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HomeMy WebLinkAbout01-05664MELANIE T. WHITE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 01-5664 CIVIL ACTION LAW CHARLES V. WHITE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, October 04, 2001 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 Wednesday, October 31, 2001 at 8:30 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. 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. Verney, 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 I I [ R•?J IN /-I U i MELANIE T. WHITE, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CUSTODYVISITATION CHARLES V. WHITE, Defendant : NO. 01- S6v'1 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 on the day of 2001, at o'clock, _.m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: Custody Conciliator The Court of Common Pleas of 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 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, Pennsylvania 17013 (717) 249-3166 MELANIE T. WHITE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW CUSTODY/VISITATION CHARLES V. WHITE, Defendant : NO. 01- 3L6 `F CIVIL TERM COMPLAINT FOR CUSTODY 1. The Plaintiff is Melanie T. White, residing at 5 Midland Drive, Mt. Holly Springs, Pennsylvania 17065. 2. The Defendant is Charles V. White, residing at 515 Thronwood Lane, Carlisle, Pennsylvania 17013. 3. Plaintiff seeks custody of the following children: NAME RESIDENCE DOB Kelsey B. N. White 5 Midland Drive Mt Holly Springs, PA 17065 9/17/89 AGE 12 years Laurel B. L. White 5 Midland Drive Mt. Holly Springs, PA 17065 9/23/95 6 years 4. The children were not born out of wedlock. 5. The children are presently in the custody of Melanie T. White. 6. During his life, the child has resided with the following persons and at the following addresses: NAME Melanie and Charles White Melanie White Charles White ADDRESS DATES 801 North College Street Carlisle, PA 9/89 to 4/00 5 Midland Drive Mt Holly Springs, PA 4/00 to Present 515 Thomwood Lane Carlisle, PA 4/00 to Present 7. The mother of the child is Melanie T. White, currently residing at 5 Midland Drive, Mt. Holly Springs, Pennsylvania 17065. She is unmarried. I r VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of Pa. C.S. § 4904, relating to unsworn falsification to authorities. 4 DATE: qa D .? ?, . -Mel nie T. White v ? - a - -u d Q s fltt€ m?sMUS?f ee ?rnrvw,aiers swx->.Ufl1fS?SiB°iF58MM n?Y" ud :Y.ttr ,..? .e: v nn- IlRw +'*.W* .* ?? r . 'spa Rq damd?39r"a1i MELANIE T. WHITE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CHARLES V. WHITE, Defendant CIVIL ACTION - LAW CUSTODY/VISITATION NO. 01-5664 CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 2ND day of October, 2001, I Paul Bradford Orr, Esquire, attorney for Melanie White, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Custody Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested. The original return receipt card signed by the Defendant's mother on September 29, 2001 indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. LA Dated: qoq By: Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 (717) 258-8558 I.D. # 71786 ¦ Complete Items 12' and 3. Also complete item Restricted Delivery is desired. ¦ P' your name and address on the reverse that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: (harks V. ?xk 515 14fnkowd LU (aA} V, PA 11013 2. PS Form 3811, July 1999 label) A. Received by (Please Print Clearly) B. C. Si ure / Agent Adtlre D. Is delivery address different from item 1? ? yes If YES, enter delivery address below: ? No 3. Service Type N Certified Mail ? Express Mail ? Registered I( Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? yes Domestic Return Receipt EXHIBIT "A" 102595-99-M-1789 ji fr (_.J sc C_ C 0 i? VlNVA IJwNN3d IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY SANDERS, Plaintiff vs. ALISON SANDERS, Defendant * NO. 01-5654 * CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Christine J. Taylor, Esquire hereby certify that on October 5, 2001, served Defendant with a true and correct copy of Plaintiff's Complaint for Divorce in the above-referenced matter by sending same to Defendant by certified mail, restricted delivery to addressee only, return receipt requested and by regular first class mail, postage prepaid, addressed as follows, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. A copy of the return receipt signed by Defendant on October 5, 2001 is attached. Alison Sanders P.O. Box 1224 Mechanicsburg, PA 17055 WILEY, LENOX, COLGAN & MARZZACCO P.C. Date: !o d By: ine J. Taylor,i Supreme Court I.D. 0 1 South Bahimore Stre Dillsburg, PA 17019 (717) 432-9666 (Attorney for Plaintiff) 11111`Compfete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailp' or on the front if space permits. 