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PAMELA L. HAMILTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99-3206 CIVIL TERM
THOMAS A. HAMILTON, CIVIL ACTION - LAW
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this cu day of v?h 2000, upon
consideration of the attached Custody Conciliation Report, it , is ordered
and directed as follows:
1. The parties shall submit themselves and their minor children to a
custody evaluation to be performed by an evaluator selected by agreement of
the parties and counsel. The purpose of the evaluation shall be to obtain
independent professional recommendations concerning ongoing custody
arrangements which will best serve the interests of the Children and also
to obtain interim recommendations with respect to the oldest Child's
compliance with the temporary custody arrangements set forth in this Order
as well as the ongoing custody schedule. The parties shall sign all
authorizations deemed necessary by the evaluator in order to obtain
additional information pertaining to the parties or the children. The
parties shall equally share all costs of the evaluation and agree to effect
a partial distribution of $2,000.00 to each party, from the parties' joint
Legg-Mason Account, from which the parties may pay the costs of the
evaluation.
2. The parties shall have custody of the Children in accordance with
this temporary order pending completion of the custody evaluation and
further Order of Court and agreement of the parties.
3. The Mother, Pamela L. Hamilton, and the Father, Thomas A.
Hamilton, shall have shared legal custody of Sarah E. Hamilton, born June
8, 1988, David T. Hamilton, born April 30, 1990, and Kristen R. Hamilton,
born July 6, 1995. Each parent shall have an equal right, to be exercised
jointly with the other parent, to make all major non-emergency decisions
affecting the Children's general well-being including, but not limited to,
all decisions regarding their health, education and religion.
The Mother shall have primary physical custody of the Children.
5. The Father shall have partial physical custody of the Children on
alternating weekends from Friday at 5:00 p.m. through Sunday at 9:00 a.m.
and on Sunday from 12:30 p.m. through 6:00 p.m. In addition, the Father
shall have custody of the Children on the interim Sundays from 12:30 p.m.
until 4:30 p.m. The Father shall have custody of the Children every
Tuesday evening from 5:00 p.m. until 8:00 p.m. and, during weeks following
the Mother's periods of weekend custody, the Father shall also have custody
of the Children on Friday from 5:00 p.m. until 9:00 p.m. The parties
acknowledge that the Father's agreement to the Mother having custody of the
4
Children every Sunday for church is temporary, pending receipt of the
evaluator's recommendations and is made without prejudice to the Father's
position on custody after completion of the evaluation.
6. The Mother shall have custody of the Children for the entire
Thanksgiving school vacation in 2000.
7. In 2000, the Father shall have custody of the Children from the
Friday before Christmas until New Years Eve with the specific exchange
times to be arranged by agreement of the parties.
8. The Mother shall cooperate in encouraging the Children,
particularly the parties' oldest Child, to spend all periods of partial
custody designated in this order with the Father.
9. The Children shall not be left alone in the company of their
maternal grandmother, Muriel Berry.
10. Upon completion of the custody evaluation and in the event the
parties are not at that time able to reach an agreement as to ongoing
custody arrangements for the Children, counsel for either party may contact
the Conciliator within sixty days of receipt of the evaluator's
recommendations to schedule an additional Custody Conciliation Conference.
BY THE COURT,
J.
1o-OZ-00
cc: Marcus A. McKnight, III, Esquire - Counsel for Mother RKS
John H. Broujos, Esquire - Counsel for Father
4
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PAMELA L. HAMILTON,
Plaintiff
VS.
THOMAS A. HAMILTON,
Defendant
PRIOR JUDO: Kevin A. Hess
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3206 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CML PROCEDURE
1915.3-81 the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME DATE OF BIRTH CURREN'T'LY IN CUSTODY OF
Sarah E. Hamilton June 81 1988 Mother
David T. Hamilton April 30, 1990 Mother
Kristen R. Hamilton July 7, 1995 Mother
2. A Conciliation Conference was held on October 12, 2000, with the
following individuals in attendance: The Mother, Pamela L. Hamilton, with
her counsel, Marcus A. McKnight, III, Esquire, and the Father, Thomas A.
Hamilton, with his counsel, John H. Broujos, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
- 00y6e4 14 2! Date Dawn S. Sunday, Esquire
Custody Conciliator
PAMELA L. HAMILTON 1N'f1IE COURT OF COMMON PLEAS OF
PLAIN'T'IFF CUMBERLAND COUNI'Y, PENNSYLVANIA
V.
THOMAS A. HAMILTON
DEFENDANT 99-3206 CIVIL ACTION LAW
IN CUSTODY
DROER OF COURT
AND NOW, this 30TH day of AUGUST , 2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at __ 39 West Main Street, Mechanicsburg, PA 17055 on the 27TH day ofEPTEMBE , 2000, at 1:00 P.M
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
By: /s/ Da Q n .. rtndav _&q e
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
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PAMELA L. HAMILTON,
Plaintiff
v
THOMAS A. HAMILTON,
Defendant
AND NOW, this
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3206 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
COURT ORDER
day of August
2000, upon
consideration of the attached petition, it is hereby directed that the parties and their
respective counsel appear before Dawn S. Sunday, Esquire, the conciliator at 39 West
Main Street, Mechanicsburg, Pennsylvania on the day of
2000 at _.M. for a Pre-Hearing 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 also be
present at the conference. Failure to appear at this conference may provide grounds for
entry of a temporary or permanent order.
By the Court,
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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
1-800-990-9108
PAMELA L. HAMILTON,
Plaintiff
v
THOMAS A. HAMILTON,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3206 CIVIL TERM
: CIVIL ACTION - LAW
: IN CUSTODY
PETITION FOR CUSTODY
Petitioner, Thomas A. Hamilton, by his attorneys, Broujos 8r Gilroy, P.C., sets forth the
following:
Petitioner, Thomas A. Hamilton, is an adult individual residing at 847 West North Street,
Carlisle, Cumberland County, Pennsylvania.
2
Respondent, Pamela L. Hamilton, is an adult individual residing at 735 West Louther
Street, Carlisle, Cumberland County, Pennsylvania.
3
Respondent initially filed the above referenced action in the nature of a custody
complaint. The case was originally assigned to Dawn S. Sunday as Custody Conciliator.
