. Mother and Fathom shall share joint legal eustady of tl~ir minor child. Mather and Father shall
have an affirmative obligation to consult with o~ another on major decisions affecting the
Child agreeing that the Child's best interest shall be their paramotmt concern. It is understood.
that joint legal. custody includes the right of each parent to have access to all the Child's
medical, deatai and educational records and participate actively in the Child's Life eves.
2. Mother shall have primary physical custody and Father shall have partial physical cawstody of
the child according to the following schedule:
a. "Alternate weeke+tds from Friday at 6:00 p.m, until Sunday at 4:00.
b. In odd numbered years, Mother shall have the drild from New Years Eve at noon
through New Years Day at noon, Easter, Fourth of July, Thanksgiving, and Christmas
Day at noon through December 2G'' at noon. In odd numbered years, Father shall have
the child Presided Day weekend, Memorial Day weekend, Labor Day weekend and
Christmas Eve,at noon through Christmas Day at noon. The scheduled would be
reversed during even aumbeted years. The holiday weekends shall be deSned at Friday
-I-
~ ~ __
at 6:00 p.m. through Monday at 4:00 p.m. Arrangements for holiday times not defined
herein shall be by agreement of fhe patties at least twenty-four (24) hours in advance.
c. Father shall have the child on Father's birthday and Father's Day; Mother shall have
the child on Mother's birthday and Mother's Day. Father and Mother shall each have
quality time with the child on the child's birthday. Times for partial custody on
Mother's Day, Father's Day and birthdays shall be arranged by agreement of the
parties at leasttwenty-four (24) hams in advance.
d. ffno agreement is reached in advance, the default holiday times, not otherwise defined
herein, shall be from 9:00 a.m. to 7:00 p.m.
e. Beginning when the child starts school, the parents will split the Christmas and spring
school vacations with each parent havigg that portion of the school vacation that
coincides most closely with the Christmas Day and Easter holidays as described herein.
f. Bath parents snail have up to font (4) weeks of custody time with the child during each
calendar yeaz with a maximum of two (2) weeks being consecutive. Notice of such
times shall be communicated to the other parent at least thirty (30) days in advance.
Unused vacation tip shall not be carried over into dre next calendar year.
g. Other periods of partial a~stody may be arranged by agrearterrt of the parties at least
twenty-four (24) hours in advance.
h. Pick up and drop off of the child for transfer of custody shall be at either the
Shrewsbury exit on Route I-83 or the Reading exit (Exit 21) on the Pennsylvania
Turnpike, the exact location to be commiwicated to Mother at least tweny-four (24)
hours in advance.
-2-
_.~,__ ._. _ i _mi - - ~
3. As appropriate to the age of the child, each parent shall leave liberal and reasonable mail and
pho~ access to the child while in the custody of the other parent. Otherwise, telephone contact
between the parents concerning the child shall be reasonable and, except in emergencies,
confineA to the hours of 9:00 a.m. to 9:30 p.m. Each pared will keep the other advised at all
times of their current address and phoan number. Both parents shall provide an itinerary of any
planned vacation with the child, including specific destinations, pho~ numbers, means of
travel, departure sad arrival times, to the otlrer parerrt at leasttwo (2) weeks prior to said
vacation.
4. .Notice of any planned relocation out of the county of each parent's current residence shall be
provided to the other patent at least suety (60) days prior to the anticipated move, in writing by
certified mail, to the other parent.
5. The parents agree W cooperate with each other in the fullest in the upbringing of their child, and
further agree to foster a good relationship between the child a~ the other parent and that
parent's extended family. Mother and Father shall neither alienate nor attempt to alienate or
destroy the affection ofthe Child for each other or any other persa~n to whom the Child is
related by blood or marriage, but shall instead exert every reasonable effort to foster a feeling of
affecticn between the Child and each other or any other related person.
6. - The parents hereby confirm their intent and desire that in the event ot~ of the pazenis dies
before the child reaches his majority, the other parent shall have full guardianship of the child.
In the evert both parents die before the child reaches his majority, the parents hereby designate
the materrrdl grandparents as guardians of the child, and, if they are unable or umvilling to
-3-
_ ___ ~.
assume said guardianship, the parems hereby design'ste the paternal grandparents as guarr~ans
NOTARIZED: CJ'I~tfitOr-
ofthe mild.
