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HomeMy WebLinkAbout99-02601 ~, .\ . . ""r, I,'. " '., "":."','.', ',.:":,, ':I::~';:'I;~":~'l~::':~l'~~~<("';~;'."'::~~;:'~'~~:':,~:~~r~'",:~:.:< \,'.";':-,'.,;..,::'.' \. I"";'-'~ '. , .1' .'\ \,'1,' : '\'.:. '., I. ':/~ 1-,' ., . " .. ,': '~ ,', ,. ,". ""'.r '" ~, '--. r r) ..,'.... II.;", ~,'~/ (;,/.':. I " , i /: ') J~' '~ "\J' ..I'i,'..,;, " I . '.:,' . ,\ :.' :;', :",':. '::,,:-:';: '..,;. =;, :,\:,','0:':;"7":'::'::~',:,:,:,;~,::~~.,~;~L ::::,'{.::'::,::' :;,~.:':;>. ': ......, .: .:: "".:":' '.'" . ',:;.~': ',' '<..: :'.;: n, " ',' '., KEITH P. ARNEIT, JR. Plaintiff/Petitioner : IN THE COURT OF COMMON : PLEAS, CUMBERLAND COUNTY, : PENNSYLVANIA v. JOHN GROSS & SHERRY GROSS; PARENTS AND GUARDIAN OF JENNIFER M. GROSS, Defendant/RespoRdeRt : CIVIL ACTION - LAW : CUSTODY NO. 2601-99 : CERTlFICA TE OF SERVICE 1 hereby certifY that the foregoing Petition in the above captioned matter was served upon the following by United States First Class Mail: Elizabeth Antoun, Esquire 1941 Market Street Harrisburg, Pa 17103 Date: 7 /;;','3/q ~ Respectfully Submitted by: ~j'1)~ Michaell Pyk Attorney LD. 5885] P.O. Box 368 Camp HiII, Pa 17001-0368 (7] 7)975-9446 Attorney for Plaintitr/Pctitioncr ; ,":.:' l,:'/:" \~: : L~:: , ..:> '~:~".i ~ ,\ .', ", "':~'(' <,~,\ ~';':::'~;i::;;J;:;~li~' ,~.~~,.':':: ':: ,:~~~~":~,il~.~;~;>,('I( '.~ :"~'Y,<:-,\ '~~; ~~ '<;.:, I: ,.' , ': \ '1,1: \ ,~" " .~)~ /': ", ", ': :.' ~, " ~' ' " '" " -,- (,;-. (..l -.. " :~ I." (~' " '(,')'" t::.,' ~'l\ t1-. . , \,1 C C"\ \." ,~. .-~'\ C' \ . ?" .- , '.J CA-lf (zvvt O{~ - . "\ . . . '~ /". '\:> 'V. '\ ." ::'.~ .......~~ ,. ~ "'OJ ,..~ ~~'~ ,\\ ,/,~) ",.,- ~\)'" .' : IN THE COURT OF COMMON PL S, /" : CUMBERLAND COUNTY, PENNSYLVANIA : ~~ : CIVIL ACTION-LAW KEITH P. ARNETT, JR. Plaintiff v. JOHN GROSS and SHERRY GROSS AS PARENTS and GUARDIAN OF JENNIFER M. GROSS, Defendant : CUSTODY NO. 2601-99 CUSTODY VISITATION AND STIPULATION AGREEMENT THIS AGREEMENT, made this .JLdsy of ~r Ct ( ~ ' 1999, between Plaintiff, Keith Arnett, Jr. (hereinafter referred to as "Father"), and De endant, John Gross and Sherry Gross as Parents and parents and Guardian of Jennifer Gross, (hereinafter referred to as "Mother"), concerns the custody of the parties' child, DRA VEN B, ARNETT (D.O.B. 05115/98), (hereinafter referred to as "child"). WHEREAS, a Custody Complaint was filed on May 3, 1999. The patties have reached an agreement with the best regard to the best interests and welfare of their minor child. WHEREAS, Father and Mother desire to enter into a Stipulation and Agreement as to the custody of the child and to have this Stipulation and Agreement made an Order of Court. WHEREAS, in entering this Agreement, the parties have had the benefit of counsel as follows: Michael J. Pykosh, Esquire for Father and Elizabeth S. Antoun, Esquire for Mother. NOW THEREFORE, Father and Mother agree to the following: I. The parties shall have shared legal custody of the subject minor child. They shall regularly consult with each other relative to all important decisions regarding the minor child. including such maIlers as health, education, and religion. Further. each of the parties is specifically emp,)wered to authorize medical care for the minor child, and discuss the child's development with both medical caregivers, and educators. 