The parties reached an agreement and the Conciliator relinquished jurisdiction.
4
Petitioner avers that a Custody Order must be put in place in order to promote the health
and welfare of the minor children and in order to ensure that Petitioner has meaningful
visitation with the minor children.
5
Petitioner and Respondent are the natural parents of three children, Sarah E. Hamilton,
born June 8, 1988; David T. Hamilton, born April 30, 1990; and Kristen R. Hamilton,
born July 6, 1995.
6
Petitioner requests that a Custody Order be set up along the following terms:
A. Mother and Father would share legal custody of the minor children.
B. Mother would enjoy primary physical custody of the minor children.
C. Father would enjoy periods of temporary custody of the minor children to
include alternating weekends from Friday at 5:00 p.m. until Monday
morning, every Friday evening until 9:00 p.m. on the weekends the Father
does not have custody, and every Tuesday evening until 9:00 p.m. Plus
such other times as agreed upon by the parties and a standard schedule
addressing holidays and vacation.
D. Father also requests that a custody evaluation be performed to address a
number of issues including an existing problem whereby Sarah has indicated
a reluctance to visit with the Father.
WHEREFORE, Petitioner requests your Honorable Court to refer this matter to a Custody
Conciliator for the scheduling of a conference.
Respectfully submitted,
A` tc rney for Petitioner
Broujos & Gilroy, P.C.
4 North Hanover Street
Carlisle, PA 17013
(717) 243-4574
I verify that the statements made in the foregoing document are true and correct. I understand that
false statements herein are made subject to the penalties of 18 PA. C.S. Section 4904 relating to
unsworn falsification to authorities.
DATE: aooD / ../L- , ?Z1L
Thomas A. Hamilton
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AUG 1 9 1999
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PAMELA L. HAMILTON, : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
: NO. 99-3206
THOMAS A. HAMILTON,
Respondent, IN CUSTODY
ORDER OF OOURT
AND NOW, this 17th day of August, 1999, the Conciliator, having
received no contact from counsel for either party rescheduling the Custody
Conciliation Conference canceled for July B, 1999, hereby relinquishes
jurisdiction in this case.
FOR THE COURT,
Dawn S. Sunday, Esquire
Custody Conciliator
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MAY 2 7 1999
PAMELA L. HAMILTON, : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
99 MO(p
THOMAS A. HAMILTON, CIVIL TERM
Respondent IN CUSTODY
ORDER OF COURT
AND NOW, this JCS day of n ,-r rp . 1999' , upon consideration of the attached
petition, it is hereby directed that the parties and their respective counsel appear before
?r Ctt t`I Esquire, the conciliator, at 3c? W .1-'(Ctt (1 on the
_$ day of' 1- 1992 at 1 A. M. for aPre-Hearing Custody Co .rence. At such
conference, an effortde 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 this conference may provide
grounds for entry of a temporary or permanent order.
By the Court,
Custody Conciliator t 7,D
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
1-800-990-9108
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AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having
business before the court, please contact our office. All arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
2
PAMELA L. HAMILTON,
Petitioner
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
THOMAS A. HAMILTON, CIVIL TERM y 9 3-U Tu--
Respondent IN CUSTODY
PETITION FOR CUSTODY
AND NOW, this 26th day of May, 1999, comes the Petitioner, Pamela L. Hamilton, by
her attorneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody.
1.
The Petitioner is Pamela L. Hamilton, an adult individual residing at 735 West Louther
Street, Carlisle, Cumberland County, Pennsylvania 17013.
2.
The Respondent is Thomas A. Hamilton, an adult individual residing 735 West Louther
Street, Carlisle, Cumberland County, Pennsylvania, 17013.
3.
The parties are the natural parents of three minor children, namely, Sarah E. Hamilton,
born dune 8, 1988, age 10; David T. Hamilton, born April 30, 1990, age 9; and Kristen R.
Hamilton, born duly 6, 1995, age 3.
4.
The parties were residents of the Commonwealth of Pennsylvania since 1981.
3
5.
The parties anticipate separation in the very near future.
6.
The petitioner has been the primary caregiver for the children and it is in their best
interest that she be granted primary physical custody of the children with partial custody to the
respondent as the parties agree is in the children's best interest.
7.
The best interest of the children require that the Court grant the request of the petitioner
as set forth above.
WHEREFORE, Petitioner respectfully seeks primary physical custody of the children
with partial custody to the respondent as the parties agree is in the best interest of the children.
Respectfully submitted,
IRWIN, NlclDiIGHT & HUGHES
By:
Marcus A. M ht III,-Es,
Attorney for Petitioner,
Pamela L. Hamilton
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court 1. D. No. 25476
Date: May 26, 1999
4
VERIFICATION
The foregoing Petition for Custody is based upon information which has been gathered
by my counsel and myself in the preparation of this action. 1 have read the statements made in
this document and they are true and correct to the best of my knowledge, information and belief.
I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A.
Section 4904, relating to unswom falsification to authorities.
?oa 2 -n &a . f?i?2?
PAMELA L. HAMILTON
Date: MAY 26. 1999
PAMELA L. HAMILTON, : COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
: NO. 1999-3206
THOMAS A. HAMILTON,
Defendant IN DIVORCE
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Defendant, THOMAS
HAMILTON, in the above captioned case.
SAIDIS, SHUFF, FLOWER & LINDSAY
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTIM -AnuW
26 W. High Street
Carlisle. PA
26 West High Street
Carlisle, PA 17013
(717) 243-6222
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PAMELA L. HAMILTON,
Plaintiff
v
THOMAS A. HAMILTON,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999 - 3206
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE
Please withdraw the appearance of Hubert X. Gilroy, Esquire and the firm of Broujos &
Gilroy, P.C. in the above captioned action.
Respectfully submitted,
Hubert X. G' roy, Esquire
Broujos & ilroy, P.C.
4 North H• nover Street
Carlisle, PA 17013
(717) 243-4574
Supreme Court ID No. 29943
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DEC 2
PAMELA L. HAMILTON
Plaintiff
vs.