1. Article Addressed to: R 1?s?n ???,d S? A. Received by (Please Print Clearly) B. Date of Delivery C. Sig atr1ure :SB(y X ?lJS9Y? SCLk ? Agent ? Atldre )e-C :different from item 17 Yes e very address below: ? No 5 251 FA Yc as4Nl'CS DU Y9 -fA- )70 SS ,w'uM i^W ? J'1 J 3. icefied ertlied Mail ? Express Mail 1? ? Registered ? Return Receipt for Merchandise ? Insured Mall ? C.O.D. 4. Restricted Delivery? (Extra Fee) AY 2. Articl PS Forl 595.00-M-0952 r' C _ ??c< 7 , n t? ...4... , ,.,. oxen APU`?nWEVaag^r?. ? ?l;?wkw, gsme??w.ma?+u,?y. NOV 15 2001 MELANIE T. WHITE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL DIVISION - LAW CHARLES V. WHITE, : NO. 2001-5664 CIVIL TERM Defendant IN CUSTODY ORDER OF COURT AND NOW, this ?70 day of WA. 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Melanie T. White, and the Father, Charles V. White, shall have shared legal custody of Kelsey B. N. White, born September 17, 1989, and Laurel B. L. White, born September 23, 1995. 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 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 custody of the children on alternating weekends as follows: The Father will pickup Kelsey and Laurel on Friday at 5:00 p.m. and will be dropped off Kelsey and Laurel at the Mother's residence at 6:00 p.m. on Tuesday. On the opposite weekend the Father will pickup Kelsey and Laurel at the Mother's residence on Sunday at 7:00 p.m. and the Mother will pickup the children at the Father's residence at 6:00 p.m. on Wednesday. 4. The holiday schedule can be modified upon mutual agreement. The holiday schedule shall supersede and take precedence over the regular custody schedule. The parties shall alternate having custody of the Children on holidays as follows: a. Christmas: Christmas holiday will be divided into Segment A that begins on the day school recesses for the Christmas holiday to Christmas Day at 2:00 p.m., and Segment B, which begins on Christmas Day at 2:00 p.m. and ends on December 27 at 8:00 p.m. The Mother shall have custody of the children during Segment B in even numbered years and Segment A in odd numbered years. The Father shall have custody of the children during Segment B in odd numbered years and Segment A in even numbered years. b. New Year's: New Year's holiday will be divided into Segment A which begins on New Year's Eve at 6:00 p.m. and ends on New Year's Day at 12:00 noon, and Segment B, which begins on New Year's Day at 12:00 noon and ends on January 2 at 7:30 p.m. The Mother shall have custody of the children during Segment A in even numbered years and Segment B in odd numbered years. The Father shall have custody of the children during Segment B in even numbered years and Segment A in odd numbered years. The year is determined on December 31. c. Alternating holidays: The parties shall alternate having custody on the following holidays: Memorial Day, July 41h, and Labor Day. d. Split holidays: The parties shall split the following holidays as follows: Thanksgiving and' Easter (9 a.m. to 2 p.m. or 2 p.m. to 8:30 p.m.) e. Mother's Day/Father's Day: The Mother shall have custody of the children every year for Mother's Day and the Father shall have custody of the children every year on Father's Day. f. Extensions: The Mother recognizes that the Father has out of state relatives and agrees to extend the holiday schedule upon mutual agreement. In the absence of mutual agreement, the terms of the holiday schedule shall control. 5. Each parry shall be entitled to have summer periods of extended custody with the children for four weeks each year with no more than fourteen (14) consecutive days unless extended by mutual agreement to the number of consecutive days. Each party shall provide the other with at least thirty days (30) advance notice of their intent to exercise such custody. Each party shall inform the other party of the destination and a phone number where the children can be reached if one is available. 6. Each party shall provide prompt notice to the other party of any emergencies that arise in connection with the children while they are in their custody. 7. For exchanges of custody, all adults shall conduct the exchange in a cooperative and civil manner with concern for the children's well being. 