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Home My WebLink About01-07092 jt"':,-"~"'fi "~'~ r- " ANDREW E, SLIKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW TAMERAJ. SLIKE, Defendant NO. 01-7092 CIVIL TERM ORDER OF COURT AND NOW, this 21st day of December, 2001, upon consideration of Plaintiffs Petition for Special Relief, filed December 18, 2001, and the court being unable to hold a hearing to receive the position of Defendant prior to Christmas, the request for ex parte relief regarding custody on Christmas day is denied. A HEARING is scheduled for Friday, January 11, 2002, at 1:30 p,m., in Courtroom No. I, Cumberland County Courthouse, Carlisle, Pennsylvania, on the balance of the petition for special relief. BY THE COURT, ,jWesley 0 V ., Debra Denison Cantor, Esq. 2331 Market Street Camp Hill, PA 17011 Attorney for Plaintiff James M. Bach, Esq. 352 S. Sporting Hill Road Mechanicsburg, PA 17055 Attorney for Defendant ,~ Jf~~ks 0 0 C~ c: <'"' -n vr'''--''; 0 :71 [l1['{-1 p'} Z'X' C') (,:_; ;J;! ~3~ N -:-;1"-" i,,~~i ~~S :<c, v ~o ::;;: ~:?f~ 4.,~ 5>>:- s> ~ 0'T1 0 'b! .-J :n -< :rc )':'~?r::'F'_",_" -, ,.., ',,"","---'- "~"'--'''''' ~_I!f""?' , ~,,' .." . ""'" ' Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. Ol~ 109'JCIVIL TERM ANDREW E. SLIKE, TAMERA J. SLIKE, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT day of , 2001, it is hereby AND NOW this ORDERED that Plaintiff shall have partial custody from December 22, 2001 at 12:00 PM to December 25,2001 at 12:00 PM and December 28, 2001 at 12:00 PM to January 1,2001 at 12:00 PM and partial custody every other weekend, Friday evening to Sunday evening, pending a custody conference. BY THE COURT: 1. "~!"1'\'f;'."W ,_, _" r~~,"_ C"", ~,~_ , ' .. .. ~"~ ,~~ . r 1 W1:-L'<" "',"'~i'!r.~ ~~~-,. r - -~ -. . ~ Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA ANDREW E. SLIKE, NO. CIVIL TERM TAMERA J. SLIKE, Defendant CIVIL ACTION - LAW IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW comes Plaintiff, by and through his counsel, Reager & Adler, P.c., and requests this Court to enter a Petition for Special Relief as follows: 1, Plaintiff is an adult individual residing at 110 Wildflower Drive, Carlisle, Pennsylvania 17013. 2. Defendant is an adult individual residing at 6171 Haymarket Way, Mechanicsburg, Pennsylvania 17050. 3, The parties are the parents ofthree minor children, namely Shanna E. Slike date of birth 7/14/83, Brandon E. Slike date of birth 9/l4/95 and Nicholas R. Slike, date of birth 2/6/90. 4, On or about November 26,2001, Defendant separated from Plaintiff and removed the children from the home, 5, Since that date, Plaintiff has been unable to see his children. 6. Plaintiff desires this Court to enter an Order granting him custodial time during the Christmas holidays as follows: (a) December 22,2001 at 12:00 PM until December 25,2001 at 12:00 PM. (b) December 28, 2001 at 12:00 PM until Tuesday, January I, 2002 at 12:00 PM. ,j~!l;~ --~,' . ~ .,' I . T' " ' " -","~!I!\!I jii'" "~~ ,:,'~j- 7. Plaintiff has not seen his children for a period of one month and to provide this custodial time will permit him the time necessary to reestablish his relationships. 8. Concurrently with the filing of this Petition for Special Relief, Plaintiff has filed a Custody Complaint. 9. Petitioner requests this Honorable Court to enter an Order granting him custody of the minor children every other weekend until such time as a custody conference held to ensure that he has regular contact with the children. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order awarding him partial custody from December 22,2001 at 12:00 PM to December 25, 2001 at 12:00 PM and December 28, 2001 at 12:00 PM to January 1,2001 at 12:00 PM and to enter an interim order granting him partial custody every other weekend pending a custody conference.. Respectfully Submitted, REAGER & ADLER, PC Dated: / ';)-11251 0 I By: Debrc nis C tor, Esquire PAID. #66378 2331 Market Street Camp Hill, PA l70ll (717)763-1383 2 .' ~,,~ , , ""I . ~ 'T " ,,""""' 12-18-01 11:51 t .\,~ ! ?,~_.",:,~~I~ ,I 1"'1,' ..,' I ,,,.i ;~~. 'I' ~ 7175823364 , .'~ ~".' .." '. SHER_DALE_BEER & BEV CiI 001 V l'mI"JC,i\l:JD.t'J " \!',I!r..'.', ~. ~;,!ii",,'. L'.::t'i,t! , 'J"',-, "'1' .",.(... ,II \i Ihl- -(!:ll-"~ 'd'l l~"'rt\'~\l_\ 1\',.\: tl\rc.~rlt\.1'1~, ';;:', ~..." ,',. _. ". ,V... , " , \ y,,,.,~;:I;,', ,11",.' 1.1'1:'.' '~' .' 1.. l' -I I n ':'>1 "i l'''lh.1 ,I "~,, ''''I'' ,:.,1"''''1 ",I '~"'. 111lnrp~.;'I":'.!I, -!>'.ll',l'\;'. \"',,' ",: .""I,~. /., .._. . It ,l" 1'-', I.. . ',_ I, . ~., ., '" , "",.'" .. r und!.!.' I..U"j(j '!:':,i'T',ll,,!, i.J I . ~ \ \~: 'j '\' I; : ~ 1 .- lit, 1 t~ i. ,1 <\: e ! .l.I'. \" , ~ \ ~: I ~.- i: ': , , 1 " I' (' ~" '\ f.'. (ql t I 'j..l.::.til) I 1'1 i !II lht" pGL\~~ltn"'; "~I h'.'"1 "..,),h.. ';:.~? '. r.h~,.,. ~". , tifl:,.\\'..:t 11 "VI tL:.:: ~~~!I'ld 1':"1 !.1IJHll.'rh h,,~ 1"\/,11:" , i'"_~ ~...",..,., """'.,..- /\ ndn~~...\. [::. S [ikl.;' ~'- ,,-~ ,,' ~~, .-, ~~ "' CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served on the following individuals via United States First Class Mail, postage prepaid as follows: J ames Bach, Esquire 352 S, Sporting Hill Road Mechanicsburg, PA 17055 Dated:):2-) /g/O I Cantor, Esquire '-'~'i'>\R'!q,j1\l", _v '~-r"P~'. ::" ",,", "I 00",,",", ~~~ (~~ " ~~ ~- -=~~.,-,^ ~ ~ ~ 8 -o~ ~ Q " ~' J "-.~-~,. ,-~" ^,"""-"->'<';'~'=""'t""""TFi;tr~Y"limf-""l~ C) " , " , .:..: V C': .. rn ,'"1 -:;,':- " cc! D-' !-..- " .- )" " r " . '''.) '" -, , -, \? V' -:r- .~!.~,~~~::;;i~'J!lrr:~~,", ,~., _",~~~!l-'i"-(AlM..;r!':i,,"':<'7"r"i"".",F~'?iY'r7!>\;hf"'-~i,;{";l!'~I'a;m(!Wi"'i%_"f-,'tmL~\f-~J};!'lW'~i3i.;;,{'~:;';-;;;~Fi'!~~-f?"~:~,~_\ ~~_~. " 'BH~J_]lm~I~~]i?,m.~,f/lf1'r ~'P~ , JAN 0 9 200? ~l--- Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA ANDREW E, SLIKE, NO. 01.7092 CIVIL TERM T AMERA J. SLIKE, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW this day of , 2002, it is hereby ORDERED that Petitioner shall have custody of the minor children on an alternating weekly basis pending the custody conciliation of final order of court. BY THE COURT: ], "'im--"':"-~n ,_ "I ',,- (" ~ '-. , - t '- """w'~'l1I t Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA ANDREW E. SLIKE, NO. 01.7092 CIVIL TERM T AMERA J. SLIKE, Defendant CIVIL ACTION - LAW IN CUSTODY AMENDMENT TO PETITION FOR SPECIAL RELIEF AND NOW comes Petitioner Andy Slike, by and through his counsel, Reager & Adler, P.C., and amends the Petition for Special Relief filed on December 18, 2001, as follows: I, Paragraphs 1 through 9 of the Petition for Special Relief are incorporated herein by reference, 2, Since the filing of this Petition, Petitioner has requested through Respondent's family members, custodial time with his children. Said requests have all been ignored. 3. Respondent continues to act contrary to the best interest ofthe children, WHEREFORE, Petitioner requests this Honorable Court to enter an interim order granting Petitioner shared physical custody of the minor children on an alternating weekly basis pending the custody conciliation and final order of court. Respectfully Submitted, REAGER & ADLER, PC De a ison PA!D. #6 2331 Market Street Camp Hill, P A 170 II (717) 763-1383 Dated: 110..;.. By: ^<f~~i'f,..LJ:"" '."" ^,~__. .,-v'.t"^-, ,~_., _ ._-:~"' ,"I'-~ , , '<n'~ ,'" . CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served on the following individual via United States First Class Mail, postage prepaid, as follows: James Bach, Esquire 352 South Sporting Hill Road Mechanicsburg, PA 17055 Dated: /7 II,}. ''''''''ljiI",%',,' ^",--<, """" or"~, 'f': 1-'" c ,or ,^ ,. ~_~,~_ t u ~- .'''..J .r-".,o,'<"-"','"Wo~;'",,-M'." --^.~ - ."~; .-. -," .-lrr~ ','-'F'""r,~?~ .! ~~~~@...~~g~~__n'~+_1~1~;i""",*",'''-';j''i!''FJ1''!'''''W"';;;_~'-~'-T"'--~!.'>)lr+," 0 ~, 9. ~"' C f'-..~' ~ t_ -occ ~,:I;' mlTl ;-~::rt zS; , ~:~-' OJ r~'---- <,,'--- :P'~ ~n :]1' ;-: ,. 5") c z: ~) -, -< (...) i' [i IiIlIIr~'I.efi:c~"~, . 8> '~ C) 1'...1 ;:u ,1:> 0) I"n s: C.0 ::c~ -0 ~ (i) :r: S::!I' j':;: :t> A} , ;01<'0 " /C)> 'lJmc ::1> '~'l r,2 __I.. (j) rn ......1 j"j ?J S 1!1 ,., "-~ ~~ (~ S::W'- rnCJ1:I> ON$: I((;m :po(l) ~~ C.: ~ o ~ . 'n :C ()J <Jl (f) "" C '1) (; :;0 0 T G) )J . 'lJ :::.1 u: :r>ijjo .._'t. C -.j;;J; ;0 a,m (JI r'" 0'1 ;0 () ;p- O J;;. JAN I) II 2a02' jJ- Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYL V AN1A ANDREW E. SLIKE, NO. 01-7092 CNIL TERM TAMERAJ. SLIKE, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW this day of , 2002, it is hereby ORDERED that Petitioner shall have custody of the minor children on an alternating weekly basis pending the custody conciliation of fmal order of court. BY THE COURT: 1. .~~~ - - ~ . -,--, --".. ,. .- 'Q'.";:::rf;':';'C::'~':'''' -C";J''f."",'f- ;~' .y_;,. Co;" ~, ,::,,"~,,~:"\,c ""~.-:<' ,.':' c,_ _,t_ . '__''''"'~'''.'" ,""'._ .'C ' [~ CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served on the following individual via United States First Class Mail, postage prepaid, as follows: James Bach, Esquire 352 South Sporting Hill Road Mechanicsburg, PA 17055 Dated: ;j '7/,1,;;1. " ll,~;,~!,'!I0, 'r,_-""^_ "-~-',""'7 -~--', <. ~- -_-_-" ,h- , -~ "'""! 0'" ;U )>wm ;;:~)> -U;;:G> I)>m ,;U;U .!;>;9" -urn)> )> -; 0 (fl' ,J,- -i m Cj;U;U ~m. ~m-U ...,0 nl"~H ::.;; (,,;.) "-'" ~ (.).) I.! (],) ~.....>-sr >T<:S::C1'" ~e;~d ,;-' * r"'!] ""d ~, ~ S;' ~ en;p. 6 ;:;- CI ::1 (3~r"Q I-' ..... tT', ~ {No "" ."' nm , :co H c; ::;' " "I"\' n ""f"'" 'L .,.I.M!'I e, ", ( lull' Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA ANDREW E. SLIKE, NO. 01-7092 CIVIL TERM TAMERA J. SLIlill, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW this day of , 2002, it is hereby ORDERED that Petitioner shall have custody of the minor children on an alternating weekly basis pending the custody conciliation of fmal order of court. BY THE COURT: 1. '~'9",,~_r.____o ~~)"_""~,____",,' I"",' ,~, ,~_",~ ~__I_ Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO" PENNSYLVANIA ANDREW E. SLIlill, NO. 01-7092 CIVIL TERM TAMERA], SLIKE, Defendant CIVIL ACTION - LAW IN CUSTgDYR; 0 s: f_ -0 0:-' :~'1m mrr' -...