THOMAS A. HAMILTON
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 70A day of re__U ? , 2004, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
Order. 1. The prior Order of this Court dated October 25, 2000, is vacated and replaced with this
2. The Mother, Pamela L. Hamilton, and the Father, Thomas A. Hamilton, shall have shared
legal custody of Sarah Hamilton, born June 8, 1988, David Hamilton, born April 30, 1990, and Kristen
Hamilton, born July 7, 1995. Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the Children's general well-being
including, but not limited to, all decisions regarding their health, education and religion. Pursuant to
the terms of this paragraph each parent shall be entitled to all records and information pertaining to the
Children including, but not limited to, school and medical records and information.
3. The Mother shall have primary physical custody of Sarah and Kristen and the Father shall
have primary physical custody of David beginning on January 2, 2005.
4. The parties shall have partial physical custody of the Children as follows:
A. The Mother shall have partial custody of David on Mondays and Wednesdays from
5:00 p.m. until 8:00 p.m. and the Father shall have partial custody of Kristen on
Tuesdays and Thursdays from 5:00 p.m. until 8:00 p.m. This schedule is intended to
ensure that David and Kristen are with the same parent on the specified weekday
evenings.
B. The parties shall alternate having custody of the Children on weekends. The Mother
shall have custody on alternating weekends from Friday at 5:00 p.m. through Sunday at
8:00 p.m. The Father shall have custody of the Children on a rotating alternating
weekend basis, with his first alternating weekend period of custody to run from Friday
at 5:00 p.m. through Sunday at 8:00 p.m. and his second alternating weekend period of
custody to run from Friday at 5:00 p.m. through Sunday at 7:30 p.m. (when the Father
shall transport the Children to the Mother's church), with the Mother having a period of
custody on the Sunday morning from 9:00 a.m. until 1:00 p.m. for church.
5. The parties shall share having custody of the Children on holidays as arranged by agreement.
6. Each party shall be entitled to have custody of the Children for three weeks during each year
upon providing at least 30 days advance notice to the other party. The party who provides notice first
shall be entitled to preference on his or her selection of weeks under this provision.
7. In the event either party is unavailable to provide care for the Children during his or her
period of custody for a period of two overnights or more, that parent shall first contact the other parent
to offer the opportunity to provide care for the Children during the period of unavailability before
contacting third party caregivers.
8. The parties shall participate in therapeutic family counseling for the purpose of improving
communication patterns and skills between the parties to enable them to effectively co-parent the
Children. The parties shall attempt to identify and select a counselor within the Father's insurance
plan. All costs of counseling which are not covered by insurance shall be shared equally between the
parties.
9. The parties and their counsel shall attend a custody conciliation conference in the office of
the conciliator, Dawn S. Sunday, on Tuesday, May 10, 2005 at 9:00 a.m. for the purpose of reviewing
the trial custody arrangements set forth in this Order and to address concerns regarding all three of the
parties' Children.
Berry. 10. The Children shall not be left alone in the company of their maternal grandmother, Muriel
11. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
2;W
Edward E. Guido J.
cc: 44arcus A. McKnight, 111, Esquire - Counsel for Mother
,12`6rol J. Lindsay, Esquire - Counsel for Father
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OF THE PROTH
2004 DEC 30 AH 9: 22
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PAMELA L. HAMILTON
Plaintiff
VS.
THOMAS A. HAMILTON
Defendant
Prior Judge: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sarah Hamilton June 8, 1988
David Hamilton April 30, 1990
Kristen Hamilton July 7, 1995
Mother
Mother
Mother
2. A conciliation conference was held on December 23, 2004, with the following individuals in
attendance: The Mother, Pamela L. Hamilton, with her counsel, Marcus A. McKnight, III, Esquire, and
the Father, Thomas A. Hamilton, with his counsel, Carol J. Lindsay, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date Dawn S. Sunday, EsquirdY
Custody Conciliator
?d? .
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RECEIVED MAY 1370-V Jr
vs.
PAMELA L. HAMILTON
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
THOMAS A. HAMILTON
Defendant
99-3206
IN CUSTODY
ORDER OF COURT
AND NOW, this l day of Vl/? 2005, upon
consideration of the attached Custody Conciliation Report, it is ord red and directed as follows:
1. The prior Order of this Court dated December 30, 2004 shall continue in effect as modified
by this Order.
2. The parties shall participate in therapeutic family counseling at Mazzitti and Sullivan
Counseling Services or other professional selected by agreement of the parties. The purpose of the
counseling shall be to improve communication patterns and skills between the parties to enable them to
effectively co-parent the Children. The parties shall attend a minimum of six sessions (including
individual sessions). All costs of counseling which are not covered by insurance shall be shared
equally between the parties.
3. The parties shall proceed with the counseling scheduled for Kristen with Victoria Whitcomb
or other professional selected by agreement between the parties. The purpose of the counseling shall
be to address any adjustment issues the Child maybe having and assist the Child in dealing with her
feelings in connection with the custodial arrangements. The Father shall be responsible for any costs
of counseling under this provision which are not covered by insurance.
4. Paragraph 4A of the Order dated December 30, 2004 shall be expanded to reflect the parties'
agreement to be reasonable in permitting the Children to visit the other parent's residence on evenings
other than those specified in the provision at either Child's request.
5. Paragraph 4B of the Order dated December 30, 2004 is deleted and replaced with the
following provision: The parties shall alternate having custody of the Children on weekends from
Friday at 5:00 p.m. through Sunday at 8:00 p.m.
6. During the period from June 19 through July 2, when the Mother is out of town, the parties
agree that Kristen may stay with friends (the Patterson family) subject to the Father's regular periods
of custody. The Mother shall ensure that no corporal punishment is imposed upon the Child under this
provision. The parties agree that the Child may spend additional overnight or other periods of custody
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with the Father during this time period as arranged by agreement between the Father, the Child and the
Pattersons.
7. Counsel for either party may contact the conciliator to schedule an additional custody
conciliation conference, if necessary, prior to the beginning of the 2005-2006 school year.
8. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
J.
J . W?s?t? CJ Cr ?f
cc: Marcus A. McKnight, III, Esquire - Counsel for Mother
Carol J. Lindsay, Esquire - Counsel for Father
PAMELA L. HAMILTON
Plaintiff
VS.