8. Both parties pledge to refrain from doing or saying 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. 9. Both parties will share all information regarding the children's school and social events. Any correspondence regarding these events will be shared by both parties, including, but riot limited to report cards, interim reports, notices of open houses and school events. 10. The Mother shall inform the Father of any medical conditions, recommended treatments, treatments and medical care of the children (including all doctor visits). 11. The Mother and Father agree to share the transportation of the children to each other's respective homes as agreed upon and needed. 12. In the event the Mother cannot provide care for the children for more than 24 hours, the Father will be given the right of first refusal with respect to caring for the children when the Mother is not available because of work or otherwise. 13. In the event the Mother or Father is unable to exercise a planned period of custody, the Mother or Father shall provide at least twenty-four (24) hours advance notice of the cancellation to the other parent whenever possible. The Mother and Father will mutually agree upon alternative visitation arrangements. 14. The parties may agree to additional visitation times and overnight stays by mutual agreement. 15. 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: Paul Bradford Off, Esquire, counsel for Mother 1? j o John W. Purcell, Esquire, counsel for Father e MELANIE T. WHITE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW CHARLES V. WHITE, Defendant PRIOR JUDGE: None NO. 2001-5664 CIVIL TERM : 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 subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kelsey B. N. White September 17, 1989 Mother Laurel B. L. White September 23, 1995 Mother 2. A Conciliation Conference was held on November 14, 2001 with the following individuals in attendance: The Mother, Melanie T. White, with her counsel, Paul Bradford Orr, Esquire, and the Father, Charles V. White, with his counsel, John W. Purcell, Jr., Esquire. 3. The parties agreed to entry of an Order in the form as attached. l(-rs-off ?. U Date acq line M. Verney, Esquire Custody Conciliator ,l! Nno Fit 25 _ _ vliP.?t+ ?+YM?('mFMxYte'pp _, diP O,EaYpY ri w_v€..e 4. ...ts4i'TC i ` 'Yf.???'R .x?(..i I?M'?fiA 5Y14?44TJ4G ALvjit Tooe A rt,.._.,C y=M9 ir_e: 1:,l plaintiff V. :IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 0 : CIVIL ACTION - LAW t?h[wr`?S V. (,jV.i eD dant IN DIVORCE PETITION TO MODIFY CUSTODY And now, on this 31 day of March 2008, the Plaintiff, Charles V. White wishes to make the court aware that the child whose custody is in question, Laurel B.L. White, has been involved in a shared custody agreement since 2001 (enclosed). No complaint has ever been filed against the Father or Mother in question to planned periods of custody, care, or overall well-being. Further, as the child is special needs, diagnosed with Retts Syndrome., the Father wishes to make the court aware that she receives medical assistance through Gateway Insurance; she has very little out-of-pocket expenses, [i.e. diapers, medicine, medical equipment, special needs equipment, transportation to and from school, therapy (currently through Stevens Center, which the Father initiated), and after school nursing assistance (currently through Links-2-Care Nursing Agency)] are all financed fully through her insurance. The Father wishes the court to know that he wishes for the best interests of his daughter, which he believes is retaining in the custody of the Mother, wherein her education, therapy, and medical needs are previously arranged. He wishes to be involved in his daughter's life and his proposed modification will prove to establish this. The Father and Mother have attempted to resolve these issues outside of court, but no reasonable agreement can be met. Therefore, the Father would like to place the decision in the hands of the court. Charles V. White, counsel for self Enclosures [24]: (4) covers, (4) Petition to Modify Custody Request, (4) Verification, (4) Order of the Court, (4) Original Custody Order of the Court, (4) Proposed Modifications erN- A%ite IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 4 f' SttU ( Me6rtie e CIVIL ACTION - LAW ??4z v, "A, Defendant IN DIVORCE PETITION TO MODIFY CUSTODY AND NOW, the Plaintiff, Charles V. White, avers the following. 1. The petition of Charles V. White, Plaintiff, respectfully represents that on November 20, 2001 an Order of Court was entered for shared custody (a true and correct copy of which is attached). 