~ Z 'T ~'- r-- wS~_:, I ,-,,'n AMENDMENT TO PETITION FOR SPECIAL RELIEF ~ E., co ,~i 2; d;: c' :Po {)~ :::.;j ..,;,.. - 0C) j;Q t.., IT' C,~ .. -"_~ AND NOW comes Petitioner Andy Slike, by and through his counsel, Reager & ~ner~.C.,~ and amends the Petition for Special Relief filed on December 18, 2001, as follows: I, Paragraphs 1 through 9 of the Petition for Special Relief are incorporated herein by reference, 2. Since the filing of this Petition, Petitioner has requested through Respondent's family members, custodial time with his children. Said requests have all been ignored, 3. Respondent continues to act contrary to the best interest of the children, WHEREFORE, Petitioner requests this Honorable Court to enter an interim order granting Petitioner shared physical custody of the minor children on an alternating weekly basis pending the custody conciliation and [mal order of court, Respectfully Submitted, REAGER & ADLER, PC Dated: );10;;' By: I De ison ntor, Esquire PAID. #6 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 '";1'_H3,,~,_i1i n ~__. '~t. ;" /'-'7-7' "~""?r:"'_~'~ "~Of ~ CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served on the following individual via United States First Class Mail, postage prepaid, as follows: James Bach, Esquire 352 South Sporting Hill Road Mechanicsburg, PA 17055 Dated: 17/1,}.. -''',~~~~;< ,-.r,;-, ',- ~--- -,"/, -^'_"'J-L'--"!'_'_.~<I"_O "'-" ~--,,- ANDREW E. SLIJill PLAINTIFF IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 01-7092 CIVIL ACTION LAW TAMARAJ. SLIKE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, December 20, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. at 214 Senate Avenue, Suite 105, Camp HiU, PA 17011 on Monday, January 28, 2002 , the conciliator, at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to tbe conciliator 48 bours prior to scbeduled bearing. FOR TIIE COURT, By: Isl Melissa P. Greevy. Esq. ~ 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 '-''';--''''*''~JI,~. ~~_ '. , q r._ ,,'I' ,. ~. ~ .",_~.-c ~ ~._=~ -~"'~-"1 ~~ - -.l="~ . ,~<.~ A\)~ httfj c::>}. )41~UJ ~clO() rti5(l ~ttI or )~l')~ --;3-),I-j-O<Y ---vorv frttf ~ yr311f'W /,dOU '~O --, Qf 1r:/~1 ~~d ~~K),{:r{\'d3~\J'\I'\':) ~\\\..J~' u., , ~ \ ~ 'J3C1 \ {} "t\~ \\0 .' \ ,,,. II ,l_ '" \, .'\'....... N'lV' OI\O\~\\k:f)3~\:\ "o\j:~ -;f...,~L....: ....' :3,,)0- LI r,)"t",', 1,'.,"" ;_.-: .) "ti,th 1,,', "~j''-----' J'~ ...I . .....]b'j:~l}-'U~n~~. ., _"~,,~~Im,,,~, ~, _ ,0" . I,~t" 1V$!jlThjli'!~~'*Fl!W~~,_ ~, lIfll~~i\i;-"-:'''''''''''''';.'r:,:;'r,'r)c J-l-,":,"'j',~~,';"__,'!k:"q",'i':;'8!i1X-~i~~~5."r4,\',~lti8""'f!jr'r.!:":tti1'"'!tr5f:Wl"~f,~l~!JY;~,-~ v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 01- 7oq~ ANDREWE. SLIKE, Plaintiff TAMARAJ. SLlKE, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Conciliator, at the , Pennsylvania, on the , Esquire, day of ,2001, at .m, for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or, if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary Order. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory, Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT DATED: BY: Custody Conciliator 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 '-,n~",1j._,,," ~~_. . - 1~ " I ANDREW E. SLlKE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. Olvl0gd- TAMARA 1. SLIKE, Defendant : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY I. Plaintiff is Andrew E. Slike, an adult individual residing at 110 Wildflower Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Tamara J. Slike, an adult individual residing at 6171 Haymarket Way, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff seeks shared physical and shared legal custody of the following children: Name Address Age Brandon E. Slike 6171 Haymarket Way Mechanicsburg, P A 17050 16 Nicholas R. Slike 6171 Haymarket Way Mechanicsburg, P A 17050 11 Sharma E. Slike 6171 Haymarket Way Mechanicsburg, P A 17050 18 4, The children were not born out of wedlock. The children are presently in the custody of Defendant who resides at 6171 Haymarket Way, Mechanicsburg, Pennsylvania, '16-e'...1;, """c'''" ~ - ~ ' 5. During the past five (5) years, the children have resided with the following persons at the following addresses: Name Address Dates Tamara J. Slike 6171 Haymarket Way 11/26/01 to present Mechanicsburg, P A 17050 Andrew E. Slike Tamara J. Slike 110 Wildflower Drive 11/25/96 - 11/25/01 Carlisle, P A 17050 6. The mother ofthe children is currently residing at 6171 Haymarket Way, Mechanicsburg, Pennsylvania, 7. The father of the children is currently residing at 110 Wildflower Carlisle, Pennsylvania 17013. 8. The relationship of Plaintiff to the children is that of father. Plaintiff currently resides with the following persons: Name RelationshiD None 9, The relationship of Defendant to the children is that ofrnother. Defendant currently resides with the following persons: Name Relationship Brandon E. Slike Nicholas R. Slike Sharma E. Slike Mother Mother Mother "'r~<:A--~,~",,~< '!'''' I 10. Plu,intitT hu,s not participated as a party or a witness, or ill any other capacity in other litigaticlll cO!Jcerning the custody of the children in this or any other Court. 11. Plaintiff has 110 infol1l1atiotl of a custody proceeding coneeming the children peuJing i.ll a C(Jurt ()f this (),JIllIllOIJ\vealth, 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custl)dy or visitatiol1 rights with respect to the childn:!J, 13, The hest interest and pel1l1auent welfure ofth" children will be served by grunting the re Lief requested. 14. Eaeh parent whose parental rights to the children have not been terminated and the person who has physical custody of th" cllltdrtm have been narned as parties to this action. \VHEREFORE, Plaintitl'requests the Court to grant him shared legal and shared physical custody of the children. DATED; jj -'j P'OI By; Respeettl111y submitted, REAGER & ADLER, PC "-- (, (I t ~"T"'''''-," _:./' ,/' ,_. ..,-0"-' D~td nl~l!;'E;~t:;:: ~;;:~-'-'-- LD. No. 66378-, 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 Attorney for Plaintiff 12-18-01 1.1: 37 n 7175823364' SHER_DALE_BEE~ & BEV CiI 086 ....EIH;t](','.TlQN. . .. I . ',' ",' ....~(<', t1~:u: rll':' '.!I.:'ll~ ',t.' ~l,nb llJ t.h~ fr:.I!e.g('lju~..! J..\.:U.;:r:,;".'..;:':.SIU(f;'.l:,{-nT:I'f"d.(.I)~"':"'~_('J.~. ..,...,._".... . 1'-;:...:111:-' , ,',', ,-,','.,...."..1..,'. :".',", 1,'.',... ~l'.' ',I:': il'~I(\,.ti~al.~o.\J., k:Lr.:':I,:;.':..:~?e ::l.nd hdi:::.f l1.HLl,l::rsl,ltd(l 'rL~' 1.:n,lr' .I.. \.. .. ...1" r , ," ~ ... "I.!: . .~L:,.' ""'~'I;..~ l :',11'" I ;1,:,> b~r'," :}'". ~u';': .1"I.k ;;./'I~~':(::~ :'~I \.hl;; ptf''il:\b~' ~:. ,I~ l g Pi'l. (',S ....~. ~4904 re}al\l.\~ td iJI.L~"I/:"Ir:1 Vl,':;l'll,',lllull 1\', .:.itltlil)titi;;::s D,\n~ ~ --. ... ---.... .-.-,. ~~ "\l1dn;<.\ E, Slik." '<>~_VJK, CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served on the following individuals via United States First Class Mail, postage prepaid as follows: J ames Bach, Esquire 352 S. Sporting Hill Road Mechanicsburg, P A 17055 D,,," J)- J/ t /0 I " " "'__:-.1""''''' I ~~-~, . ... '"""- " ~ (J 8 P":,H ~ d -, , (r'; _ ()) ,,--,'- ...... -Q c': i_ ....... ....., - - ~ ~ -0 ?J~~ , -- 0l 'JJ \tJ ~ \; ~ .r:. vJ oOQ :J -".1 ;:';' 0 ) ::~L c"-' ~,DJ,__,,,, _ ~~m~p~'"0",.-,<:,I~~"~--_i'_- , ,'}', . ,. ,!L~ _~-'~<<" ~~_~i~"~I!!liI..p"""".~~.~,~:,>W~;'ij~,,*'f:Nfiff'~~'-',"-.i'--,,,-~'~';"'~~;N-';!A",\\';i'1f~",%JM'j1lW~~~~lrp#,:/,j!~i~~~~'~.~~~0 V'",--' ~-__, ~ ._~w..".~~. ANDREW E. SLIKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW TAMERA J. SLIKE, Defendant NO. 01-7092 CIVIL TERM ORDER OF COURT AND NOW, this 11th day of January, 2002, upon consideration of Plaintiffs Petition for Special Relief and Plaintiffs Amendment to Petition for Special Relief, and following a hearing held on January II, 2002, it is ordered and directed as follows, pending the custody conciliation conference and further order of court: 1. Legal custody of the parties' child, Nicholas Robert Slike, shall be shared by the parties. 2, Primary physical custody of the child shall be in Defendant, the mother. 3. Temporary or partial physical custody of the child shall be in Plaintiff, the father, on alternating weekends from Friday at 7:00 p.m. until Sunday at 7 :00 p.m. The fIrst period of such temporary or partial custody shall commence on Friday, January 18,2002. BY THE COURT, ~ es ey Ole ~bra Denison Cantor, Esq. 2331 Market Street ~ ~ Camp Hill, PA 17011 fI-,- .fIJ ~)C1. Attorney for Plaintiff ~ -/.5-0 d L 'R'l V'James M. Bach, Esq. 352 S. Sporting Hill Road Mechanicsburg, PA 17055 Attorney for Defendant ';.;.>Af ~. '_'" '.~ . ",_" 1--. '1- -'-'", '""',' ----,- ~ -- ,,""'. ",'C'.' .,'.,'<"." . iU,.,,', "r. """,,,," <,'-',',^ ""''''''''~''''''< '''''' """1Ii~""'1~UnWTTnl"'< \iiNVAl\SNN3d ,\I i\!r:,u.....t1 (1r\!\.t1!.~:jC:~AsrYI ...., \ , ~) ".,. - "__~t.,, 'I .V .? '7 'I' Lv:(, }',l1 17 r l\jVr ;~O Atfv10!'-,!8:'"; ;{)H~O"-cI,:','i'~:::1 FEe- 64 __~'$<7'f.!;1li,_ ',;?:'_~'f,/?:~i011~(~!l'!tWrn-ijili-'!,'WYii.("'\,:F'~';':SW;',"'iW7"'ij~),i!l;J;~~'~'O:;Hm~"i~~i""'.-:i-'~~rW'.;ffli!,~~r.~~- ~ ' F~9 1 9 2002 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 01-7092 ANDREW E. SLIKE, vs. Defendant CIVIL ACTION - LAW CUSTODY TAMARA J. SLlKE, Oler, J. -- I',i 'i 1 I :i ::j :-! TEMPORAR ORDER. OF COUR AND NOW, this "2-2.-....,d day f February, 2002, upon consideration of the attached Custody Conciliation Summary R port, it is hereby ordered and directed as follows: (1 !i " ;:'1 (.!i !{ ',\' I"! :i; 1. Legal Custody. The parties, And ew E. Slike and Tamara J, Slike, shall have shared legal custody of the minor Children, Brandon E, Slike, born September 4, 1985; Shanna E. Slike, born July 14, 1983; and N cholas R. Slike, born February 6, 1990. Each parent shall have an equal right, to be exer ised jointly with the other parent, to make all major non-emergency decisions affecting the Chil ren's general well-being including, but not limited to, all decisions regarding their health, edu ation and religion, Pursuant to the terms of Pa, C. S, S 5309, each parent shall be entitled to II records and information pertaining to the Children including, but not limited to, medi ai, dental, religious or school records, the residence address of the Children and of t e other parent. To the extent one parent has possession of any such records or informa ion, that parent shall be required to share the same, or copies thereof, with the other par nt within such reasonable time as to make the records and information of reasonable use to the other parent. if :1 2. Physical Custody. Effective Ma ch 1, 2002, Father shall have physical custody of Nicholas on alternate weekends from Frid y after school until he is returned to school on Monday mornings. 3. Holidays, Father shall have cusl ody for the Easter school break from Saturday at 7:00 p.m, until Monday at Noon, and on J Iy 4, 2002, from 9:00 a.m. until July 5, 2002, at 9:00 a.m. Mother shall have holiday custody fo Memorial Day and Labor Day. 4. The parties shall submit thems Ives and their minor Children to an independent custody evaluation to be performed by Dr. Stanley Schneider. The parties shall sign all necessary releases and authorizations for the evaluator to obtain medical and psychological information pertaining to the parties. Addi ionally, the parties shall extend their full cooperation in completing this evaluation in a timely fa hion and in the scheduling of appointments, Father shall bear the full expense of the evaluati n. Therefore, Dr. Schneider will serve as Father's witness, ! I i ";lJ""'~~",," _ ,",,- ,....,. ,--"'~' I ,', '-.'