THOMAS A. HAMILTON
Defendant
Prior Judge: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sarah Hamilton June 8, 1988 Mother
David Hamilton April 30, 1990 Father
Kristen Hamilton July 7, 1995 Mother
2. A conciliation conference was held on May 10, 2005, with the following individuals in
attendance: The Mother, Pamela L. Hamilton, with her counsel, Marcus A. McKnight, III, Esquire, and
the Father, Thomas A. Hamilton, with his counsel, Carol J. Lindsay, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
/ -/ Jou, 5
Date Dawn S. Sunday, Esquire
Custody Conciliator
Vi
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PAMELA L. IIAMILTON IN1 I IF COURT Of COMMON PLEAS Oh
PLAINT111 CUMBERLAND COUNTY, PENNSYLVANIA
99-3206 CIVIL ACTION LAW
THOMAS A. IIAM11: rON
OFITNDANT
IN CUS'fODI'
ORDER OF COURT
AND NOW, Wednesday November 09, 2005 upon Coll sideation of the atlached Complaint,
it is hereby directed that parties and their respective counsel appeal. before Dawn S. Sunday, Esq. the conciliator,
at 39 West Main Street. Mechanicsburg, PA 17055 on Wednesday, December 07, 2005 at 8:30 AM
for a Pre-Hcaring Custody Conference. At such conference an el•lurl n ill he nmde to resolve the issues in dispute; or
if this cannot he accomplished, to define and narrow the issues to he heard by Ille court, and to enter into n temporary
order. All children age live or older nmv also be present at the conlirence. Pailtue to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court he•ehY directs the parties to ftirnislt :uq alll all ecistin? Protection from Abuse orders,
Special Relief orders, and Cusiodv orders to the conciliator 48 hours prior to scheduled hearimi.
POR 'I I Ili COURT.
Hy; h' Dnrr>_S. Sunc/n;.Esq,..,._??
Custody C oncili:uor T
The Court of Common Pleas of Cumbet'land County is required by lace to comply with the Americans
vith DisabiIites Act of 1990, For information about accessible facilities and reasonable accommodations
available w (1kabled individuals h:n inu, husiucss helorc the rood, please contact our office. All arrangements
nutsu be made :n least 72 hours prior it) any hcarin;. ur business before the court. You must amend the scheduled
coof?rcnce ur hcm'ing.
YOU SHOULD TAR1:'I HIS PAPER 10 YOUR Af'I.ORNLY A7.ONC'E. IF YOU DO NOT
HAVE AN A'l'l ORiAl--)' OR CANN011? AFFORD ON]-" (iO ?10 OR ' I LIA-THONE THL OPI-ICE S F I
FOR'I'll BELOW 1(I FIND OUT WIII{RI: YOU CAN Bill I F(iAl. 11171,11.
('Illnhetland ( O'all% Bar Association
South Hc(Ilmd Slrecl
Carlislo,Pcnns\kamii I7013
lclephunc 1717) _249-31(to
FI'?FU- err J`.TI RY
OF [I E c Q? i'
2005 i U`1 -0 F1'; 3 2 t
??'?' ?r //? /far "`_? GL ?GYi %/f?jCi"/uG/?:
PAMELA L. HAMILTON,
Plaintiff
V.
THOMAS A. HAMILTON,
Defendant
NOV n :3 2005
COURT OF CWM0h -
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1999-3206
IN DIVORCE
ORDER OF COURT
AND now, this day of , 20_, upon consideration of
the attached Motion, it is hereby directed that the parties and their respective counsel
appear before the conciliator, at
on the day of
20_, at AM/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.
Failure to appear at the conference may provide grounds for entry of a temporary or
permanent order.
FOR THE COURT:
Custody Conciliator
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
AMERICANS WITH DISABILITIES ACT OF 1990
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATT9RWVPAT-uw
26 W. High Street
Carlisle, PA
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.
The Court of Common Pleas of Cumberland County, Pennsylvania, is required by
law to comply with the Americans with Disabilities Act of 1990. For information about
accessible facilities and reasonable accommodations available to disabled individuals
having business before the court, please contact our office. All arrangements must be
made at least 72 hours prior to any hearing or business before the Court.
BY THE COURT,
, J.
PAMELA L. HAMILTON,
Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 1999-3206
THOMAS A. HAMILTON,
Defendant IN DIVORCE
PETITION FOR CONTEMPT OF COURT
AND NOW, comes Thomas A. Hamilton, by and through his counsel, Saidis, Shuff,
Flower & Lindsay, and petitions This Honorable Court as follows:
1. The parties hereto are the parents of three children: Sarah Hamilton born
June 8,1988, David Hamilton born April 30, 1990, and Kristen Hamilton born July 6, 1995.
2. Custody of David and Kristen is controlled by two Court Orders, that of
December 30, 2004 and May 17, 2005. Copies of the two Orders are attached hereto as
Exhibit "A"
3. Respondent Pamela A. Hamilton is in contempt of the two Court Orders in
the following particulars:
a. Paragraph 7 of the Court Order of December 30, 2004, states
SAIDIS
SNUFF, FLOWER
& LINDSAY
ATTURNEn-AT•IAW
26 W. High Street
Grlide, PA
in pertinent part: "In the event either party is unavailable to provide care for
the children during his or her period of custody for a period of two overnights
or more, that parent shall first contact the other parent to offer the
opportunity to provide care for the children during the period of unavailability
before contacting third party care givers." Respondent placed the children in
the rare of a third party without offering the opportunity to Petitioner to care
for the children on October 27, 28 and 29.
b. Paragraph 3 of the Court Order of May 17, 2005, states: "The
parties shall proceed with counseling scheduled for Kristen with Victoria
Whitcomb or other professionals selected by Agreement between the
parties." Although Kristen attended two sessions of counseling with Victoria
Whitcomb, Respondent refused to return Kristen to counseling against the
recommendation of Victoria Whitcomb.
C. Paragraph 6 of the Court Order of December 30, 2004,
states: "Each party shall be entitled to have custody of the children for three
weeks during each year upon providing at least thirty (30) days advance
notice to the other party." For her vacation in 2005, Respondent provided no
notice to Petitioner for her vacation.
4. Respondent has articulated disregard to the Court Orders and her actions
indicate that she does not feel bound by them.
5. The children's best interests are served by Respondent obeying Court
Orders.
6. Respondent will Incur attorney's fees in attempting to have the Orders of
December 30, 2004 and May 17, 2005 enforced.
