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Home My WebLink About99-01946 ~ { \, \) :f ~ ~ '" '\ \ \ \ ) , /. / ;' / LAW OFFICES SNELBAKER. BRENNEMAN 6: SPARE CAROLANN ZEIDERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 9')-/9'1(. CIVIL TERM v. BRAD LEE ROTHERMEL, Defendant CUSTODY OF MINOR CHILD COMPLAINT FOR CUSTODY OF MINOR CHILD AND NOW, comes the Plaintiff, Carolann Zeiders, by her attorneys, Snelbaker, Brenneman & Spare, p, C" and avers the fallowing: 1, Plaintiff is Carolann Zeiders residing a 5608 Locust Lane, Harrisburg, Dauphin County, Pennsylvania, 2. Defendant is Brad Lee Rothermel residing at 1942A Fry Loop Avenue, Carlisle, Cumberland county, Pennsylvania, 3, Plaintiff seeks custody of the following child: NAME PRESENT RESIDENCE AGE 9 Brittany Ann Rothermel 5608 Locust Lane Harrisburg, Pennsylvania The child was not born out of wedlock, The child is presently in the custody of Carolann Zeiders who resides at 5608 Locust Lane, Harrisburg, Pennsylvania, 4. During the last five (5) years, the child has resided CAROLANN ZEIDERS, . . IN THE: CXlURT OF CXXoIMCtl PLEAS OF CUMBERLAND ~, PENNSYLVANIA Plaintiff . . vs. : NO. 99-1946 CIVIL TERM BRAD LEE RCIl'HERMEL, Defendant CIVIL ACTION - LAW : CUSTODY ClUJER OF CXXlRT AND K:JoI, this /I ,. day of I'l?Er consideration of the attached Custody Conciliat on Report, and directed as follows: , 1999, upon it is ordered 1. ihe Mother, Carolann Zeiders and the Father, Brad Lee Rothermel, shall have shared legal custody of Brittany A. Rothermel, born Septerrber 8, 19B9. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. In the event of serious illness of the Child at any time, the custodial parent shall notify the other parent inmecliately, informing the other parent of the nature of the illness. During such illness, both parties shall have the right to visit the Child as often as he or she desires consistent with the proper medical care of the Child. The word illness, for the purpose of this order, shall mean any disability which confines the Child to bed under the direction of a licensed physician. 2. ihe Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child on alternating weekends from Friday at 6:00 p.m. through Sunday at 8:30 p.m. The Father shall pick up the Child at the Mother I s residence unless the Mother notifies the Father in advance that the Child will be at day care, in which case the Father shall pick up the Child at the day care provider I s residence. In addition, the Father shall have custody of the Child every Tuesday from 4:00 p.m. until 8:30 p.m. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. CBRISTMAS/l~ YEARS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon until Christmas Day at 12:00 noon, and Segment B, which shall run from Christmas Day at 12:00 noon until December 26 at 12:00 noon. The Father shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. In every year, the Father shall have custody of the Child from December 26 at 12:00 noon through New Years Day at 2:00 p.m. The Mother shall have custody of the Child in every year from New Years Day at 2:00 p,m. through the day on which school resumes. B. TllANKSGIVING: The Thanksgiving holiday shall run from the Wednesday before Thanksgiving at 6:00 p.m. through the Sunday after Thanksgiving at 8:30 p.m. The Father shall have custody of the Child over the Thanksgiving holiday in odd numbered years and the Mother shall have custody of the Child over the Thanksgiving holiday in even numbered years. C. EASTER: The Easter holiday shall run from the Thursday before Easter at 6:00 p.m. through Easter Sunday at 8:30 p.m. The Father shall have custody of the Child over the Easter holiday in odd numbered years and the Mother shall have custody of the Child over the Easter holiday in even numbered years. D. MIlIDW\L DAY/LA!lClt DAY: The Memorial and Labor Day holidays shall run from the Friday before the holiday at 6:00 p.m. through the Monday holiday at 8:30 p.m. The Father shall have custody of the Child over the Memorial Day holiday in even numbered years and over the Labor Day holiday in odd numbered years. The Mother shall have custody of the Child over the Memorial Day holiday in odd numbered years and over the Labor Day holiday in even numbered years. E. MOl'IIER'S DAY/FATHER'S DAY: The Father shall have custody of the Child every year on Father's Day from 10:00 a.m. until 8:30 p.m. and the Mother shall have custody of the Child every year on Mother's Day from 10:00 a,m. until 8:30 p.m. F. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. Each party shall be entitled to have custody of the Child each year for two non-consecutive weeks upon providing 60 days advance written notice to the other party. Vacation custody arrangements under this provision shall not be scheduled to interfere with the other party's holiday period of custody unless otherldse agreed by the parties. The parties agree that the Father shall have custody of the Child from July 2, 1999 through July 11, 1999 and the Mother shall have custody of the Child from June II, 1999 through June 19, 1999 in accordance with this provision. 6. The parties agree to modify the alternating weekend custody schedule to exchange certain weekends during the summer of 1999 so that the Mother shall have custody of the Child from July 23 through July 25 and the Father shall have custody of the Child from August 13 through August 15. 7. The Father shall be responsible to provide transportation for all exchanges of custody under this order unless otherwise agreed by the parties. 8. This order is entered pursuant to the agreement of the parties at ;~j ~~e-03: .... ~::l~ .... .., s .... ~ !~~I .., ~~ ... on ,CJtsEl c ,g~.au~ .... ~!~~~ III ' .. 5~~~- '..... . rj.... ffi'" ~ j2! ~I . =.:. ~~ <i\ '" ';; . Q 1Oi,gi i::a ~ ~i~~ ... :c 6J ~ ~ == fW _.0 N = E <II <II I a.a~~'~ l:J 8 iiim91~il ~~~ .., ::a ~ " MAY