It is understood and agreed that the Custody provisions of this Stipulation shall be presented by
Mother to tbe Cumberland County Court of Canmon Pleas to be confirmed by Urder of Cant.
CPI.[LD SUPPORT
8. Father shall pay the sum of $400.00 per march for child support plus $500. W/marth to
reimburse Mother for child care incurred during her hou~r~s~tof employment. ~9(~''~sti
P/lnulA4e FIrTNSC eewrwswm />re~x~c <ae 'rl+i 9/fi[NL6 ~tiP~RXtr F~IOj /S1o7Ne! SN4u My,,.~ 7Aic
9. .. Mother will provide to Father receipts for ~d
~ Cv~4 Ch~l~ curr~e Caeu~~ ~,
. Care' expemaes Upar IequesE IN YAYA+ d E }.a~~FH.. ~....
10. Mother will provide medical and denial insurance for the child^ Unreimbursed medical and
dental expenses, after the first $250.00 per calendar year to be borne by Mothet, shall be try
divided between the parties, Father paying 80% and Mather paying 20'/o thereof.
11. It is n~erstood and agreai that if Father fails to make child support payments as agreed herein.,
Mother may seek enforcemart of this agreement through her county's Domestio Relations
Court.
. .lr/
J ~ S PATRICK RIC LARDS, Father EE R RIDOI,FI, Mo
SWORI ~ and 611b8Crlbld blt0/A Rle
this~dayct~s:"i ~'LO.r~
NOTARIZED: ~~
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Netarisl ,sal
Dirk E. Be Nrnary Public
-4- tianiaburg, Dauphin Courrty
Sly ~Tranmissinn Fr ras A r. 28, 2ts~3
Man:t~9t Fe!wry~we~ r0 As69;iatl3n et Pk+tm°~es
VERIFICATION
The foregoing Modification of Custody is based upon information which has been gathered
by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and
not my own. I have read the document and to the extent that it is based upon information which I
have given to my counsel, it is true and correct to the best of my knowledge, information and belief.
To the extent that the content of the document is that of counsel, I have relied upon counsel in
making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
J P. Richards
Ir - ~
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby
certify that a copy of the foregoing Petition to Modify was served this date by depositing same in the
Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
James K. Jones, Esquire
7 Irvine Row
Carlisle, PA 17013
MARTSON DEARDORFF WILLIAMS &
Tncia D. Eckemoad
T-en East High Street
Carlisle, PA 17013
(717)243-3341
Dated: Apri129, 2002
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RENEE R. RIDOLFI, : IN THE COURT OF COMMON PLEAS OF
PlaintiffBespondent :CUMBERLAND COUNTY, PENNSYLVANIA
V. : N0.2001-5610 CIVIL TERM
JAMES PATRICK RICHARDS, :CIVIL ACTION -LAW
Defendant/Petitioner
IN CUSTODY
ORDER OF COURT
AND NOW, this LQ"' day of /"'+/0 `/ , 2002, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Order of Court dated October 1, 2001 shall remain in full force
and effect except as modified as follows:
2. Paragraph 2 shall be replaced with the following: Father shall have
primary physical custody and Mother shall have partial physical custody of the Child
according to the following schedule.
3. Paragraph 6 is hereby deleted.
4. This Order of Court is entered pursuant to the 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,
Kevin
J.
cc/lhomas J. Williams, Esquire, Counsel for aF ther ) __ r
Tames K. Jones, Esquire, Counsel for Mother ~ R S
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RENEE R. RIDOLFI, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent :CUMBERLAND COUNTY, PENNSYLVANIA
V. :2001-5610 CIVIL TERM
JAMES PATRICI{ RICHARDS, :CIVIL ACTION -LAW
Defendant/Petitioner
IN CUSTODY
PRIOR JUDGE: I{evin A. Hess, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Michael James Ridolfi March 5, 2001 Father
2. A Conciliation Conference was held in this matter on May 21, 2002, with
the following individuals in attendance: The Father, James Patrick Richards, with his
counsel, Thomas J. Williams, Esquire and James K. Jones, Esquire for Mother who
appeared following the conference.
3. A prior Order of Court, dated October 1, 2001 was entered by the
Honorable Kevin A. Hess, which provided for shared legal custody, Mother to have
primary physical custody with Father having periods of partial physical custody on an
alternating weekend schedule, holidays and vacations.
4. The parties agreed to the entry of an Order in the form as attached.
Date cqu ine M. Verney, Esquire
Custody Conciliator