WHEREFORE, Petitioner prays this Honorable Court to hold Respondent in
contempt of Court and to order such relief as the Court deems appropriate, including
payment of Petitioner's counsel fees.
SAIDIS, SNUFF, FLOWER & LINDSAY
SAIDIS
SHUFF, FLOWER
& LINDSAY
A'n0RNCYEATNAW
26 W. Irlch Sitm
Grlldr, PA
i
i
i
i
Carol J. Lindsay, Esqq ire
Supreme Court ID No. 44693
26 West High Street
Carlisle, PA 17013
717-243-6222
Exhibit "A"
RECEIVED MAY 19 2005y'
PAMELA L. HAMILTON IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA.
VS. 99-3206 CIVIL ACTION LAW
THOMAS A. HAMILTON
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this (Illy of ?1'.g 2005, upon
consideration of the attached Custody Conciliation Repo k, it is ordered and directed as follows:
1, The prior Order of this Court dated December 30, 2004 shall continue in effect as modified
by this Order,
2. The parties shall participate in therapeutic family counseling at Mazzitti and Sullivan
Counseling Services or other professional selected by agreement of the parties. The purpose of the
counseling shall be to improve communication patterns and skills between the parties to enable them to
effectively co-parent the Children, The parties shall attend a minimum of six sessions (including
individual sessions). All costs of counseling which arc not covered by insurance shall be shared
equally between the parties,
3. The parties shall proceed with the counseling scheduled for Kristen with Victoria Whitcomb
or other professional selected by agreement between the parties. The purpose of the counseling shall
be to address any adjustment issues the Child may be having and assist the Child in dealing with her
feelings in connection with the custodial arrangements. The Father shall be responsible for any costs
of counseling under this provision which arc not covered by insurance.
4. Paragraph 4A of the Order dated December 30, 2004 shall be expanded to reflect the parties'
agreement to be reasonable in permitting the Children to visit the*other parent's residence on evenings
other than those specified in the provision at either Child's request.
5, Paragraph 411 of the Order dated December 30, 2004 is deleted and replaced with the
following provision: 'f'ile parties shall alternate having custody of the Children on weekends from
Friday at 5:00 p.m. through Sunday at 5:00 p.m.
0. During the pcriod from June 19 through July 2, when the Mother is out of town, the parties
agree that Kristen may stay with friends (the Patterson family) subject to the Father's regular periods
of custody. The Mother shall ensure that no corporal punishment is imposed upon the Child under this
provision. The parties agree that the Child may spend additional overnight or other periods of custody
with the Father during this time period as arranged by agreement between the Father, the Child and the
Patterson.
7. Counsel for either party may contact the conciliator to schedule an additional custody
conciliation conference, if necessary, prior to the beginning of the 2005-2006 school year.
8. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
trIa L.? 0-&?'9.
?. o
,-1 (k)CSlal (2))e r, 'Tx.
cc: Marcus A. McKnight, III, Esquire - Counsel for Mother
Carol J. Lindsay, Esquire - Counsel for Father
TRUE COPY FROM RECORD
In Tutimony whereof, I here unto set my hand
anti the W of said rt al ca t.48 P2
ihi day o? ava2
Promonotsrr
PAMELA L. HAMILTON
Plaintiff
vs.
THOMAS A. HAMILTON
Defendant
Prior Judge: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
follows: 1. The pertinent information concerning the Children who are the subjects of this litigation is as
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sarah Hamilton June 8, 1988 Mother
David Hamilton April 30, 1990 Father
Kristen Hamilton July 7, 1995 Mother
2. A conciliation conference was held on May 10, 2005, with the following individuals in
attendance: The Mother, Pamela L. Hamilton, with her counsel, Marcus A. McKnight, III, Esquire, and
the Father, Thomas A. Hamilton, with his counsel, Carol J. Lindsay, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
t?"wt / !f 400,5 eee
Date Dawn S. Sunday, Esquire
Custody Conciliator
PAMELA L. HAMILTON
Plaintiff
VS.
THOMAS A. HAMILTON
Defendant
I
DEC 2 7. 2004 IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this ?6A day of re_f_ ? , 2004, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated October 25, 2000, is vacated and replaced with this
Order.
2. The Mother, Pamela L. Hamilton, and the Father, Thomas A. Hamilton, shall have shared
legal custody of Sarah Hamilton, born June 8, 1988, David Hamilton, born April 30, 1990, and Kristen
Hamilton, bom July 7, 1995. Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the Children's general well-being
including, but not limited to, all decisions regarding their health, education and religion. Pursuant to
the terms of this paragraph each parent shall be entitled to all records and information pertaining to the
Children including, but not limited to, school and medical records and information.
3. The Mother shall have primary physical custody of Sarah and Kristen and the Father shall
have primary physical custody of David beginning on January 2, 2005.
4. The parties shall have partial physical custody of the Children as follows:
A. The Mother shall have partial custody of David on Mondays and Wednesdays from
5:00 p.m. until 8:00 p.m. and the Father shall have partial custody of Kristen on
Tuesdays and Thursdays from 5:00 p.m. until 8:00 p.m. This schedule is intended to
ensure that David and Kristen are with the same parent on the specified weekday
evenings.
B. The parties shall alternate having custody of the Children on weekends. The Mother
shall have custody on alternating weekends from Friday at 5:00 p.m. through Sunday at
8:00 p.m. The Father shall have custody of the Children on a rotating alternating
weekend basis, with his first alienating weekend period of custody to run from Friday
at 5:00 p.m. through Sunday at 8:00 p.m. and his second alternating weekend period of
custody to run from Friday at 5:00 p.m. through Sunday at 7:30 p.m. (when the Father
aM `
shall transport the Children to the Mother's church), with the Mother having a period of
custody on the Sunday morning from 9:00 a.m. until 1:00 p.m. for church.
5. The parties shall share having custody of the Children on holidays as arranged by agreement.
6. Each party shall be entitled to have custody of the Children for three weeks during each year
upon providing at least 30 days advance notice to the other party. The party who provides notice first
shall be entitled to preference on his or her selection of weeks under this provision.
7. In the event either party is unavailable to provide care for the Children during his or her
period of custody for a period of two overnights or more, that parent shall first contact the other parent
to offer the opportunity to provide care for the Children during the period of unavailability before
contacting third party caregivers.