2. This Order should be modified because: a. The Plaintiff (father) is moving from the commonwealth on June 16, 2008. b. The Plaintiff (father) will be unable to follow the current order. c. The Plaintiff's (father) modification proposal is attached. WHEREFORE, the Petitioner requests that, in the best interest of the parties' minor child, this Honorable Court modify the existing Order of Court. Respectfully submitted, DATE 313110ql Charles V. White Pro Se . . . , VERIFICATION I, Charles V. White, verify that the statements made in this Petition to Modify Custody 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 3 1/0 e Charles V. White 1) Plaintiff is Charles V. White, residing at 515 Thornwood Lane, Carlisle, PA 17013 2) The Defendant is Melanie T. Jewell, residing at 110 Westgate Drive, Mt. Holly Springs, PA, 17065 3) The parties have two children: a) Kelsey Brie Noel White, born September 17, 1989 b) Laurel Brooke Lynne White, born September 23, 1995. 4) Kelsey White is of age 18 and is emancipated from the order. 5) Laurel White is a special needs child diagnosed with Retts Syndrome. 6) The mother shall have sole physical and legal custody of Laurel White. 7) The father shall be granted visitation as follows: a) 7-21 days during the month of July to be performed outside the commonwealth. b) 7-14 days during December/January to include the Christmas Holiday and in alternating years to include the New Year Holiday to be performed outside the commonwealth. i) The Christmas Holiday will be in even numbered years to begin December 2008. ii) The New Year Holiday will be in odd numbered years to begin December 2009. c) The mother will be given sixty (60) days advance notice of planned periods of visitation. d) The father will be granted right of first refusal if the mother is unable to care for the child for seven (7) or more consecutive days. e) The father will be granted other times of visitation in the commonwealth, not to exceed seven (7) consecutive days, providing the mother twenty (20) days advanced notice. 8) The parties agree to make arrangements for visitation and travel in the best interests of the child and within realistic guidelines. 9) The following persons are named, in addition to the father, to pickup/drop off child from/to the mother: a) Kelsey White, sister of the child. b) Heather White, stepmother of the child c) Other persons named by mutual consent. 10) The father will pay traveling expenses for planned periods of visitation, items 7a) & 7b). 11) The mother and father will share traveling expenses for item 7d) above. 12) The mother will provide all necessary items for the child during periods of visitation. (To include, but not limited to, clothing, diapers, medicines, wheel chair, insurance information etc...). 13) The father is granted right to fast refusal if the mother should decide to place the child in an institution. a) The father is granted rights in the decision making process. 14) The father is granted sole physical and legal custody of the child if the mother is deceased or physically/mentally unable to care for the child. a) The father agrees to grant visitation to the mother's family. 15) If the father is deceased or mentally/physically unable to carry out visitation, Kelsey White, sister of the child, and/or Heather White, stepmother of the child, are granted to follow the order. 16) The 14 and 15'` of every month at 10:00 p.m. Eastern Standard Time, a phone call will take place, with the father initiating, to discuss the child's health, education, therapeutic services, and general well-being. 17) The mother will provide the father with immediate telephone notification of medical emergencies. 18) The mother will provide the father with copies of IEP's, report cards, and evaluations by mail. 19) The father has permission to converse with the child's teachers and therapists by phone/mail/e-mail. a) The father has established relationships with these persons. 20) The terms of the agreement are to be revisited every three (3) years and amended if necessary in the best interests of the child. a) To begin March 2011, 2014, etc.... 21) The terms shall control, with the father receiving visitation and the mother retaining custody (unless the child has been permanently hospitalized or otherwise) until the child is deceased. a) In the event the child outlives the parents, guardianship shall be given to the sister, Kelsey White. 