2. The mother and fathcr shall provide the nanles, addresses, and phone numbers upon request of caretakers providing services for said child. 3. The Mother shall have primary physical custody of the minor child. 4. The Father shall have Partial Custody with the following visitation schedule: a. Every other weekend beginnin.g 6PM Friday evening and ending 6P1'v( Sunday evening with times changed only by mutual agreemcnt of Father and Mother. b. Every other holiday. 10f2 ..'!\~~\ . . .,," -..; ........) '" '\i /1., \,:.' ..,~ ""~ "'~~. c. One evening/day through the week as can be mutually agreed upon with Fa~~cl)\YerM'-:; ./" \ ~ .. schedule. ' 'S ./' /' 5. During any period of custody or visitation the parties to this Order shall not possess or u~~ any controlled substance. If there is any suspicion that either of the parties are possessing or using a controlled substance, authorities shall be notified immediately. Use of alcohol to the point of intoxication is prohibited while exercising custodial rights. 6. Both parents shall refrain from making derogatory comments about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child whether "sleeping" or "awake". WHEREAS, the parties' agree that for purposes ofincome raxes. the Mother shall be permitted to claim the parties' child and one halfofthe day care that she has paid as a deduction commencing in tax year 1999. WHEREAS, the parties agree that for purposes of income taxes, the Father shall be permitted to claim one half of the day care he has paid for as a deduction commencing in tax year 1999. WHEREAS, this Agreement and Order shall be construed in accordance with the laws of the Commonwealth ofPelIDsylvania. WHEREAS, the Parties agree to be legally bound by the terms of this Agreement. 74f-~f ;? .-' 'b .--/ '- ~'iI~~~V 1enni~ r M. ross: Mother ~b .d / J'}-J/l(/'''''''/ J Gross. Parent and Guardian of Jennifer Gross ~~.t~.~rKfl SheITy Gros amn and Guardian of Jennifer Gross 200 i 1;0 c-( >- en G V:l~ - 0; ~ ':::2 ~:-: .. ~;.=: \ ~ G ("') - :J..:r ~ B 8 ~ ~-'-, ~:5 ~~ 8 'o- x. -=<" R=~-; C4.. ~f :~J ;-..::s ,~ v) Uj ~ ~ & c. . . in '-'j"- <":l 1--' [i; ~~ cr: 7ieb t"- o_ ~.,~~ ;.1.. """ 1>J.. I.L m =3 0 CI\ 0 ,JUL 2 3 19~ KEITH P. ARNETT, JR., Plaintiff vs. ) ) ) ) ) ) ) ) ) NO. 99-2601 CIVIL TERM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN GROSS and SHERRY GROSS as parents and guardian of JENNIFER M. GROSS, Defendants ORDER AND NOW this J IS" day of 4- ' 1999, it being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, MICHAEL L. BAN J . Custody Conciliat cc: Michacl J. Pykosh, Esquire Elizabeth S. Antoun. Esquire , . .' .;.. .;..' " !, ;,; , \ ", .!~ ..... ';'''.' " ""t::~~' i~ ">,',';;L';t"'''~,,. :'~''''';~~'':~ ~~~, .)':'~; ~ >' ,i, .!: ",:,: r ~!, ':. ,co' .',:\,' .' ~~".' ."'. F , , .,.1 <... ,.1. ", .', :>J 1,. ') ':.) r.'- 0: ('Tn l" I. ~ ' .' CIII':'" . , ,....I!...... ._ . "-' PEN;'~,:<'{i:'"!/": ":.' ':i,l ,,""t C' I:' I. ....,.) .l. f.':' J.'