8. The parties shall participate in therapeutic family counseling for the purpose of improving
communication patterns and skills between the parties to enable them to effectively co-parent the
Children. The parties shall attempt to identify and select a counselor within the Father's insurance
plan. All costs of counseling which are not covered by insurance shall be shared equally between the
parties.
9. The parties and their counsel shall attend a custody conciliation conference in the office of
the conciliator, Dawn S. Sunday, on Tuesday, May ] 0,'j)05 at 9:00 a.m. for the purpose of reviewing
the trial custody arrangements set forth in this Order and to address concerns regarding all three of the
parties' Children.
10. The Children shall not be left alone in the company of their maternal grandmother, Muriel
Berry.
11. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
2;W
Edward E. Guido J.
cc: Marcus A. McKnight, 1I1, Esquire - Counsel for Mother
Carol J. Lindsay, Esquire - Counsel for Father
F.
1n) ,et(niony v.ilr,?•? ;`, f f,: unl set nIly howl
arm 114 seal of sill coot i1 i51(:, Pa.
a
r•
PAMELA L. HAMILTON
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
THOMAS A. HAMILTON
Defendant
Prior Judge: Edward E. Guido
99-3206 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sarah Hamilton June 8, 1988 Mother
David Hamilton April 30, 1990 Mother
Kristen Hamilton July 7, 1995 Mother
2. A conciliation conference was held on December 23, 2004, with the following individuals in
attendance: The Mother, Pamela L. Hamilton, with her counsel, Marcus A. McKnight, III, Esquire, and
the Father, Thomas A. Hamilton, with his counsel, Carol J. Lindsay, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date Dawn S. Sunday, Esquire
Custody Conciliator
VERIFICATION
I verify that the statements made in the foregoing document are true and
correct. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities
Thomas A. amilton
Date:
SAIDIS
SNUFF. FLOWER
& LINDSAY
ArFORIEMAMAW
26 W. High Street
Carlisle. PA
CERTIFICATE OF SERVICE
I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, SNUFF, FLOWER & LINDSAY,
hereby certify that on this date a copy of the attached document was served on the following
individual(s), via first class mail, postage prepaid, addressed as follows:
Marcus A. McKnight, III, Esquire
60 West Pomfret Street
Carlisle, PA 17013
SAIDIS, SNUFF, FLOWER & LINDSAY
Carol J. Lindsay, E:
Supreme Court ID 1
26 West High Stree
Carlisle, PA 17013
717-243-6222
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATtORNEVS•ATMW
26 W. NISh Street
Cadble, PA
-
-
C
?,
Cl-
UJ
C-3
O ? Lti
PAMELA L. HAMILTON
Plaintiff
vs.
THOMAS A. HAMILTON
Defendant
DEC 2 7 2005 y
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this day of - ?e?C 2005, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
I . The prior Orders of this Court dated December 30, 2004 and May 17, 2005 shall continue in
effect as modified by this Order.
2. The Father shall have a make-up period of custody with the Children from Thursday after
school through Sunday at 8:00 p.m. upon providing at least two weeks advance notice to the Mother in
writing, including e-mail communication.
3. Each party shall be entitled to have custody of the Children for three weeks during each year
upon providing at least two weeks advance notice to the other party. The party providing notice first
shall be entitled to preference on his or her selection of weeks under this provision. Each party shall
provide the other party with advance notice of the address and telephone number (standard telephone
service) where the Children can be contacted during periods of custody under this provision.
4. The Father shall make arrangements for Kristen to participate in counseling with a
professional to be selected by the Father. The Father shall notify the Mother promptly upon selecting
the counselor and scheduling the initial appointment. The Father shall provide all transportation for
the counseling sessions and shall be responsible to pay all costs of counseling which are not covered
by insurance.
5. All notices required by this Order or prior Orders shall be in writing.
> N
Lu Ci n
y'
LL,
O ?n
o°
Z5
N U
4C
6. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by written mutual consent. In the
absence of written mutual consent, the terms of this Order shall control.
BY THE COURT,
V
J.
7. Wcs c-I O Cr?J's
cc: Marcus A. McKnight, III, Esquire -Counsel for Mother
Carol J. Lindsay, Esquire - Counsel for Father
fs
1
PAMELA L. HAMILTON
Plaintiff
Vs.
THOMAS A. HAMILTON
Defendant
Prior Judge: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sarah Hamilton June 8, 1988 Mother
David Hamilton April 30, 1990 Father
Kristen Hamilton July 6, 1995 Mother
2. A custody conciliation conference was held on December 20, 2005, with the following
individuals in attendance: The Mother, Pamela L. Hamilton, with her counsel, Marcus A. McKnight,
III, Esquire, and the Father, Thomas A. Hamilton, with his counsel, Carol J. Lindsay, Esquire.
3. The Father filed this Petition for Contempt alleging that the Mother had violated the existing
Orders by failing to provide him with the right of first refusal in October, by refusing to continue
counseling for the parties' daughter, Kristen, and by failing to provide notice to the Father of the
Mother's vacation in 2005. At the conference, the Mother acknowledged that she had not provided the
Father with an opportunity to provide care for the Children during her absence in October and also had
not provided notice of vacation time as required by the existing Order. However, the parties were able
to reach an agreement on the issues addressed at the conference as reflected in the attached
recommended Order.
?-
Date Dawn S. Sunday, Esquir
Custody Conciliator
?y
???
.. .T?.
. 1
PAMELA L. HAMILTON
Plaintiff
vs.
THOMAS A. HAMILTON
Defendant
7
CE-C ?
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this ?61+
day of , 2004, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated October 25, 2000, is vacated and replaced with this
Order
2. The Mother, Pamela L. Hamilton, and the Father, Thomas A. Hamilton, shall have shared
legal custody of Sarah Hamilton, born June 8, 1988, David Hamilton, born April 30, 1990, and Kristen
Hamilton, born July 7, 1995. Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the Children's general well-being
including, but not limited to, all decisions regarding their health, education and religion. Pursuant to
the terms of this paragraph each parent shall be entitled to all records and information pertaining to the
Children including, but not limited to, school and medical records and information.