22) Support: a) The father agrees to pay the mother $130 per month excluding the months of July and December to commence July 1, 2008. b) The last payment will be October 1, 2016. c) The child reaches age 21 on September 23, 2016. d) The father agrees to pay the mother $130 for the month of July 2008 and waive visitation for that month/year. e) The father agrees to split costs of recommended medical treatments outside of insurance coverage. i) The child currently carries Gateway Medical Insurance. f) The father agrees to pay traveling expenses for planned periods of visitation items 7a) & 7b). g) The father agrees to share traveling expenses for item 7d). .. I MELANIE T. WHITE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL DIVISION - LAW CHARLES V. WHITE, : NO. 2001-5664 CIVIL TERM Defendant IN CUSTODY ORDER OF COURT NOV 15 20014 14'' AND NOW, this -2,, `v day of?'Lc? ? , 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Melanie T. White, and the Father, Charles V. White, shall have shared legal custody of Kelsey B. N. White, born September 17, 1989, and Laurel B. L. White, born September 23, 1995. 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 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 custody of the children on alternating weekends as follows: The Father will pickup Kelsey and Laurel on Friday at 5:00 p.m. and will be dropped off Kelsey and Laurel at the Mother's residence at 6:00 p.m. on Tuesday. On the opposite weekend the Father will pickup Kelsey and Laurel at the Mother's residence on Sunday at 7:00 p.m. and the Mother will pickup the children at the Father's residence at 6:00 p.m. on Wednesday. 4. The holiday schedule can be modified upon mutual agreement. The holiday schedule shall' supersede and take precedence over the regular custody schedule. The parties shall alternate having custody of the Children on holidays as follows: a. Christmas: Christmas holiday will be divided into Segment A that begins on the day school recesses for the Christmas holiday to Christmas Day at 2:00 p.m., and Segment B, which begins on Christmas Day at 2:00 p.m. and ends on December 27 at 8:00 p.m. The Mother shall have custody of the children during Segment B in even numbered years and Segment A in odd numbered years. The Father shall have custody of the children during Segment B in odd numbered years and Segment A in even numbered years. b. New Year's: New Year's holiday will be divided into Segment A which begins on New Year's Eve at 6:00 p.m. and ends on New Year's Day at 12:00 noon, and Segment B, which begins on New Year's Day at 12:00 noon and ends on January 2 at 7:30 p.m. The Mother shall have custody of the children during Segment A in even numbered years and Segment B in odd numbered years. The Father shall have custody of the children during Segment B in even numbered years and Segment A in odd numbered years. The year is determined on December 31. c. Alternating holidays: The parties shall alternate having custody on the following holidays: Memorial Day, July 4th, and Labor Day. d. Split holidays: The parties shall split the following holidays as follows: Thanksgiving and' Easter (9 a.m. to 2 p.m. or 2 p.m. to 8:30 p.m.) e. Mother's Day/Father's Day: The Mother shall have custody of the children every year for Mother's Day and the Father shall have custody of the children every year on Father's Day. f. Extensions: The Mother recognizes that the Father has out of state relatives and agrees to extend the holiday schedule upon mutual agreement. in the absence of mutual agreement, the terms of the holiday schedule shall control. 5. Each party shall be entitled to have summer periods of extended custody with the children for four weeks each year with no more than fourteen (14) consecutive days unless extended by mutual agreement to the number of consecutive days. Each party shall provide the other with at least thirty days (30) advance notice of their intent to exercise such custody. Each party shall inform the other party of the destination and a phone number where the children can be reached if one is available. 6. Each party shall provide prompt notice to the other party of any emergencies that arise in connection with the children while they are in their custody. 7. For exchanges of custody, all adults shall conduct the exchange in a cooperative and civil manner with concern for the children's well being. 8. Both parties pledge to refrain from doing or saying 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. 