..r;Y '.. , , KEITH P. ARNETT, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W JOHN GROSS and SHERRY GROSS, as parents and GUARDIAN OF JENNIFER M. GROSS, Defendant NO. 99-260 I CIVIL TERM ORDER OF COURT AND NOW, this 30th day of March, 2001, upon relation of Michael Hynum, Esq., attorney for Defendants, that he is withdrawing Defendants' Emergency Petition for Special Relief in Custody, the hearing scheduled in this matter for March 26, 2001, is cancelled. BY THE COURT, " / ,I, t' i 4 .',. /' 1-1 J/ J. Wesley OICf:)~, Michael Hynum, Esq. CAPOZZI AND ASSOCIATES. P.C. 2933 North Front Street I !arrisburg. I' A 171 J 0 Attorney lor Defendants ~,\ Y fl.,b,D ~p~ r)?"' ~ (-'J '0- ( ---. -- f . . .! " " .' c) , , :.) c " : , :-~') -- , (11 Keith P. Arnett, Jr. 225 Church Road Lewisberry, PA 17339 Plaintiff, Pro Se v :rc '>- (':0 i-:.: "" , , .. , ." , ~.:.J ',:":l ,. (" . . ,d '- L. ::j "- C.J (.:J , APR 0 92001{,O JOHN GROSS AND SHERRY GROSS, AS PARENTS AND GUARDIAN OF JENNIFER M. GROSS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. NO. 99-2601 KEITH P. ARNETT, JR., CIVIL ACTION - LAW CUSTODY Defendant ORDER OF COURT AND NOW, this 30th day of March, 2001, thirty days now having passed since the request for continuance made by counsel for the Plaintiffs and the Conciliator having received no request for an additional Custody Conciliation Conference, the Conciliator hereby relinquishes jurisdiction of this matter. FOR THE COURT, ~:i'"P''' Gree'Y'~ Custody Conciliator J - -' : ~ !., :.) ; '..}l....' .' : {'~. 1"-""\' . . ):'.1 I eli,.:,:.......,.....;;:... i's>t".) {L\/... ~-OJI.(j1 W~ ~Je/ <6 4~ t,C:;h:l/ ~ /"A~/:6 5 ~ tf-cll-c?1' /1,... -.~.;:It 4 ~/hh ~7? /I/f~~ ".? - ~ KEITH P. ARNETT. JR. Plaintiff v. : IN THE COURT OF COMMON PLEAS. : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW JOlIN GROSS and SHERRY GROSS AS PARENTS and GUARDIAN OF JENNIFER M. GROSS. Defendant : CUSTODY NO. :2601-99 CUSTODY VISITATION AND STIPULATION AGUEEMENT THIS AGR[EMEl'!T, m:ldc this .i.~ay of .j.1I i~ ' 1999, between Plaintiff: Keith Arnett. Jr. (hereinalier referred to as "Father"), and D fendant. John Gross and Sherry Gross as Parents and parents and Guardian of Jennifer Gross, (hereinafter referred to as "Mother"), concerns the custody of the panics' child, DRA VEN B. ARNETT (0.0.8. 05/15/98). (hereinafter referred to as "child"). WHEREAS. a Custody Complaint was filed on May 3.1999. The panics have reached an agreement with the best regard to the best interests and welfare of their minor child. WHEREAS, Father and Mother desire to enter into a Stipulation and Agreement as to the custody of the child and to have this Stipulation and Agreement made an Order of Court. WHEREAS. in entering this Agreement. the panics have had the benefit of counsel as follows: Michael J. Pykosh. Esquire for Father and Elizabeth S. Antoun. Esquire for Mother. NOW THEREFORE, Father and Mother agree to the following: 1. The panics shall have shared legal custody of the subject minor child. They shall regularly consult with each other relative to all important decisions regarding the minor child. including such malleI'S as health, education. and religion. Further. each of the panics is specifically empower<:d to authorize medical can~ f()r the minor child. and discuss the ehild's development with both medical caregivers. and educators. :2. The mother and fathC't shall provide the names. addresses. and phone numbers upon request of caretakers providing services for said child. 3. The Mother shall have primary physical custody of the minor child. 