. -'--':"1 ,,'T -."" ",..'"',,, ~ , - ~_.. - " '"~, ',~' .. ~ -, - ,-". ..." or """"""" "-,,, ."" .... ,",'~"_.,"- '," i Imll"'.'~}I'r!il'~ r..r , )- Lt:- '--om C' C -.'-, <"-I. ::;:::-- " :?j .. , C '" -;-,- >- :-'-,] -'--;-:::' C_f} c< '-1 ;2: ~z \1 LU CL L'-, ..' C'"j ::::> c::' (.) ',;,-- ',~" ':"_,, ,",,_'" ,","" ,'" ',_,' _~p,R[~_"",.,'O__ ~.~" _~.'1", ,,-".J~~JIIm_,,:,:<,,o~~,, -~--." ~>_""'" _ ' ~~,,_, _f" ",_,.J1,~~~~tof('n",i"~F'e';i'"~~f';:.,,',"mfi~''-@~~~.~@~r_""m 1~:Ii~~",lJ!l,~[!!l~~~~JIIIJi,<'~:' :y;,~';' ;";:~'/'-IY.f~ff~ --",,,-,,,,~,~~ .. ,,-,.. No. 01-7092 -- Civil Term 5. A hearing is scheduled in Courtroom Number 1 of the Cumberland County Courthouse, on the ,;II) ~ day of May, 2002, at '1 ;.JtJl o'clock, .t1:::.M, at which time testimony will be taken. For the purposes of the hearing the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least ten days prior to the hearing date. BY THE COURT, Dist: Debra Denison Cantor. Esquire, 2331 Market Street. Camp Hill. PA 17011-4642 James M, Bach. Esquire. 352 S, Sporting Hill Road. Mechanicsburg. PA 17050 ~ ~ ;2.-;;,,,. 0 ~ Ch- ~71~ d/~i}lo?~ '-,1"1<'0, ,"" " ,,_,_"~ __ "'co',' ~- '_':'~--'O'"C ' ,__",,__q ,"'_'1--'- ",' b_T"_ __,. 7-,_' ",_ ,-~ ,1 _,m,[ T_ .- 'I""~"""='-'''' , ../ ' . Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANDREW E. SLlKE, vs. NO, 01-7092 Defendant CIVIL ACTION - LAW CUSTODY TAMARA J. SLlKE, 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 Brandon Slike Nicholas Slike Shanna Slike September 4, 1985 February 6, 1990 July 14,1983 Mother Mother Mother 2. A Custody Conciliation Conference was held on January 28, 2002, with the following individuals in attendance: the Father, Andrew E. Slike, and his counsel, Debra Denison Cantor, Esquire; the Mother, Tamara J. Slike, and her counsel, James M. Bach, Esquire. 3. The parties were seen for their first Custody Conciliation Conference in respons~ to a Complaint for Custody filed on December 20,2001. There was a Petition for Special Relief filed that same day. Following a January 11, 2002, hearing, the Court ordered shared legal custody of Nicholas; primary physical custody of Nicholas in the Mother; and periods of partial custody on alternating weekends for Father. The matter was subsequently referred for a Custody Conciliation Conference. 4. At the time of the Conference the parties reached an agreement to continue the present schedule wherein the present Order would not be changed with the exception of some provisions for holiday time and participation in a custody evaluation through Dr. Stanley Schneider. At the time of the Conference, Mother agreed to participate in the custody evaluation but refused to contribute anything to its cost. Subsequent to the Conference thE;! Conciliator was contacted by counsel for Mother via a letter indicating that Mother has now taken the position that she does not want to change the present Order in any way and that she will not voluntarily participate in a custody evaluation. Counsel for Father subsequently responded with correspondence indicating that they oppose any change in the Order as structured at the Custody Conference and that they continue to wish to pursue a custody evaluation with all costs being born by Father. ~"f:~: i:' '__'~->/,1<, '-',._;"~ , ,c ~"-r -," 5. < _ '_':_ -~" , rj. "~' , ~ ",' ",- ,,-,'""" ,,- ,", _ 0', , -" _l~ . , ... ' No. 01-7092 -- Civil Term :'! 5. Father's Dosition on custody. Father reports that Mother left the marital home with the Children in November 2001 and initially denied all contact between he and the Children, Subsequently he contacted counsel, filed a Petition for Special Relief and, through Order of Court, received a temporary alternating weekend schedule. Father is seeking to have shared physical custody of the youngest Child, Nicholas. Father acknowledges that there is an estrangement that exists between himself and the two older Children, which he reports has occurred since the Mother left. the home. Father feels that Mother is being overprotective. He has historically worked long hours at a family-owned beer distributorship. In light of the concern regarding the estrangement of the older Children and their relationship to Father, Father is seeking a custody evaluation to include both parents and all three Children, Father is specifically most concerned that the estrangement that exists between himself and the older Children not be repeated in the relationship between himself and the youngest Child, Father has proposed a custody evaluation with Dr. Stanley Schneider and based on Mother's refusal to pay any portion of the evaluation, Father has agreed to pay the full amount of the evaluation should the Court so order it, in light of Mother's change in position and present refusal to participate in such an evaluation. In response to Mother's allegations regarding his lack of involvement with the Children since separation, Father points out that Mother, until recently, refused to disclose her whereabouts with the Children, With regard to the allegation that he attacked his oldest Son, Father describes a circumstance where he stood a few feet away from him and pointed his finger at him in the midst of a family meeting. Father acknowledges that he did allow the Child the choice of sleeping in a guest bedroom or sleeping in Father's bedroom on a mattress and the Child chose to sleep in Father's bedroom on the mattress. Father also acknowledges that he did ask the Child to leave the bedroom ajar while he was showering, however, Father did not feel the Child was lacking appropriate levels of privacy for his shower. 6. Mother's position on custody. Mother alleges that during the marriage Father was not participating much in the raising of the Children and described him as being very uninvolved. She alleges that since separation he has not asked about the Children, contacted them by phone or sent a Christmas card, She does acknowledge the older Children have some hostility toward Father. Mother also thinks that Father is not competent to be alone with the youngest Child but does not make any specific allegations on how this might be a danger. to the Child. Mother is presently employed as a registered nurse case manager for Health South, and works from 7:30 a.m. to 4:00 p.m. Monday through Friday, She periodically takes call on Saturdays. Mother has taken the position that Brandon does not want to see his Father on alternating weekends. She is very critical of Father for allowing the Child to sleep on a mattress in his bedroom during custodial visits and of allowing the Child to be around a pet dog due to allergies. Mother claims that Father attacked the oldest Child in September. She describes Father as lacking in common sense but denies that he would try to harm his youngest Son unless he voiced an opinion. Mother was also very critical of Father for what she deemed to be a lack of privacy by asking the Child to leave the bedroom door open while -,["V~ ,~. ,~i1'~'^ "~" -,!'!P_. "', 10',~-" , _'.~'",__, C.~- " , ~ ......-- No. 01-7092 -- Civil Term he showered. She claims that because Father sleeps very soundly he might not get out of bed if a fire were to occur at the home. At the Custody Conference it was Mother's position that Father needed to attend parenting skills classes. 7. The Conciliator recommends an Order in the form as attached. It is expected that a hearing will take one full day. 8, The Custody Conciliator strongly recommends that a custody evaluation be done in this matter and that Mother be required by the Court to participate therein, It is the Conciliator's opinion that it would be in the best interest of the Children to understand the nature of whatever estrangement may exist between Father and the two older Children, and to provide them an opportunity to address the situation in this very key relationship. Additionally, the evaluation would be helpful to all Children if the evaluator could give the parties guidance in assisting their children as they adjust to their parents' marital separation. C2 -f S;O-z--- eli sa Peel Greevy, Esquire Custbdy Conciliator Date -"0J1i~f41 ^ _ - ',<, _PW''''-" "'~- "'~-"" >',~" ,;~ '., 'I' r _ '.r., c - ,t" '- ~ ,'" , ' "" ,'--, ,--~, , ~" - 0" ,t ~ c :t~(~-".--'~'lr 'H"",""-~"""'~""'" " ~, ~-- . . . , \ ANDREW E. SLUill, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA v. NO. 01-7092 CIVIL TERM TAMERA J, SLlKE, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this OKday of \IlIl? '/ ,2002, upon consideration of Plaintiffs . . ~1J7.d.dt?",4 j ILltu {~'-1 f'1?,."t,f{( (O"-1~\" Motlon for Contmuance, It IS hereby {)RDERED that the hearmg scheduled for May 20, 2002 is continued.1T/cl ~c. ~:'Z)I?~ l's f'C ~~k~cL,~J -f.cJ jJ7tm~ ItltLF ;,(:1 ;)OO;? cd tj: 31 q. m, U'-' ~ .po'-/, {/ I / BY THE COURT: L~ 5 /).;}.. - 0 d-. to', '; ~ . ~cu::..h ... a t:-OJ.\ \OP- J. ~~ ' 511}/J~ ""-.-"'1;r.-,,, ". ^'_,-;<:_'"J""'Y:"~'f"",:~~;-,'._'""_-_'''",t'''''''';!::'i'-:)',,,t,,/_>~,, '-':l'T -,. " . '" ,5''':''!':-r''' ""., " '-~"" ~,'-''';-''-' "', .- ,-' J ,- -"'-::-", '-- -, -, " ';'!~'- ~",<1,-"~;"f'1- ,,'-,,'..,=- '''('_ )-1:;":_ ,__'~-" ~ " I " '!'^,-;; j . . . . I '"'-::<"'t.~J\"",'-!\,:;<:;_;,';'_:~':f','>~, _/ .~ :'r ~/;"\'_ ,~'- C__, ,-" "OJ' ~"'~~';'\"-'.~"tJ",-" "">~','\--"_"Y'__ ',2':1,0-:'-"""-", ,,"",,',' ,',,,C,, _ ,_ __ _ _ ~- ., '".'> , '.~"~'" '='ii.1""~~,_,,,;,"""""-"".' ~'-~. ViNV/\lASNN3d ,t. ! ~llr'I i'(l~l ~~t\ ,\,'^1!.J:1q!,'\J("'II"'\ ~ ......t, '.- ',' - " , ~I ." ,t 1\.} 6Z =t; i,~:d I 'J ),'" I ~n " r.., , j 't< ~ v-, '.... \. AUVIC':i __ _"~. __ .:J(j :"i~}!3:IC)-'\J:Ti!.:i _,'-' ~_" ,<1_1"_,.,.", 'V't,1Y'--i$:~f;;:;'!"~.~\'~.,f",_-'-_ ",,;,:_',;<~'\_,~: ' _,.~_~,,-,l ~",:-,~ "J,4~'1'~":}~~''':?''~!' ~'~" mnll Tlr" ] 'TUF4f".'firf' I ! i 1: I. r [,- ! L , F f, 1 r ! \~ ~: f ",- o ,/ ':"G'^ :1'" ":,~"-~~~'?!5'f'?'''':"'''J::.:,1''7~';;~: IT T REAGER & ADLER 141002 05/17/20Cr. 08:22 FAX 717 7.30 73~6 , :""\"iI<i1!