9. Both parties will share all information regarding the children's school and social events. Any correspondence regarding these events will be shared by both parties, including, but not limited to report cards, interim reports, notices of open houses and school events. 10. The Mother shall inform the Father of any medical conditions, recommended treatments, treatments and medical care of the children (including all doctor visits). 11. The Mother and Father agree to share the transportation of the children to each other's respective homes as agreed upon and needed. 12. In the event the Mother cannot provide care for the children for more than 24 hours, the Father will be given the right of first refusal with respect to caring for the children when the Mother is not available because of work or otherwise. 13. In the event the Mother or Father is unable to exercise a planned period of custody, the Mother or Father shall provide at least twenty-four (24) hours advance notice of the cancellation to the T ,• other parent whenever possible. The Mother and Father will mutually agree upon alternative visitation arrangements. 14. The parties may agree to additional visitation times and overnight stays by mutual agreement. 15. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. cc: Paul Bradford Orr, Esquire, counsel for Mother John W. Purcell, Esquire, counsel for Father a. +' A -MELANIE T. WHITE, Plaintiff V. CHARLES V. WHITE, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001-5664 CIVIL TERM : 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 subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kelsey B. N. White September 17, 1989 Mother Laurel B. L. White September 23, 1995 Mother 2. A Conciliation Conference was held on November 14, 2001 with the following individuals in attendance: The Mother, Melanie T. White, with her counsel, Paul Bradford Orr, Esquire, and the Father, Charles V. White, with his counsel, John W. Purcell, Jr., Esquire. 3. The parties agreed to entry of an Order in the form as attached. - /S-o C);R . U 1 Date cq line M. Verney, Esquire Custody Conciliator ,ft rte) , C° C"Y? MELANIE T. JEWELL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CHARLES V. WHITE DEFENDANT 2001-5664 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 04, 2008 , 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 Monday, May 05, 2008 _ at 10:30 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/ Jacqueline M. Verne Es _ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 pp '00,? MAY 0 7 2008 MELANIE T. JEWELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-5664 CIVIL ACTION - LAW CHARLES V. WHITE, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 7th day of May, 2008, being advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, acq eline M. Verney, Esquire, Cus y Conciliator MINA IASWUd OZ : I Ind 8- M Ieox AWI® . I -40 301140 MELANIE THEA JEWELL, Plaintiff V. CHARLES VINCENT WHITE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 2001 - 5664 CIVIL TERM ACTION IN CUSTODY AGREEMENT OF THE PARTIES FOR MODIFICATION OF A PATIAL CUSTODY AND NOW, this-7 dav of , 2008, the parties hereto agree as follows: 1. Plaintiff is Melanie T. Jewell, residing at 110 Westgate Drive, Mt. Holly Springs, Pennsylvania, 17065 2. The Defendant is Charles V. White, residing at 515 Thornwood Lane, Carlisle, Pennsylvania, 17013 3. The parties have two children, a. Kelsey Brie Noel White, age 18, born September 17, 1989. b. Laurel Brooke Lynne White, age 12, born September 23, 1995. 4. The parties have agreed to shared physical custody of the children to Defendant and visitation by Defendant in accordance with an order issued by the Court of Common Pleas. 5. Kelsey White is emancipated from the current order. 6. Laurel White is a special needs child that is diagnosed with Rett Syndrome. 7. The Defendant will be moving out of the Commonwealth on June 16, 2008. 8. The Defendant will be unable to follow the current order. 