3. The Mother shall have primary physical custody of Sarah and Kristen and the Father shall
have primary physical custody of David beginning on January 2, 2005.
4. The parties shall have partial physical custody of the Children as follows:
A. The Mother shall have partial custody of David on Mondays and Wednesdays from
5:00 p.m. until 8:00 p.m. and the Father shall have partial custody of Kristen on
Tuesdays and Thursdays from 5:00 p.m. until 8:00 p.m. This schedule is intended to
ensure that David and Kristen are with the same parent on the specified weekday
evenings.
B. The parties shall alternate having custody of the Children on weekends. The Mother
shall have custody on alternating weekends from Friday at 5:00 p.m. through Sunday at
8:00 p.m. The Father shall have custody of the Children on a rotating alternating
weekend basis, with his first alternating weekend period of custody to run from Friday
at 5:00 p.m. through Sunday at 8:00 p.m. and his second alternating weekend period of
custody to run from Friday at 5:00 p.m. through Sunday at 7:30 p.m. (when the Father
shall transport the Children to the Mother's church), with the Mother having a period of
custody on the Sunday morning from 9:00 a.m. until 1:00 p.m. for church.
5. The parties shall share having custody of the Children on holidays as arranged by agreement.
6. Each party shall be entitled to have custody of the Children for three weeks during each year
upon providing at least 30 days advance notice to the other party. The party who provides notice first
shall be entitled to preference on his or her selection of weeks under this provision.
7. In the event either party is unavailable to provide care for the Children during his or her
period of custody for a period of two overnights or more, that parent shall first contact the other parent
to offer the opportunity to provide care for the Children during the period of unavailability before
contacting third party caregivers.
8. The parties shall participate in therapeutic family counseling for the purpose of improving
communication patterns and skills between the parties to enable them to effectively co-parent the
Children. The parties shall attempt to identify and select a counselor within the Father's insurance
plan. All costs of counseling which are not covered by insurance shall be shared equally between the
parties.
9. The parties and their counsel shall attend a custody conciliation conference in the office of
the conciliator, Dawn S. Sunday, on Tuesday, May 10, 2005 at 9:01) a.m. for the purpose of reviewing
the trial custody arrangements set forth in this Order and to address concerns regarding all three of the
parties' Children.
10. The Children shall not be left alone in the company of their maternal grandmother, Muriel
Berry.
11. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY T R ,
Edward E. Guido J.
cc: 44arcus A. McKnight, III, Esquire - Counsel for Mother
,,Clriol J. Lindsay, Esquire - Counsel for Father
0 q
13
ZZ :6 HN 0C 330 hGDZ
']HI d0
PAMELA L. HAMILTON
Plaintiff
VS.
THOMAS A. HAMILTON
Defendant
Prior Judge: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sarah Hamilton June 8, 1988 Mother
David Hamilton April 30, 1990 Mother
Kristen Hamilton July 7, 1995 Mother
2. A conciliation conference was held on December 23, 2004, with the following individuals in
attendance: The Mother, Pamela L. Hamilton, with her counsel, Marcus A. McKnight, III, Esquire, and
the Father, Thomas A. Hamilton, with his counsel, Carol J. Lindsay, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
4?(C, 2-jix 1 ;a
Date Dawn S. Sunday, Esquire
Custody Conciliator
RECEIVED MAY 13
PAMELA L. HAMILTON IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 99-3206 CIVIL ACTION LAW
THOMAS A. HAMILTON
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this A day of yo , 2005, upon 1? 11 consideration of the attached Custody Conciliation Report, it is ord red and directed as follows:
1. The prior Order of this Court dated December 30, 2004 shall continue in effect as modified
by this Order.
2. The parties shall participate in therapeutic family counseling at Mazzitti and Sullivan
Counseling Services or other professional selected by agreement of the parties. The purpose of the
counseling shall be to improve communication patterns and skills between the parties to enable them to
effectively co-parent the Children. The parties shall attend a minimum of six sessions (including
individual sessions). All costs of counseling which are not covered by insurance shall be shared
equally between the parties.
3. The parties shall proceed with the counseling scheduled for Kristen with Victoria Whitcomb
or other professional selected by agreement between the parties. The purpose of the counseling shall
be to address any adjustment issues the Child may be having and assist the Child in dealing with her
feelings in connection with the custodial arrangements. The Father shall be responsible for any costs
of counseling under this provision which are not covered by insurance.
4. Paragraph 4A of the Order dated December 30, 2004 shall be expanded to reflect the parties'
agreement to be reasonable in permitting the Children to visit the other parent's residence on evenings
other than those specified in the provision at either Child's request.
5. Paragraph 4B of the Order dated December 30, 2004 is deleted and replaced with the
following provision: The parties shall alternate having custody of the Children on weekends from
Friday at 5:00 p.m. through Sunday at 8:00 p.m.
6. During the period from June 19 through July 2, when the Mother is out of town, the parties
agree that Kristen may stay with friends (the Patterson family) subject to the Father's regular periods
of custody. The Mother shall ensure that no corporal punishment is imposed upon the Child under this
provision. The parties agree that the Child may spend additional overnight or other periods of custody
?
_
?.? f
,..it.l-? ??
1? _
1 i?
?i ?j _?
?l lJ
with the Father during this time period as arranged by agreement between the Father, the Child and the
Pattersons.
7. Counsel for either party may contact the conciliator to schedule an additional custody
conciliation conference, if necessary, prior to the beginning of the 2005-2006 school year.
8. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control,
BY THE COURT,
J.
cc: Marcus A. McKnight, III, Esquire - Counsel for Mother
Carol J. Lindsay, Esquire - Counsel for Father a
PAMELA L. HAMILTON
Plaintiff
VS.
THOMAS A. HAMILTON
Defendant
Prior Judge: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
The pertinent information concerning the Children who are the subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sarah Hamilton June 8, 1988 Mother
David Hamilton April 30, 1990 Father
Kristen Hamilton July 7, 1995 Mother
2. A conciliation conference was held on May 10, 2005, with the following individuals in
attendance: The Mother, Pamela L. Hamilton, with her counsel, Marcus A. McKnight, III, Esquire, and
the Father, Thomas A. Hamilton, with his counsel, Carol J. Lindsay, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
oD J / !, moos
Date Dawn S. Sunday, Esquire
Custody Conciliator
PAMELA L. HAMILTON,
Plaintiff
V.