~~_M REAGER & ADLeR, PC ATTjlRNEYS AND COUNSELORS AT LAW ~SI MAnKEr I)Tn[;~ CAMP HILL. PENNSYLVANIA 1701 t.4642 717'7f13-1SSS TELEFAX717-7a~7366 WEOllSITEO; ResgerAdlerPC.com THEODORE A. ADLER + DAVID W. REAGER CHARlES 1;. ZALESKI LINUS E, FENICl.E Dall'lA DENlaON CANTOR THOMASa. WIWAMS SllSAN H r:l"lNFAIR JOANNE H, CLOUGH CHRISTINESCHWAMBERGER LJOUGu>.8 P. LI:HMAN Wriler's E-Mail AQ'dress; c:lUenlsol\!lJeJ)lx.ner ... ('l;PJ1ified eMt TrJaI S~ClCialill' May 17, 2002 Via Fai'~;miJp: (717) 240-6462 The Honorable J. Wesley Oler, Jr. CIillibt:rll1Ilu County Courthouse One Courthouse Square Carlisk, PA 17013 Re: SIike v. Slike Docket No. 01-7092 File No. 01-1076 Dear Judge OIeL This letter serves to supplement my Motion for continuance in the above-captioned matter. Attorney J lIIIleS Bach does not oppose the continuance. Your attention is appreciated. Very truly yours, ~{Jt~f11~ Debra Denison Canto!:' DDClrmnk ~ -, .:-'-,}--'- ., I ~ - :lJ_ . .' . Plaintiff IN THE COURT OF COMMON PLEAS CUM.BERLAND CO., PENNSYLVANIA ANDREW E. SLIKE, v. NO. 01-7092 CIVIL TERM TAMERAJ. SLIKE, Defendant CIVIL ACTION - LAW IN CUSTODY MOTION FOR CONTINUANCE AND NOW, comes Plaintiff, ANDREW E. SLIKE, by and through his counsel, Reager & Adler, PC, and petitions this Court for a continuance as follows: 1, The parties in this case are mother and father of one minor child at issue, namely Nicholas R. Slike. 2. Pursuant to a Court Order dated February 22, 2002, Dr. Stanley Schneider was appointed as an expert in this matter to prepare custody evaluations, reports and recommendations to this Court. 3. Pursuant to the Court Order, Plaintiff made timely appointments with the Custody Evaluator. 4. Defendant engaged in some delay prior to making her first appointment. 5. As a result of this delay, Dr. Stanley Schneider has indicated that he will not have completed his evaluation in time for the May 20, 2002 hearing. WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant him a continuance until such time as Dr. Schneider's report is completed. DATED: 6/4/ D Z-- '~"''l'1~~-{ " "~-~, -,,'c'_';c.,:- "Ff,"'i_'-'_'_\"~'"-"",:_-c:';;',,_;';,,_'-,,~,,, '., I~"'_':"''?'"t'o'''' .w" _,n-..",,-,-' ,." ' . , "^ . '~-"'-,--,- ,- , ~':"'>--"--,".' .__' 'C""'~',,', ~,~_.,', . r ,,'- ,,. . CRRTTFICA TR OF SRRVTCR I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served on the following individuals via United States First Class Mail, postage prepaid as follows: 'I "I I :] ;:! James Bach, Esquire 352 S. Sporting Hill Road Mechanicsburg, P A 17055 Dated: 5/tl/D 1- ':i Ii ,I; ;,:; ~ : 1 " ," . i:i: I :i' ',I ':1 i'j:.J"iJ}~",' .~ -- . ".__, ',-"":y,,,:,:,,,,,,,~_''''~''''J ,~_-~_:';_,,/<' _"<"'/,,,,,~:;:~__ '_I~~"t",,{",v.:r,-,~'~7. _' _' ""':"" ":.~ ",,,",,,,~ / .., "- --.'", ,,-.- -,-,,)', ~- -":">4',_~"-,':",,"_;, ""':<:'_" --1' C._ , ~" ,_ _"-<,,,,,T~V'-,__::,, ,,,.,-,,,., ""," " m, "', h '''"YC',.".'=.~,''Y'.C'' ' ",--,,",,-,'"->' ~~ -0. r ", <_',,"_',0' -,' ""'""4'_~ ~ 'C._"'"' ',-- '}"'><"''''""^-<" ,~. '.r~.f]'J"i'J\-f' o c "'~ ;gtH z:x.1 "Zt-. ~~:: ~-'-.' ~Q z :~ ^;. ~,__~l~'~y-,;,-~;-",~~S''''_~_~, ,~_~;,':rT""~-'''- " C) J,\) ::I: 1:~" -....: () "'1'1 ,,~ ";~i :!J r- ,.'~~ ~,.. -T. :~?~:; Ol-n ,-. """ :D -< i'" -C' _~7' (n -~"8!I<d ....~~?:""~~~_,~_.)J.~!Ji_l!l~~,' , PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REW E. SLIKE v, 01-7092 CIVIL ACTION LAW AMERA J. SLIKE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, ~onday,June24,2002 , upon consideration of the attached Complaint, it is ereby directed that parties and their respective counsel appear before ~elissa P. Greevy, Esq. , the conciliator, at 301~arketStreet,Lemoyne,PA17043 on Tnesday, JuIy30, 2002 at 10:30 AM for Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if th s cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary orde . All children age five or older may also be present at the conference, Failure to appear at the conference may pro ide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish auy and all existing Protection from Abuse orders, Spe ial Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Melissa P. Greevy. Esq. ~ 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 TOYOURATIORNEY AT ONCE. IFYOUDONOT HAVE AN ATIORNEY 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 ";-~r~~ _, >."~.",,,,> , ;" ~. - ~ " "'"' I, ' " "'::'", >, l' ,. =J: " >c ~~,- ---'Hel~"""'<s;"_<h' w'-<~,"'~\'~'+ -Y~-.-""'~- r;:'>-l"Jl>)f1r;1i,..;tl1~tl-[t~:'~t~;'-f~~o&!'f2~~;~-'1\ ~p~~~ ~#Zl~ ~nI ~ ~ J:::z~~-rv \/(NV/\1A,SNN3d U!\!01([1 n,I$I'J:];:;,'Jfv'I I ,__ _' _", " (__H ~n 1, h...' ~ . -;I I" ,...,,, I nl~ '70 $~ :(,. /,jd ':10 f"41 (, Al:lVIOl\j~j':~J:,;:.L 38i:l:iO-GJl1J _1" ~'J ;, i',_, ,~, ~J).J", ' (V -3(' '7 ('(75(;-7 ('(} 5(' ~ ,_J~!I1,<J.,lj<l~~,<!f'JlI~-m~-8!f!i1"1;~'~!ii':i~", ,"'""\iI';,*"-,,:,,#'<i'd-''''J~''';!i'*i,,;;,;;,,,,,"<_'~-'<-'_F''' '~h'-"""i~"";:"~'-":',1("!I"iif""""m;1\;!Jtg?'ii"~'''f'ji'-jf,,jfWt"~~jj1~_~I~i~Jj!lF~~'~~8 i {~ Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA ANDREW E. SLIKE, v. NO. 01-7092 CIVIL TERM TAMERAJ. SLIKE, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this _ day of ,2002, upon consideration of Plaintiffs Petition to Modify Custody, it is hereby ORDERED that the hearing scheduled for 2002, in courtroom # at .m. BY THE COURT: J. ',~}l~,J" . _, ".' '0"""'" """ _.y' ~ . 0 ,0 I" :' '; c,,", Cl" .-"_~_. " _._,_ . ~- "- ';"-' -" ' ~,' F--- - -. r~!(~~~-~ij' ANDREW E. SLIKE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. :NO. 01-7092 Civil Term TAMARA J. SLIKE, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Conciliator, at the , Esquire, , Pennsylvania, on the day of ,2001, at .m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or, ifthis cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary Order. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT DATED: BY: Custody Conciliator YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 " '.-. ..,""', ~ --~ "'" ~ -I~ ' '",- '-"'"'-"'^ < "-'" ',-y" ~-" ' , ANDREW E, SLIKE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-7092 Civil Term TAMERA J. SLIKE, : CIVIL ACTION-LAW IN CUSTODY Defendant PETITION TO MODIFY CUSTODY AND NOW comes Andrew E. Slike, by and through his counsel, Reager & Adler, P.c. and requests this Court to modify the temporary Order dated February 22, 2002 as follows: I. The parties hereto are the natural parents of Brandon E. Slike, Shanna E. Slike and Nicholas R. Slike. A complaint for custody was filed by petitioner on or about December 18, 2001 along with the Petition for Special Relief. 2. A hearing on the Petition for Special Reliefwas held on January II, 2002. The Court granted Petitioner partially custody rights. 3. A custody conference was held before Melissa Greevy on January 28, 2002 wherein a temporary order of court was entered granting additional partial physical custody rights to petitioner and in addition ordering a custody evaluation to be performed by Dr. Stanley Schneider. The temporary order is attached hereto as Exhibit "A". 4. Pursuant to this temporary Order of Court, the parties have been participating in the custody evaluation process. However, it is not expected to be concluded in the immediate future. 5. The temporary Order Court does not make any provisions for summer vacation time with the minor child, Nicholas. In correspondence to opposing counsel, ''"i~,_!""__."__,,,,,___,".___"__";,o, "" , , petitioner has requested a least one (I) week of time to spend with his son. His request has been ignored. 6, Petitioner would like custodial time with his son from July 3'd through the 14th of July which is inclusive of his weekend. WHEREFORE, Petitioner requests this Honorable Court to enter an Order granting him partial custody from July 3,d through July 14th so that he may vacation with his son. Respectfully submitted: &/17/D2- 2331 Market Street Camp Hill, PA 17011 (717) 763-7366 J"-,ft, ",-~"':""'?'~- ; _, _ - p_'?"j ~_,__ ~ '- '-1.',-- ~ -r-,",," . ''c'__ _ I tlL iYEB 1 9 2002 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANDREW E. SLlKE, Defendant NO. 01-7092 CIVIL ACTION - LAW CUSTODY vs. TAMARAJ. SLlKE, Oler, J. -- TEMPORARY ORDER OF COURT AND NOW, this :l. ;l ~ day of February, 2002, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. ' Legal Custody. The parties, Andrew E. Slike and Tamara J. Slike, shall have shared legal custody of the minor Children, Brandon E. Slike, born September 4, 1985; Shanna E. Slike, born July 14,1983; and Nicholas R. Slike, born February 6,1990. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion, Pursuant to the terms of Pa, C. S. S 5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address ofthe Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Effective March 1, 2002, Father shall have physical custody of Nicholas on alternate weekends from Friday after school until he is returned to school on Monday mornings. 3. Holidays. Father shall have custody for the Easter school break from Saturday at 7:00 p.m. until Monday at Noon, and on July 4, 2002, from 9:00 a.m. until July 5, 2002, at 9:00 ,a.m, Mother shall have holiday custody for Memorial Day and Labor Day. _ 4. 'The parties shall submit themselves and their minor Children to an independent custody evaluation to be performed by Dr. Stanley Schneider. The parties shall sign all necessary releases and authorizations for the evaluator to obtain medical and psychological information pertaining to the parties, Additionally, the parties shall extend their full cooperation in completing this evaluation in a timely fashion and in the scheduling of appointments. Father shall bear the full expense of the evaluation: Therefore, Dr. Schneider will serve as Father's witness. Exhibit "A" 'C,\~5:rrTL """7"" '_^. -- ~,' ~-" ~- _..0_ _,"""" , " No. 01-7092 -- Civil Term ": ;1 5. A hearing is scheduled in Courtroom Number 1 of the Cumberland County Courthouse, on the day of May, 2002, at o'clock, _M, at which time testimony will be taken, For the purposes of the hearing the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall file' with the Court and opposing counsel a memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least ten days prior to the hearing date. BY THE COURT, /~~ 'auR/1 (fl..fh',O, J. e ley Oler, r., J. Dist: Debra Denison Cantor. Esquire, 2331 Market Street. Camp Hill. PA 17011-4642 James M, Bach, Esquire. 352 S, Sporting Hill Road. Mechanicsburg, PA 17050 4:t1;<<".~ \'.'tM t:"-t,;!f~~,:'1"''t.% ~ ~"\:~,J.t,~.r~>'f,,,)t,;~ :re,. ~:~.,. ~_~~/;A ~~'*" ~ '~:'.".:_':i,,-.-..~,;tO~tl.J In Y;~$t~m\~~.~y I '; " ~%;(:J;', iJJ! ha;:d ~';ij thrJ '''''.,J .d ..,,',..(' :','.'''.,': ::,''. t'" G~~..J ,.. v~~ .,.:, -1"."',,, '_ '",< <'> ,-, .,",'~..'~ ' l:.Ilo. T, his .2 ~ 't dg~' 'J!-'~/d"J .,21.Jd.1..> _ ~u () --'-~ . ,Aq~~ Prothonatart ~J;~~!l!i'" ,., -,~ ',< , I' , ,_.