9. The parties wish to resolve this outstanding issue as follows: a. The Defendant relinquishes his right to shared physical custody and agrees that sole physical and legal custody be awarded to the Plaintiff. b. The Defendant will be granted visitation as follows: i. The Defendant will be granted twenty eight (28) days of visitation during each calendar year beginning in 2009. Visitation may not run more than seven (7) days in concession during the school year and fourteen (14) days in concession during the summer months. ii. The Defendant will contact the Plaintiff ninety (90) days in advance to request visitation. iii. The Plaintiff consents that visitation will be permitted outside of Plaintiff's custodial care. iv. The Defendant is permitted to perform his periods of visitation outside the Commonwealth of Pennsylvania. V. The Christmas and New Years holiday schedule will run from the first day of winter vacation until the last day of winter vacation as determined by the child's educational schedule. The Defendant will be granted visitation on odd numbered years and Plaintiff will retain custody on even numbered years. Time used during the holiday schedule will count toward the Defendants permitted twenty eight (28) days. vi. The Defendant will be notified sixty (60) days in advance and will be given right of first refusal to additional visitation when the Plaintiff is on vacation or not able to care for the child for more than seven (7) consecutive calendar days. Time used will not count against the Defendants permitted twenty eight (28) days. vii. The Plaintiff and Defendant must mutually agree upon additional visitation times above and beyond the allotted twenty eight (28) days. The Defendant must notify the Plaintiff in writing or by phone thirty (30) days in advance for any additional visitation requests. Time used will not count against the Defendants permitted twenty eight (28) days. d. In the event the Defendant is not able to pickup or drop off the child during his periods of visitation, Kelsey White, Sister, and Heather White, Stepmother, may act as the Defendants proxy. All other adults not named must be agreed to by mutual consent. e. The Plaintiff will provide to the Defendant all necessary items required for the child's well-being during his periods of visitation. Necessary items are clothing, diapers, prescription medicines, insurance information and any medical apparatus. f. Upon initiation of the Defendant, the Plaintiff agrees to communicate with the Defendant twice per month concerning the child's general well-being. g. The Defendant is permitted to correspond with the child's teachers and medical care providers to obtain status reports on the child's progress and general well-being; this includes making arrangements to receive copies of all educational and medical related correspondence. h. Each party shall provide prompt notice to the other parry of any emergencies that arise in connection with the child while they are in their respective care. i. The Defendant will be given right of first refusal to permanently care for the child in the event the Plaintiff determines it is in the child's best interest to be placed in a permanent care facility or home other than the Plaintiffs. j. The Defendant will pay to the Plaintiff $100.00 per month commencing July 1, 2008, until the child reaches the age of twenty one (21) years with the final payment to be made on October 1, 2016. Said payment is made directly to Plaintiff pursuant to a Consent Support Order filed with the Domestic Relations office. k. The Defendant will sign IRS Form 8332, Release of Claim to Exemption, turning over all current and future tax rights of the child to the Plaintiff. The parties agree to make travel arrangements that are in the best interest of the child. During any periods of visitation the child may not travel alone and must be accompanied by the Defendant or the parties agreed to proxy. The Defendant shall inform the Plaintiff of all destinations and a phone number where the child can be reached. M. The Defendant will pay all travel expenses incurred during his periods of visitation. n. The Defendant will pay fifty (50) percent of all medical expenses that may be incurred outside of the standard insurance coverage. o. The parties may modify the provisions of this agreement by mutual consent. In the absence of mutual consent, the terms of this agreement shall control. Sworn and affirmed to and acknowledged before me this -7 ay of May, 2008. L W9 'It AW 83MIdX3 NOIS8IWWOO AW Al ooaNV1d38Wn0'HOnovoealsnwo ?16ftd AHVLON W3a T M01UNd N RY PUBLIC IMIVIWM.LON VINVAMONN3d d0 HITISMNOWWOO Charles Vincent White ...j `3 } ' n ? ' , J r7 --, ,. Q ' ? ? l . ?i j ?` ' ?v R :> -.-? ? i ?'.dw ?Y'??rr?i uw . a? t Melanie T. Jewell, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 2001-5664 CIVIL TERM Charles V. White, CIVIL ACTION - LAW Defendant IN DIVORCE ORDER OF COURT to AND NOW, this -?7 day of may- , 2008, upon consideration of the attached agreement of the parties for modification of a partial custody is hereby granted. (4 5 ta'V ?ll r V? ? V w ? i 4