4. The Father shalllmve Partial Cusl<ldy with the following visitation scheduh:: a. Every other \\'eekend beginning 61'M Friday evening and ending 6PM Sunday evening with times changed Hnly hy -;nutual agreement of Falher and Mother. b. Evcry other holiday. Illf:! '", '- l"') C- '-T'- --/. "---.. ." c; '.1 '" I "'; >.,...... ct) .-' ;; -,-. ), :i... I.l.. ':::-i !t ( ; ,. 'J :') -j~< ~ ~ 1'-.::: ~ :;J " ~ <L.l --'J !L_ 8 ~ '. .. ~3 ........ , ' '.." .....-:l U . ~ ~ 1J ~ r::L Plaintiff AUr, 0 220m&, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ,., KEITH P. ARNETT, JR., vs. NO. 99-2601 JOHN GROSS AND SHERRY M. GROSS, : AS PARENTS AND GUARDIANS OF JENNIFER M. GROSS, CIVIL ACTION - LAW CUSTODY Defendants ORDER OF COURT Oler, J.- AND NOW, this '-; J. day of August, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Keith P. Arnett, Jr., and Jennifer M. Gross, shall have shared legal custody of the minor Child, Draven B. Arnett, born May 15, 1998. 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 his health, education and religion. Pursuant to the terms of Pa. C. S. ~ 5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child 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. Mother shall have primary physical custody subject to Father's schedule of visitation which shall be arranged as follows: A. Counsel for the parties shall choose a neutral site for supervised visitation by selecting either the Children's Playroom, Inner Works, or the Carlisle branch of the YWCA. B. Father shall have supervised visitation on the first, second and fourth Saturday of each month. The period of visitation shall be from 9:00 a.m. until 12:00 Noon unless the site for supervision of visits limits the time by agency policy. Father's first visit may begin August 4, 2001. C. The arrangements for supervised visitation shall continue for a period of not less than three months and shall continue pending Father's sentencing by York County Court of Common Pleas. No. 99-2601 D. Father shall bear the costs associated with his supervised visits. In the event that Father is unable to attend a scheduled supervised visit, Father shall notify the Mother and the provider of the supervision. In the event that Father has not arrived by 9:15 a.m. on the day of any given visit, Mother may leave with the Child without any additional wait. 3. The Custody Conciliation Conference shall reconvene on November 5, 2001, at 9:15 a.m. at the office of the Conciliator, Melissa Peel Greevy, Esquire, 214 Senate Avenue, Suite 105, Camp Hill, PA 17011. Counsel for the Father may request a Continuance until after sentencing in the event that sentencing has not occurred by the November 2001 Conference date. 4. Both parents shall establish a no-conflict zone for their children. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. 5. During any period of custody or visitation the parties to this Order shall not possess or use controlled substances, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. 6. The parties are prohibited from discussing their differences and this Custody litigation in the presence or earshot of the minor Child. BY THE COURT, (, . Cist: Michael A. Hynum, Esquire, 2933 N. Front Street. Harrisburg. PA 17110 f MichaelJ. Pykosh. Esquire, 3805 Market Street, Camp Hill, PA 17011 &F' //1,,-,,;.1u4, . J -0/ /'-- \ I - t-. .