< - ~'"1 "'; ,,_,_, ~-, ,- - - - . , ANDREW E. SLIKE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. NO, 01-7092 TAMARA J. SLlKE, CIVIL ACTION - LAW CUSTODY Defendant 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: ; \:l~:p!f'r~ -~, ,,' NAME DATE OF BIRTH' CURRENTLY IN CUSTODY OF Brandon Slike Nicholas Slike Shanna Slike September 4, 1985 February 6, 1990 July 14,1983 Mother Mother Mother 2. A Custody Conciliation Conference was held on January 28, 2002, with the following individuals in attendance: the Father, Andrew E. Slike, and his counsel, Debra Denison Cantor, Esquire; the Mother, Tamara J. Slike, and her counsel, James M. Bach, Esquire, 3. The parties were seen for their first Custody Conciliation Conference in response to a Complaint for Custody tiled on December 20, 2001. There was a Petition for Special Relief filed that same day. Following a January 11, 2002, hearing, the Court ordered shared legal custody of Nicholas; primary physical custody of Nicholas in the Mother; and periods of partial custody on alternating weekends for Father. The matter was subsequently referred for a Custody Conciliation Conference. 4. At the time of the Conference the parties reached an agreement to continue the present schedule wherein the present Order would not be changed with the exception of some provisions'for holiday time and participation in a custody evaluation through Dr. Stanley Schneider. At the time of the Conference, Mother agreed to participate in the custody evaluation but refused to contribute anything to its cost. Subsequent to the Conference the Conciliator was contacted by counsel for Mother via a letter indicating that Mother has now taken the position that she does not want to change the present Order in any way and that she will not voluntarily participate in a custody evaluation. 'Counsel for Father subsequently responded with correspondence indicating that they oppose any change in the Order as structured at the Custody Conference and that they continue to wish to pursue a custody evaluation with all costs being born by Father. ",,''::''-'' -.' "",-~,_'1' _", "'If: '-- ~. - "'t'.."",-_ "" ','" _ "d, ."''-__, ~,__ ,_-_C'. '~''le",' ._ ~ ,,__ _"".-.~"~ . ,_, , ,~ ~ " , i) j't ,; [": r, :'? :';~ " i! ii k! v; 1'; [':-- I:; , :~; t: i>i ;-1 " i(i j~: !'!: I;:, ..:,,; ';o!, "~I '~,' I ) ,--1 -'\"'*-'!;<~;-~,.,"-" .' No. 01-7092 -- Civil Term 5. Father's position on custody, Father reports that Mother left the marital home with the Children in November 2001 and initially denied all contact between he and the Children. Subsequently he contacted counsel, filed a Petition for Special Relief and, through Order of Court, received a temporary alternating weekend schedule. Father is seeking to have shared physical custody of the youngest Child, Nicholas. Father acknowledges that there is an estrangement that exists between himself and the two older Children, which he reports has occurred since the Mother left. the home. Father feels that Mother is being overprotective, He has historically worked long hours at a family-owned beer distributorship. ,In light of the concern regarding the estrangement of the older Children and theirrelationship to Father, Father is seeking a custody evaluation to include both parents and all three Children. Father is specifically most concerned that the estrangement that exists between hims,elf and the older Children not be repeated in the relationship between himself and the youngest Child. Father has proposed a custody evaluation with Dr. Stanley Schneider and based on Mother's refusal to pay any portion of the evaluation, Father has agreed to pay the full amount ofthe evaluation should the Court so order it, in light of Mother's change in position and present refusal to participate in such an evaluation. In response to Mother's allegations regarding his lack of involvement with the Children since separation, Father points out that Mother, until recently, refused to disclose her whereabouts with the Children. With regard to the allegation that he attacked his oldest Son, Father describes a circumstance where he stood a few feet away from him and pointed his finger at him in the midst of a family meeting. Father acknowledges that he did allow the Child the choice of sleeping in a guest bedroom or sleeping in Father's bedroom on a mattress and the Child chose to sleep in Father's bedroom on the mattress. Father also acknowledges that he did ask the Child to leave the bedroom ajar while he was showering, however, Father did not feel the Child was lacking appropriate levels of privacy for his shower. 6. Mother's position on custody. Mother alleges that during the marriage Father was not participating much in the raising of the Children and described him as being very uninvolved. She alleges that since separation he has not asked about the Children, contacted them by phone or sent a Christmas card. She does acknowledge the older Children have some hostility toward Father. Mother also thinks that Father is not competent to be alone with the youngest Child but does not make any specific allegations on how this might be a danger to the Child. Mother is presently employed as a registered nurse case manager for Health South, and works from 7:30 a.m. to 4:00 p.m. Monday through Friday. She periodically takes call on Saturdays. Mother has taken the position that Brandon does not want to see his Father on alternating weekends. She is very critical of Father for allowing the Child to sleep on a mattress in his bedroom during custodial visits and of allowing the Child to be around a pet dog due to allergies. Mother claims that Father attacked the oldest Child in September. She describes Father as lacking in common sense but denies that he would try to harm his youngest Son unless he voiced an opinion. Mother was also very critical of Father for what she deemed to be a lack of privacy by asking the Child to leave the bedroom door open while I . ,,,'" ":Pf'.. '''~'.'''' _" ,_" '''_''_ - C'_ , -,-... ~ c '}.~"!~ -' No. 01-7092 -- Civil Term he showered. She claims that because Father sleeps very soundly he might not get out of bed if a fire were ,to occur at the home. At the Custody Conference it was Mother's position that Father needed to attend parenting skills classes. 7. The Conciliator, recommends an Order in the form as attached. It is expected that a hearing will take one full day. 8. The Custody Conciliator strongly recommends that a custody evaluation be, done in this matter and that Mother be required by the Court to participate therein. It is the Conciliator's opinion that it would be in the best interest of the Children to understand the nature of whatever estrangement may exist between Father and the two older Children, and to provide them an opportunity to address the situation in this very key relationship. Additionally, the evaluation would be helpful to all Children if the evaluator could give the parties guidance in assisting their children as they adjust to their parents' marital separation. OZ -1 S;(}2-- eli sa Peel Greevy, Esquire Custbdy Conciliator Date ... ., "~,,. ...'.01: \. ( " '. '. .' ,...... '.1,~. ":~'r-"'''-i""_;_,,,,,'~'''''''~f'''',, . ,,,-,, _. -..... ...,.,' ....,- .~.... c.l~' .' .10 "v... .1...... ...... j -.._ _ l"'l"W'WEAWW...,--r "'~"" _'_"_._nn_'~~'" .....rn.;;I".;.;.U11"-"-~.&.."''""1oo;T-.. ....-.; .I.J"-.... -a...r ~\,;'. " VO'UTFlt': ,,,',/10:'01 ...:!:t.!:.~..;...._~.o.;. ......~.,.. L ~\~',d;.;:.\~. 'E, Slik~. l'l.rd.~~.. ....elift} :t!lJ 5tat~ 1.b~il tll~' .i:~\~:t:-1. fP,t forfb in the tbrl:'going l:].....:hl ill~' ;:n'L:: :rl tl' <J.lH.i ,,;('jT~~( ':: ['l't ;i~.. b(.~,t (.If 11\Y i nL~,H 1:~,:ltkrn.. k'I.I.i,,)\,\,jcd~';l:' _lud bl~hef T 1.lll.der.s.tan(1 ~ , 1h:,I; '''ll;':!~ ., ::"l'~JT~I;.ni~ h.:>ll.:irl ~:...;, !~'l~~l.!r.:- :';l~b}l~('t to the pt;:laltic:\j of 1.~: f'~'L C.S.A. 949(J.~;. relating to un:;\~l'll.l! '.'1':lit'i',':lticm f() unrlhlr~:i('.~" 1!!\TE: ~. .t/.~ 2: ~ ~~ --........-..... --- .-..._-~.. Andrew 1", Silk" ~cn- . .' CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing Petition for Modification was served on the following individuals via United States First Class Mail, postage prepaid as follows: James Bach, Esquire 352 S. Sporting Hill Road Mechanicsbnrg, P A 17055 Dated: U (r1/ 0 2-- 23 Market Street Camp Hill, P A 170 II (717) 763-1366 .;--'::0~~ _.,',-.'V,,_, ,un'I___' -, ',^ ,:"" -, , "" 'I ~ k. _', \',_,'''''''V''- ""_'_",,_,~"" .."'.,_,,,,:,",_,,," ~, '~-'---' =r"'-""""" -..,,~!-~ "~. ~" '.,-. ~-.-~'''''~' ''OJ, "'-~""~l_"'~","'y~-"__~-<,~''',,'L,* 0i~j;;'h4,"''''. ":'1"'1:'0' jji<~~it.fJi;lli~f:'~r~).l~;t'f't!;cg ::t't' . '. )::;~ti: t~ 9 ~ g ~f:! b 1-. '-<: ~ (' C1 - -- (') c "-,- -u(t! r.-,r-''', '.:~ ~~::,i 7~ t.__' e.;'" ~~~~'; ;:: r-~~ ~, '7 :=j -' -, c::~ r-..) (') .:n ,-, c_ ~:~,~; 1] c.) C:J ;>1 .,-. '..,-' T::;o-, CJ --- :::El -,---. -~5?Cfj ._.1 - " ::'-0 -< ,_,'1 (-T~,~ ,TI[J~#;\l~'l\i?fJ':q't'f"'1'W'.w(,"',-e~~~~_~~~tif.w::rrr,~,":-- . - . " ANDREW E, SLIKE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01-7092 Civil Term TAMERA J. SLIKE, : CIVIL ACTION-IN CUSTODY Defendant ORDER AND NOW, this 2...l.day of r u l L ,2002, upon consideration of Plaintiffs Petition to Modify Custody as well as the attached Stipulation, IT IS HEREBY ORDERED that petitioner shall have partial custody of his minor son, Nicholas from July 3, 2002 to July 14,2002. BY THE COURT: ,Wva "(~'7illl!jj _> c '. --, - ," "'\"f~,lf<'"" ,,_'C_ - '"__, ..~""J~<,-,,<' 'L ^, " ^',,-. ~ "",p" --.,"-,-,-,", , ""~'~',',,,, IM'~ '""",",,' . \11'1'.'0 " f i ~.. ,,",/..'1/\ ,11\SNN':Jd /I.!.I':f 1(,,/) t~\jt/Il. /:.:;''''":1\'11 ' ' " ..'",.. "I " ,--_1,,], \' V fie: 1/ (:,~ "ill" ?n \"'~... ;\L:VI(~ \._,----, :'1;-,.''':'' ,::)0 -~-',--.- . ",,'oN """'"=~"'~~""""- < '-"~'''''-"'''.,'~''',,;.r''''_-",,- '-''''-'/' .,- ,-,.,.. r"~~H11tillir..'rht"'t':Jij' "'-''-''i''j\f . - ~, ;',f?',- ,_' "n~,~~l~~"'v;"'''~'''}wr~'~~l~,~~ - r- l~,IIJ!I~nu""'!",,,y,: "~ .-~- , ANDREW E. SLIKE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 01-7092 Civil Term T AMERA 1. SLIKE, : CIVIL ACTION-IN CUSTODY Defendant STIPULATION AND NOW COMES ANDREW E. SLIKE, by his counsel Debra Denison Cantor and TAMERA 1. SLIKE by her counsel, James Bach and stipulates as follows: I. Plaintiff filed a Petition to Modify Custody seeking vacation time from July 3, 2002 to July 14,2002. 2. The parties have concurred on this vacation date. 3. The parties request to Court to enter an Order granting plaintiff s request for vacation from July 3, 2002 to July 14,2002. Respectfully submitted: 2331 Market Street Camp Hill, PA 17011 (717) 63-1:: ~ t ' )0 ()"-' l es Bach, Esquire ttorney for Defendant 352 S. Sporting Hill Road Mechanicsbnrg, P A 17055 (717) 737-2033 ,~ "' " '''"7. > ,.<':" '_"". ;_'-,:_ , .,~~ :jl__-r_^;,"-,_~(~~ _.,-.'-~'~, _ <, ,_ '.' "',' , , I ~~ . ,cw', ,,' ""o. ,...." 'C." """'C"C''''~''ry,, ,m,,',"'" 'J'____"'_"..~_~, '.' ____~; ,,"--',-,-,-,,' >fe'" = ~~..~~o ,.~-, v~_'" "'''''L.''' ~"Y~".Tfr -'rrrlfi' ~-'[:'~'Trn'flir:i1J"_';t~ c' ~~~ !:bjB;.~ i~-t- 2i(=~, )> ---,.c) ~Cl -c: 2: ::< .lA~ 1IJ' ~ " '<~: ~~~. <"'- ''I ,.....,) c;c; :~~('5f , :..: ~.;..~ 25-j~ -I 55 -< :::;~ ,:- .J:'" '; , , )IljWM_*;!IM%i'~:Jf,r,.-0i'<>:~\,1'-~~'i,7.;_c'''''''_: J.)",,_"~~:c,,_'C; mia'i"""_'"',~"7"fr ",~- !~~!f;,-~':-' ,IUL 3 0 2002 ~ ANDREW E, SLlKE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 01-7092 CIVIL TERM v. CIVIL ACTION - LAW TAMERA J. SLlKE, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 29th day of July, 2002, the parties having reached an agreement which has been memorialized in a Stipulation and filed with this Court, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. FOR THE C~ B~4~ Melissa Peel Greevy, Esquire Custody Conciliator :160404 '.,f,liWfWE1L, ^ ""-""""'." ~,,, ,'~-~,' "'!" '> l . 'M~ "~oW. ---" ,",,,8,,,,,,,,,,-,",, .ot\,o~''i''{'''>''-Y~~f''-;';'D''-l~<.tl''W'Hl'-:~r'~~tfjJit'''~:rf1~~f.;;\:;h*VPf;'i>?:\ g S. -00:1 '""'" \..7'):' zC m,E; ;:..c,!- ~C -..p,.-, '-;7\' ) ~G Fe: '7 2 o 0 I" "T1 ~;~;~ -*'" CJ() - :-~::.\--1.'" (:55 ?:)-rn ,~. \ ?~ ~ ~~: -,.... S? (? GS ~ ~~~~l'iti.ljl;rej,*;~~*'1'~~~I''''!i'i'rnll!!~\mi0';lR'>~}''f'1'Jt'1'l--:;l'''~-l!!~'4?,,--,,'~1i?:';';;~'"",\"',l1[""O""""_9i:-;'f:!"'tr, "-'i<'-'''-''J,~:'~~~i?if.m~~j;~W~i\-'il~~';'tt1t,j~N~!IfrIt'~~:%,*i;~f "'jfI{ii',---Vit ~,,, .~, ANDREW E, SLIKE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 01-7092 TAMARA J. SLIKE, Defendant CIVIL ACTION - LAW CUSTODY WITHDRAWAL OF APPEARANCE Please withdraw my appearance on behalf of the Defendant, Tamara J. Slike, in the above-captioned matter. Date: 7' '> d ... J-z- f?s-J.-- Jame 352 Mec (71 . Bach, Sporting Hill Rd. nicsburg, PA 17050 ) 737-2033 ~, 'I ENTRY OF APPEARANCE please enter my appearance on behalf of the Defendant, Date:~D~ ~ cP:>d- J J hn F. King, E IEDMAN & KI 600 N. Second Penthouse Suite P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 Tamara J, Slike, k/p:domestic\slike.app "~",. ,~--,.. .~"",,.' ""_'0.' .c'-~->'f;,-,;~_"7",-~'"'5c:;;,__"I?f,;-',J'""f:'/~':"_', _",___",~:,_, _'"-\_""'",oe_' ",__f'" - . '~'-". ' '='~'W',""'''__'f.?"_~;';_t'''''_.__~,~~, " ,0.. ".,-_.,-1"" ~ """, ' Uk ,"..,y.,.m~...I!!!!t"..""',.,,,.' ,p,r,"'" --,-,' "':;;".'___"'1,",,_~: ___>';"'-:;;~-' --<'.' , ,,~ ,-~ ~'''',,4'<, ,- ~~~"- II Ii . ... '''fttif-;;r~"f:_1ijt:'~( "-"'<"'~,U-lli'i'it~":-f':ir~: . o c <" -ofi;:j rTlrn Z-"j Z~ ~:f: <,-,j ?2::o -~O )>C ";Y' ~ ~ ;1lIJ_]!llfI!!l~_, iljH~~"f'1.,,~JiI;LI '_> _':_ ,>, _, " .."_~,,,."e;'''\'T'r_,~ffl~,ii...~,,, '_,_ , CJ r..., :no ~ - en I li~J 'T) :.:::::1 ;!~~ ~~~ '..J -; ;~ =< v ~ ::> 0.' {:.$ ~ ~;,~,,; """\r:Q![IIJi!~_,_,__".~,, -~ lliII .' ANDREW E, SLIKE, Plaintiff v, TAMERAJ. SLIKE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 01-7092 CIVIL TERM ORDER OF COURT AND NOW, this 15th day of August, 2002, upon consideration of the attached letter from Debra Denison Cantor, Esq., attorney for Plaintiff, the hearing scheduled for August 19, 2002, is cancelled, ~bra Denison Cantor, Esq. 2331 Market Street Camp Hill, PA 17011 Attorney for Plaintiff ,rfames Bach, Esq, 352 S, Sporting Hill Road Mechanicsburg, P A 17055 Attorney for Defendant :rc <j~~)lt, '~j_,pm,_, .__~W"__,,,,, ~""_.., _",,'__~,"'.-_""'"~_', "_, I-_~,!,' '. ". ~ n BY THE COURT, / l~ <g -}$ -0:;) j-" --~ ... , ~f"~~~,'-^' ~~ .-~;,-" IJr. .,,! ./J,,;",1':r, '.' - -'-",," &, "-" ,- "'~'. '"'c^;l,'~_,,,,_" -D '", '.- '~;.- 'Tlf~") r ~~[!~~ft.!}t~f'Wr't;1.:)~>t1?iP~~"; -, . Clc\ """SN"b .,("\'" "\>','.,,,i\I!,,' Ir-,r,k'l.\ h.J }, ,~~\~)I (~{~",,~~~,.:~:~, I \ \'~\ ,'~' J'\.., '; \ ~\l1j ~\J I"" ...,' .\\\ it, (..:1 . ~ (__,~.\' - "0 .', \_Ci~2,~~_~\,i, l\-\\d\\.;\-'~~"",'>,'~f"\-G:J Ib ,,,D-,- __:,f'.,,","\\... :::\w,e'-' jO ~~_ ,~,II_ lI~,~;)\,JU, ,-.+.,.",_"~T___ T,.. -;"'-_~ ~ On, >'.'" _!~_, r". _J;~~~I:'i'~O/~.'Z'J);m"'~".i"W_'-FW:f_"\i1;"_'fi[~r;~'~",,11J1ll~~~I'i<'~~~<~~~~~1_-' 08i14i20~2 13:40 FAX 763 1907 REAGER&ADLER --~:!:....---.-- " ---_.- REAGER & ADLER, PC All LJRNEYS AND COUNSeL-ORS ^T LAW 2331 MARKET STREET CAMP HILL. PENNSYLVANIA 17011-4642 117'7e~I~63 TELEFAX 717-130-7366 WI;BSITF' Rp.agerAdlerPC.com !4i002 ~\~1 ~ ( THOMAS O. WILLIAMS h SIIAANH.CONFAIR ( :J JOANNE HARRISON CLOUGH f1 \LI DOUGLAS P. LEHMAN +cor!l1ied Trial Speciali.. THEiODOREi A Anl.ER + OAVID W. REAGER CHARLES E. ZALESKI UNUS E. ~t:Nlo,;Le: DEBRA DENISON CANTOR Write!"s E-MElil Address: dtlenie.on@epix.net August 16, 2002 VIA FAX- (717) 240-6462 The Honorable J. Wesley DIeT, Jr. Cumberland COl1nly c.ourthouse I Courthouse Square Carlisle, PAl 70 13 RE: Slike v. Slike Our File No.: 02-359 l)ocket~o.Ol-7092 Dear Judge 011:c; The parties have come to a resolution in the above captioned case. WI: 1111\1'" circulated a stipulation I1T1d anticipate having it d",livered to your chambeTs either Monday or Tuesday of next week. There ore, the hearin,g scheduled for August 19,2002 roay be continued pending the entry of the Order. ./ /../' .--....---... DDC er cc; Andy SHke John King, Esquire-Via Fax-232-9946 ~1':fi : - - " ~-----'~ ""'" "' .",,-,..- ,< . -, ,. ^ ,ANDREW E. SLIKE, Plaintiff : IN THE COURT OF COMMON PLEAS : COUNTY, PENNSYLVANIA v. : NO. 01-7092 Civil Term TAMERA J. SLIKE, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, TO WIT, this ~day of ---A . , u -' So ~ ,2002, it is hereby ORDERED AND DECREED that the attached Stipulation for Custody is made an Order of this Court and said Stipulation is adopted it its entirety and incorporated herein as an Order of Court. BY THE COURT: ''''~I''~''''",'- -'--""'_;':'_"5'=7f~ - "',"",~eJ _~_ '''.,'C." - -,'--'- 7 . . ".,r.. U,., ., "~"~'"h..'_, C",.' * > ,~-,o." w. jc;}-'::'~'~:;'~>t ,:~ 'j"'r)~~:::'<??:;'-JI?~~ji/""'iirfrlti,.i~rt\lf;e;:~~"':;~~~f'f{_;,!;;;~:;~;L liINV;ilASNN3d )J]\!ncc (ji\..!,:-rii:.i:j8ii\ln8 9? ....7 I:,,',,]' - I -, -,.., - -. b JiI\i (I) ^tN10~.C:-' 3JlJ::!O -. -O:!~:;~J :J~) .rr-e.. 1i!. 1..J, " _~'~'_7/','~' ,"._-~~~,",M~'r-,~_"ii'~:"f~''1-''1'i;''''';;_l',-wr",,''mi'iJ1~~:~~<"~m';;_~~f;::,: ~ fL"!. ',~-,-' I ANDREW E. SLIKE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01-7092 CIVIL TERM TAMERAJ. SLIKE, : CIVIL ACTION-LAW IN CUSTODY Defendant STIPULATION ;;,; WHEREAS, the parties wish to enter into an agreement relative to the legal and physical ;;:: custody of the child, Nicholas born February 6, 1990; and WHEREAS, both parties have been provided an opportunity to review the Agreement with the counsel of their choice prior to signing; and THEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound hereby, the parties agree as follows: 1. Shared Legal Custody: The parties agree to shared legal custody of the said minor child. The parties agree that major decisions concerning the child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall promptly notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the '&~~-'~'~-'-"-'--' """.,,-. ~, .- ._~ ~~,~=" - .~ ~.---' - - .,- , ,-- =,.",", ' ~ e_ .~" r - parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. Mother specifically agrees to provide Father with all documents regarding school activities, medical conditions and treatments as well as religious concerns. Mother agrees to do so in a prompt and timely manner. Father agrees to contact the school and request that the information be sent to his home directly. Mother agrees to provide Father WIth all extra-curricular activities schedules and to keep him advised of any i medical issues that may arise. In addition, Nicholas has engaged in CCD classes and the parents :/ agree that he may continue the CCD classes through confirmation. Thereafter, the parties will discuss whether or not further religious education is necessary. 2. Physical Custody: Mother shall maintain primary physical custody of the minor child. Father shall have partial custody as follows: SCHOOL YEAR. a.' Father shall have custody every other weekend from Friday after school, with ,"., . the school bus dropping the child at father's home, until Monday when he places the child on the school bus. If Monday is a school holiday, Father will maintain custody and place the child on the bus on Tuesday. b. One evening per week from after school, with the school bus dropping the child off at father home, until 8:00 p.m. except if child is in CCD class, then Father shall return him upon comple,tion of the class. Father elects Wednesday until further notice to Mother. ';'~\l - ~,. ,''''' ,'.-' - .".'" < ""_.,,. '__' '.._1___.._ <" "''' - ,~~,""_'.~' " "'--'''-'.. -.-0+'- - 1""''''' ~ "'".~" r II -- I c. Father shall be entitled to custody during every school holiday including in service days. If the school holiday is not attached to Fathers weekend, he shall have custody the day of the holiday at 10:00 a.m. until the following morning when he places the child on the school bus. I. The request for school holidays does not include any half days that ~\^ have been scheduled unless that half day falls on Father's weekend at which time the child will ride the school bus home to his father's house. 2. Father shall be present when Nicholas gets on and off the school bus. SUMMER. The parties agree to equally divide the summer holiday by alternating custody of the child every other week from Sunday at 7:00 p.m. to the following Sunday at 7:00 p.m. The summer schedule shall begin the Sunday immediately following the last day of school and shall continue to the Sunday prior to school beginning. HOLIDAYS. The parties agree to alternate Labor Day, Memorial Day and July 4th. Said holidays shall be defined as the evening before the holiday at 7 :00 p.m. through the holiday at 7:00 p.m. Mother shall have Labor Day, 2002 and the parties shall alternate thereafter. Mother's Day shall be with Mother and Father's Day shall be with Father each from 8:00 a.m. on Sunday through Monday morning at 10:00 a.m. THANKSGIVING In order to accommodate family traditions each Thanksgiving, j Mother shall have custody the Wednesday prior to Thanksgiving at 3:00 p.m. through Thanksgiving Day at 3:00 p.m. Father shall have Thanksgiving Day at 3:00 p.m. until Friday at ;,_,~",_jl."'If. '- . ..- -'~,fl~',>o ~""c<, "",-, .,,-~ ;-"".~."" -~-'^ ""~",, , <- .,-,?< " ", ' I ""P'.-, 1- ~ _ -~:~ , 3:00 p.m. If Father's weekend falls adjacent to Thanksgiving he shall keep the child through the weekend and no~ engage in any exchange on Friday. , CInuSTMAS. , Father shall have Christmas Eve from 11:00 a.m. until Christmas Day at 11:00 , a.m. Mother shall have Christmas Day from 11 :00 a.m. until December 26th at 11 :00 a.m. The parties agree to equally divide the remainder of the school holiday with the Father having his share consecutively at the end of the holiday for his family trip. SPRING BREAK. Mother and Father shall alternate custody of Nicholas during the school Spring Break every year, with Mother having custody during spring break 2003 and alternating thereafter. This break runs from after school the day prior to the break beginning until the ! morning school ~egins after the break. EASTER BREAK. Father and Mother shall alternate custody of Nicholas during the Easter break each year with Father having custody during Easter break in 2003 and alternating thereafter. This break runs from after school the day prior to the break beginning until the morning school begins after the break. TRANSPORTATION. F~ther shall provide all transportation for the minor child under the assumption that the school bus will be able to provide transportation during the school year, at those times herein specified. It is specifically acknowledged that transportation may be provided by some of Father's family members if necessary. '. """."., ,.~<'_""."__ .~,~'" ,> I~"".--F,-- - - " ,,,e,= '<',,"'.--- , _r,_.,_e" lft"11 . . ;~~$,~Jl COMMUNICATION. The parties acknowledge that they have difficulty in communicating regarding the needs oftheir children" Therefore, the parents agree to retain a counselor covered by the parties insurance and shall meet at least once a month, or at the discretion of the counselor, to discuss issues regarding the children. TELEPHONE CONTACT WITH CHILD. Both parties shall have the right to reasonable telephone contact with the child during the other party's period of custody/visitation. Neither party shall interfere with the other party's telephone contacts with the child nor shall they interfere with the child's telephone contact with non-custodial parent. Each party shall make all reasonable effects to promptly return telephone calls or messages left by the other party regarding the child. DISPARAGING REMARKS Neither Father nor Mother shall make any disparaging remarks regarding the other parent in the presence of the child. Such as those that might tend to alienate the affections of the i child toward the other parent. Also, each parent shall inform relatives and friends to also refrain from making any disparaging remarks regarding either parent in the presence of the child. SUPERCEDES OF PRIOR COURT ORDER. This Stipulation shall be entered as a court order. This Stipulation shall supersede all prior Court Orders, Stipulations or Agreements. WHEREFORE, the parties intending to be legally bound thereby, and with the desire that this Agreement be entered as an Order of Court at the request of either party, hereby set their hand an~ seals and on the date first written above. - .-,--..",-., s, ,'W"'l7-,,-'>-' -""-:-~" " ~ ','- " - ~ - , -r~~"'<: ,-,- ""1liiflr: TIH'lIIIl' ~. ~~:,~~9 ~ Witness "7 / .' ~ ~_//~ Andrew E. Slike ,;, ~A ~~ Tamara J. like ~'i -",]1ll'!W"'f__~,__ ~ 0'_, -! " "'I~,~-" -~,-,;" ., - - --~ ,,"" " -" '"~~ ~ ~~ ,~^ ",'b''''",~-,~~\'~W"6';;H-';-'~;'I,",--kW_W};P ".-oi'.'5lliY>D"<~Ff'iF~j~~~f~'~"\]l:~,i~~"ijYr;(~1t)~~;J~;\;J~1:' +1 ~t ~~ P '1' ,1:; ~ P ~ ~ ~ ~v "">,." ",. cco'."',,,,., " !',__'!.~"_O',C""~-_<l',''''__'_> to'. ""'.',_ ~,'-'"'~ - . -,,,~,,,,,,~: - - ,~~_~,qrh.'qn _co' :;~!~~~.wmW'i~~J'i',>~"l!f'F0it~~i!::~;-;lt~"ft":"')-'~iijF~~~~>r;__~~~_t_'" >;__]'~td,",,_.~,_),1.,"~~~,,:_f~~;-': ANDREW E. SLIKE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN1Y, PENNSYL VANIA V. 01 c7092 CIVIL ACTION LAW TAMARA J. SLIKE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, March 02, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Thursday, April 08, 2004 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 aU existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinjl;. FOR TIlE COURT. By: Isl Melissa P. Greevy. Esq. Custody Conciliator fJ 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 TIDS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTIl 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 ;','~\~*~'[,<t1;<!>:'(l,!>_ _,~ "'_ ~ ., " ~,. '0 ~-__I ", - tll .. .~ ~, ~ -"-, ." '-'<"I"'''-''-''~-'-'''-'''''-'''~'''''~'~"'''Vd-. ,,_,,"',>>>,',"'-'C" ',j"-, <"e"trJW'rr'lie"";p~~;tFt~:~(W!});:;g ~~~~*~ .~b$~~ ~rp-~~r;; \~~j\f/iiA8NN:?d MNnOJ Ci1'."f"HJ(:W~no 8S : II ~IV f;- ~VW ~OOl J\.VI(;\IO"10.Ud ::1"1:10 I\O'-!.~vj ru Q .."n 3JI:Ho-G31l:! ,,__P_., ,1 [, )0. ['. [' /JOf:.E: he>. F.e ~ ~~~~~~~!~~'r.N"'\l'~$-"5'!I"';;~''''?'-''~''''Hin;~'FifWlli1!.l!'~ii!of;ij.'f.1'!Wr.ji'll'"',1',-,~':;)_'-'~O"o:__"~-'-_"",-""-"_'_~' \--~;)', ..,--",o-qJ;,H-'+'!i'I'iF'tg'''''':;':tr~~m:;:lll1~f.~~_ri (;'!, "" ;,', <~l~, '._ ",' ... (0 ANDREW E. SLlKE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-7092 : CIVIL ACTION - LAW : IN CUSTODY v. TAMARA J. SLlKE, Defendant ORDER OF COURT You, Respondent, have been sued in Court to modify custody of the child, Nicholas Slike. You are ordered to appear in person at on , 2004, at .m., for a Custody Conciliation 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, at the request of either attorney or party, be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent order. If you fail to appear as provided by this Order, an Order for custody may be entered against you or the Court may issue a warrant for your arrest. 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, PA 17013 (717) 249-3166 FOR THE COURT: Date: Custody Conference Officer ,." .'<_';c"'__,' ""'-'~'~"""~~"'''',''~';.="", _'__"'I""',"~,'<'_,__ .'",' __,' ,.""_,, ~_". ,.yo.--_" ___ - --. ,.. . "~'" ", --_,,'._".'0_ .'_'__"". .:1 "; ';,::i ,J ';'! '<"J[", , C' -'-'~"-,- " " ., ANDREW E. SWill, Plaintiff : IN THE COURT OP COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-7092 : CIVIL ACTION - LAW : IN CUSTODY v. TAMARAJ. SLIKE, Defendant PETITION FOR MODIFICATION OF A CUSTODY AND VISITATION ORDER 1. The Petition of Tamara J. Slike respectfully represents that on the 19th day of August, 2002, an Order of Court was entered for the custody and visitation of the minor child, Nicholas Slike, DOB 2/6/90. A true and correct copy is attached. 2. This Order should be modified because: A. The existing Order allows for an equal division of the summer holiday by alternating custody of the child every other week from Sunday at 7:00 p.m. to the folJowing Sunday at 7:00 p.m. B. Nicholas is now fourteen (14) years of age and will begin high school in the Fall term of 2004. C. Nicholas is involved in activities which are not conducive to week- long periods of visitation with his father, Andrew E. Slike. D. Nicholas has a close relationship with his older brother, who will be leaving for college in the Pall term of 2004. E. The father, Andrew E. SJike, does not have a relationship with his oldest son (Nicholas's older brother), and does not enjoy any visitation with said older son. P. Nicholas is desirous of maximizing his time in the summer with his older brother, during which period Nicholas's brother will be residing in the home of the Petitioner, Tamara J. SJike, which time will be greatly diminished should the existing Order not be modified. . ","" 'C-- :;;:.,,>,_ ,1_~,-~_~,,~,__ - -7,'''_''''_'''' '__1, ',-, ,~~1-~"*,,,"2.-_"',""'-!':~'>"'__':' ~~~-,:__ "'.',''-'; ,""'--'- ,"'-- /--'-;c-,'.""'", ."-- - - -,~~",~"" ::..,"-,,-,~ C'. , ,.-'-" _..--,'~ , . G. Nicholas has a close relationship with his older sister, who is currently a college student and living away from home during the Fall and Spring college terms. ';j ;I H. The father, Andrew E. Slike, does not have a relationship with his daughter (Nicholas's older sister), and does not enjoy any visitation with said daughter. 1. Nicholas is desirous of maximizing his time in the summer with his sister, during which period Nicholas's sister will be residing in the home of the Petitioner, Tamara J. Slike, which time will be greatly diminished should the existing Order not be modified. ~~ WHEREFORE, Petitioner requests that the Court modify the existing Order for custody and visitation because it will be in the best interest of the child, Nicholas Slike. Respectfully submitted, Dated.eW111 ~)J~ pH { klp:domestic\slike. pet '.;q~ ., ,,,"o'1~"'W'" -_Y'~___-~ f"_,,,".$",_:<~ ~~""J"<c>,,_(-,,,,", _~""_'_ _-""'''~'''''_;i''"'""'__- ," '.-'-~- .,,~ <; "~ . ',_ "," 4 ^"r]'OOOi1lll'f' . NN' VERIFICATION I, Tamara J. Slike, hereby acknowledge that I am the Petitioner in the foregoing action; that I have read the foregoing Petition for Modification of a Custody and Visitation Order; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I :'1 I >j I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ) c.,1 ~1 '- hAA~ 9. ...tt~', Tamara J. Slike/ ',I ,,1 Dated~ L~J):JJv :'i .~ >'1 '," . 0,_ ;:'J '!J.,rIE::,)lL ", ,0_, '''''''-'~'''''''"_,_,",_.,",_,''''",,,,!",~ ,<,__"<~,,,,_ """,ch.., . _.."_,,, "~,__,_"",_, . ~,,,," -f_', ~",___"_'_"''''''-'__!-''''''''"__'- "," " _ _""<",_,__'_'- ,,"-C;>J_,.-':H'C,'~'.-"''''( F', . .. - ._'~'> -- ,t,_ -J' ,ANDREW E. SLIKE, Plaintiff : IN THE COURT OF COMMON PLEAS : COUNTY, PENNSYL VANIA v. : NO. 01-7092 Civil Term T AMERA J. SLlKE, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, TO WIT, this ;q~ day of D"f'./- ,2002, it is hereby ORDERED AND DECREED that the attached Stipulation for Custody is made an Order of this Court and said Stipulation is adopted it its entirety and incorporated herein as an Order of Court. BY THE COURT: /10 LVuL; (PPh 9J J TRUE COPY FROM RECORD In T~s~lm(lny wn\lroof. I hem lr.to sm my nand anr. t:16 w! oj :;aid Cilm't at CJl'!i~, Pa. This 19t;~~a! o;f:!l/~p'..~ ,~. Protnonctarll -~ii5'\:WF'f"""~;.r _ ~ ,,1- _ , I~ ," . . ill , . ANDREW E. SLIKE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01-7092 CIVIL TERM T AMERA 1. SLIKE, : CIVIL ACTION-LAW IN CUSTODY Defendant STIPULATION WHEREAS, the parties wish to enter into an agreement relative to the legal and physical custody ofthe child, Nicholas born February 6, 1990; and WHEREAS, both parties have been provided an opportunity to review the Agreement with the counsel of their choice prior to signing; and THEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound hereby, the parties agree as follows: 1. Shared Lellal Custody: The parties agree to shared legal custody of the said minor child. The parties agree that major decisions concerning the child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall promptly notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the ';'1!~f{~~""~~...."".~i;c~L ,,~" ,^_ , - -'_'F'I~ ~, " ---, ,,"I 1-- "\f l1nT parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. Mother specifically agrees to provide F ather with all documents regarding school activities, medical conditions and treatments as well as religious concerns. Mother agrees to do so in a prompt and timely manner. Father agrees to contact the school and request that the information be sent to his home directly. Mother agrees to provide Father with all extra-curricular activities schedules and to keep him advised of any medical issues that may arise. In addition, Nicholas has engaged in CCD classes and the parents agree that he may continue the CCD classes through confirmation. Thereafter, the parties will discuss whether or not further religious education is necessary. 2. Physical Custody: Mother shall maintain primary physical custody of the minor child. Father shall have partial custody as follows: SCHOOL YEAR. a.' Father shall have custody every other weekend from Friday after school, with the school bus dropping the child at father's home, until Monday when he places the child on the school bus. If Monday is a school holiday, Father will maintain custody and place the child on the bus on Tuesday. b. One evening per week from after school, with the school bus dropping the child off at father home, until 8:00 p.m. except if child is in CCD class, then Father shall return him upon completion of the class. Father elects Wednesday until further notice to Mother. :I''''''''''_'ii-i..''''"-''''~",~ _ _<, _H'_, "~ ' ,eo' - ~~ c. Father shall be entitled to custody during every school holiday including in service days. If the school holiday is not attached to Fathers weekend, he shall have custody the day of the holiday at 10:00 a.m. until the following morning when he places the child on the school bus. 1. The request for school holidays does not include any half days that have been scheduled unless that half day falls on Father's weekend at which time the child will ride the school bus home to his father's house. 2. Father shall be present when Nicholas gets on and offthe school bus. SUMMER. The parties agree to equally divide the summer holiday by alternating custody of the child every other week from Sunday at 7:00 p.m. to the following Sunday at 7:00 p.m. The summer schedule shall begin the Sunday immediately following the last day of school and shall continue to the Sunday prior to school beginning. HOLIDAYS. The parties agree to alternate Labor Day, Memorial Day and July 4th. Said holidays shall be defined as the evening before the holiday at 7:00 p.m. through the holiday at 7:00 p.m. Mother shall have Labor Day, 2002 and the parties shall alternate thereafter. Mother's Day shall be with Mother and Father's Day shall be with Father each from 8:00 a.m. on Sunday through Monday morning at 10:00 a.m. THANKSGMNG In order to accommodate family traditions each Thanksgiving, Mother shall have custody the Wednesday prior to Thanksgiving at 3:00 p.m. through Thanksgiving Day at 3:00 p.m. Father shall have Thanksgiving Day at 3:00 p.m. until Friday at '_""'iIH;,U<'>R:Y'M"I ~~ _ ~ ~ ~_," __,~o _ _ ~,,^ ~ "" , . . 3:00 p.m. If Father's weekend falls adjacent to Thanksgiving he shall keep the child through the weekend and not engage in any exchange on Friday. CHRISTMAS. Father shall have Christmas Eve from 11 :00 a.m. until Christmas Day at 11 :00 a.m. Mother shall have Christmas Day from 11 :00 a.m. until December 26th at 11 :00 a.m. The parties agree to equally divide the remainder of the school holiday with the Father having his share consecutively at the end of the holiday for his family trip. SPRING BREAK. Mother and Father shall alternate custody of Nicholas during the school Spring Break every year, with Mother having custody during spring break 2003 and alternating thereafter. This break runs from after school the day prior to the break beginning until the morning school begins after the break. EASTER BREAK. Father and Mother shall alternate custody of Nicholas during the Easter break each year with Father having custody during Easter break in 2003 and alternating thereafter. This break runs from after school the day prior to the break beginning until the morning school begins after the break. TRANSPORT A TION. Father shall provide all transportation for the minor child under the assumption that the school bus will be able to provide transportation during the school year, at those times herein specified. It is specifically acknowledged that transportation may be provided by some of Father's family members if necessary. c,'ij1.I:l'>rl.1"'('iI"f"1"t.'''?I!Ill!'l ~<" '" .l! ,I , 'T . '~In -,_. r , . , <- { . nn} II IT .1l . . COMMUNICA TION. The parties acknowledge that they have difficulty in communicating regarding the needs of their children. Therefore, the parents agree to retain a counselor covered by the parties insurance and shall meet at least once a month, or at the discretion of the counselor, to discuss issues regarding the children. TELEPHONE CONTACT WITH CHILD. Both parties shall have the right to reasonable telephone contact with the child during the other party's period of custody/visitation. Neither party shall interfere with the other party's telephone contacts with the child nor shall they interfere with the child's telephone contact with non-custodial parent. Each party shall make all reasonable effects to promptly return telephone calls or messages left by the other party regarding the child. DISPARAGING REMARKS Neither Father nor Mother shall make any disparaging remarks regarding the other parent in the presence of the child. Such as those that might tend to alienate the affections of the child toward the other parent. Also, each parent shall inform relatives and friends to also refrain from making any disparaging remarks regarding either parent in the presence of the child. SUPERCEDES OF PRIOR COURT ORDER. This Stipulation shall be entered as a court order. This Stipulation shall supersede all prior Court Orders, Stipulations or Agreements. WHEREFORE, the parties intending to be legally bound thereby, and with the desire that this Agreement be entered as an Order of Court at the request of either party, hereby set their hand and seals and on the date first written above. ~"Jl-'[,,,,,,,,.J;,.',m""'l:< ~." <. ~. "'~-'" - <" ~ ". ~I" ,. "~ "~ I g .,"""",-","1l,~""'~"'""",~", " /Z-L-----<c J~ Andrew E. Slike ,_~--<, ~. ~d(' Tamara J. like "',,~ ,~ ~ - ~ ~ ~- ~ , v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-7092 : CIVIL ACTION - LAW : IN CUSTODY ANDREW E. SLlKE, Plaintiff TAMARA J. SLIKE, Defendant CERTIFICATE OF SERVICE I, John F. King, Esquire, hereby certify that on February 11-,2004, I served a copy of the within Petition for Modification of a Custody and Visitation Order, by depositing same in the United States Mail, first class, postage prepaid, addressed as follows: Debra Denison Cantor, Esquire Reager & Adler, P. C. 2331 Market Street Camp Hill, PA 17011-4642 17108 \G~W._,__~;~,- -.fe', ":_ ~ ,;' -"0.,-, "'7." ,,?', ~, _~_".- ""F'~ .N_~ _'" "',_I~.'", ,,' _ _ "u _';'"''.!-''_'''~'~'";'_"o/~'_'''__''''__ _,__~ .-' "V_~'''::-- ","""_,' " '_'_~" '~~'_,~__I" _ , "~_.,. ""c,' '.,,..,' '. . ,,"M' - "'-"_' ~, ,', _~,-"-- _ L ,- Ijj ~="c"',=' ""W""',,,,=",,',,,.~,,,"",U"''''''''""".' ", ""'~_\ ,_,_,> ,_'r. "_,!:A",,.""'__' , . _o~'II.iJl~J n, ',-,', '-' ~~'h-"'" ',c_ ~~J o () v -p-- ~ -L. ~ ~ ~ -- "'Q ...l:: ....0 ../:;}" '" " 'Q:X', ^, ' o -"';'ftiL'fb' """--'C__,'@tii~~, fr1R~~ 1_ ~~tf!;q~~""'T"::-' ~__ _ , : .~?~~~~~- -, "., -, ~'-:'.., , <~~' \-~;,~::1't;~n~tet~';~~L;rft "'''~~~ft~';:;.,!};~~,~i':Z C) "" ~ 0 c-: c.~~ ~,-. 'n -'OJ --. 1~;.1 :J::" -n ccy r ,'''! 10':.:: r',,) -'''l I;-! :i) C', -$.:'- r' " ?:J c, -0 " :~~) - -.-_. - . ~--; , " ~ Z'-:I C) " c' ",,' " __', ,;_" -~~j ~~_,",I'l.~J,j'ilt{ j ".!'i;\--f:;i llH 't'..-' ........ APR 3 0 2004 ,{ 0 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-7092 CIVIL TERM ANDREW E. SLlKE, v. CIVIL ACTION - LAW TAMARA J. SLlKE, IN CUSTODY Defendant ORDER OF COURT ~ Ii rV/?1 AND NOW, this .s day of..,A;prtl, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. This Court's Order of August 19, 2002 shall remain in full force and effect except as modified below: A. With regard to physical custody in the summer, if during Mother's week, Father is off on Tuesdays and Nicholas would otherwise be alone at Mother's home, Father may have custody for that day and will provide transportation both ways. B. Mother may have custody up to three days a week when Father is working. However, Father shall have three weeks reserved for vacation during the summer school recess. The parties will provide dates and details of their planned vacation time when they become available. C. There will be a call between the parents one time a week or a weekly note to finalize the summer schedule in light of when all three of the parties' children may be available to spend time with each other. D. Summer Transportation Arrangement: Transportation to drop off Nicholas in the morning shall be provided by Mother on Mondays and Wednesdays and Father on Thursdays and Fridays. Transportation to pick up Nicholas in the afternoons shall be provided by Father on Mondays and Wednesdays and Mother on Thursdays and Fridays. ;~ffi!Iil.."'-~ _ ~ ,,"~ , <n,l. ~~~_,_, _ .. v. . ,. "~~ ,,,..,..,' -'~" -'.. ...-~, .' '?~~'-'] r J.II!!JU "' -.' -~ NO. 01-7092 CIVIL TERM E. Each party will contact Bonnie Howard, or another covered provider, by April 16, 2004, to resume co-parent counseling as previously directed and agreed upon in the Stipulation which serves as the basis of the August 19, 2002 Order. Each party will pay the co-payor unreimbursed costs for their individual visits with the therapist. Co-pays for joint sessions shall be shared between the parties on a pro- rata/net basis. Joint sessions are not expected to occur more than once a month. BY THE COURT: J. Dis!: .;6ebra D. Cantor, Esquire, 2331 Market Street. Camp Hill. PA 17011 "John F. King, Esquire. 600 North Second Street, Harrisburg. PA 17101 '1.-' ",,'<'.00__">-""0><,>""""'"'''''''' '"~, __7'<' ~- ,-_,~"I' 7'~'''''''' ,-- ~- - ',~~ ill -" ~" co,_ ,- "'c -,~."~ ., - """I' ~ ". - <'0.,'" "'\,., -<.'b"~~" ~f('C't';ir~~f~\f:if':nj"'I'" vir:"n~-"~>>'_~'Y-:5{ ~'~"f,~~~_"f)~ ....' 'Jf r ~C ..( '" J' ~ jr '<.._,~'!,~, "0"...> "",,,,,,,.,,,~,,,,,,,.. ''''',_<~", ,,111 ~.'> ~ ,'.,"-,V_' ,'i"''''-,' __~;.' .,~_", ,'-,,-~' -. _ .,Jl~!!lI:!l.-~,~~. ,_~ , ."";, _~.,~. ~~~l"WIl!*lf~~~~~ _.~,.Jr _"_ v,""" ~ f" ,;,~_,_"_ - ~lU._~ .!ill :,,~-_'" '-";",m:vg",,- ,~ . ANDREW E. SLlKE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-7092 CIVIL TERM Plaintiff v. CIVIL ACTION - LAW TAMARA J. SLlKE, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Nicholas Slike Mother February 6. 1990 2. A Custody Conciliation Conference was held on April 8, 2004 with the following individuals in attendance: Andrew E. Slike, and his counsel, Debra D. Cantor, Esquire; the Mother, Tamara J. Slike, and her counsel, John F. King, Esquire. The Conciliation Conference was convened in response to Mother's Petition to Modify Custody filed on February 24, 2004. 3. The parties reached an agreement in the form of an Order as attached. ~ 1~/Df Date Melissa Peel Greevy, Esquire Custody Conciliator .' .< '-. ".-, ., . ~, =-""",," ~~ ~ , " o "~" _ "~ "