THOMAS A. HAMILTON,
Defendant
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1999-3206
IN DIVORCE
PETITION FOR CONTEMPT OF COURT
AND NOW, comes Thomas A. Hamilton, by and through his counsel, Saidis, Shuff,
Flower & Lindsay, and petitions This Honorable Court as follows:
1. The parties hereto are the parents of three children: Sarah Hamilton born
June 8,1988, David Hamilton born April 30, 1990, and Kristen Hamilton born July 6, 1995.
2. Custody of David and Kristen is controlled by two Court Orders, that of
December 30, 2004 and May 17, 2005. Copies of the two Orders are attached hereto as
Exhibit "A".
3. Respondent Pamela A. Hamilton is in contempt of the two Court Orders in
the following particulars:
a. Paragraph 7 of the Court Order of December 30, 2004, states
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 W. High Street
Carlisle, PA
in pertinent part: "In the event either party is unavailable to provide care for
the children during his or her period of custody for a period of two overnights
or more, that parent shall first contact the other parent to offer the
opportunity to provide care for the children during the period of unavailability
before contacting third party care givers." Respondent placed the children in
the care of a third party without offering the opportunity to Petitioner to care
for the children on October 27. 28 and 29.
b. Paragraph 3 of the Court Order of May 17, 2005, states: "The
parties shall proceed with counseling scheduled for Kristen with Victoria
Whitcomb or other professionals selected by Agreement between the
parties." Although Kristen attended two sessions of counseling with Victoria
Whitcomb, Respondent refused to return Kristen to counseling against the
recommendation of Victoria Whitcomb.
C. Paragraph 6 of the Court Order of December 30, 2004,
states: "Each party shall be entitled to have custody of the children for three
weeks during each year upon providing at least thirty (30) days advance
notice to the other party." For her vacation in 2005, Respondent provided no
notice to Petitioner for her vacation.
4. Respondent has articulated disregard to the Court Orders and her actions
indicate that she does not feel bound by them.
5. The children's best interests are served by Respondent obeying Court
Orders.
6. Respondent will incur attorney's fees in attempting to have the Orders of
December 30, 2004 and May 17, 2005 enforced.
WHEREFORE, Petitioner prays this Honorable Court to hold Respondent in
contempt of Court and to order such relief as the Court deems appropriate, including
payment of Petitioner's counsel fees.
SAIDIS
SHUFF, FLOWER
& LINDSAY
ArMRHEYS•AT•LAW
26 W. High Street
Carlisle, PA
SAIDIS, SHUFF, FLOWER & LINDSAY
r
Carol J. Lindsay, Es ire
Supreme Court ID o. 44693
26 West High Street
Carlisle, PA 17013
717-243-6222
Exhibit "A"
RECEIVED MAY 13 2005Z''
PAMELA L. HAMILTON
Plaintiff
VS.
THOMAS A. HAMILTON
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 1'7 ? day of •ea , 2005, upon
consideration of the attached Custody Conciliation Repo , it is ordered and directed as follows:
1. The prior Order of this Court dated December 30, 2004 shall continue in effect as modified
by this Order.
2. The parties shall participate in therapeutic family counseling at Mazzitti and Sullivan
Counseling Services or other professional selected by agreement of the parties. The purpose of the
counseling shall be to improve communication patterns and skills between the parties to enable them to
effectively co-parent the Children. The parties shall attend a minimum of six sessions (including
individual sessions). All costs of counseling which are not covered by insurance shall be shared
equally between the parties.
3. The parties shall proceed with the counseling scheduled for Kristen with Victoria Whitcomb
or other professional selected by agreement between the parties. The purpose of the counseling shall
be to address any adjustment issues the Child may be having and assist the Child in dealing with her
feelings in connection with the custodial arrangements. The Father shall be responsible for any costs
of counseling under this provision which are not covered by insurance.
4. Paragraph 4A of the Order dated December 30, 2004 shall be expanded to reflect the parties'
agreement to be reasonable in permitting the Children to visit the other parent's residence on evenings
other than those specified in the provision at either Child's request.
5. Paragraph 413 of the Order dated December 30, 2004 is deleted and replaced with the
following provision: The parties shall alternate having custody of the Children on weekends from
Friday at 5:00 p.m. through Sunday at 8:00 p.m.
6. During the period from June 19 through July 2, when the Mother is out of town, the parties
agree that Kristen may stay with friends (the Patterson family) subject to the Father's regular periods
of custody. The Mother shall ensure that no corporal punishment is imposed upon the Child under this
provision. The parties agree that the Child may spend additional overnight or other periods of custody
with the Father during this time period as arranged by agreement between the Father, the Child and the
Pattersons.
7. Counsel for either party may contact the conciliator to schedule an additional custody
conciliation conference, if necessary, prior to the beginning of the 2005-2006 school year.
8. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
lsla 4u. 0-6 9,
d uje-del Oler, ??.
cc: Marcus A. McKnight, 111, Esquire - Counsel for Mother
Carol J. Lindsay, Esquire - Counsel for Father
TRUE COPY FROM RECORD
In Temtimony whereof, i here unto set my harw
and the seal of said at Carflsfe, Pa.
This IY?
Prof nocarr
PAMELA L. HAMILTON
Plaintiff
vs.
THOMAS A. HAMILTON
Defendant
Prior Judge: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sarah Hamilton June 8, 1988 Mother
David Hamilton April 30, 1990 Father
Kristen Hamilton July 7, 1995 Mother
2. A conciliation conference was held on May 10, 2005, with the following individuals in
attendance: The Mother, Pamela L. Hamilton, with her counsel, Marcus A. McKnight, III, Esquire, and
the Father, Thomas A. Hamilton, with his counsel, Carol J. Lindsay, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date Dawn S. Sunday, Esquire
Custody Conciliator
1
DEC 2 7 ?004
PAMELA L. HAMILTON IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 99-3206 CIVIL ACTION LAW
THOMAS A. HAMILTON
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this 3g day of 2004, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated October 25, 2000, is vacated and replaced with this
Order.
2. The Mother, Pamela L. Hamilton, and the Father, Thomas A. Hamilton, shall have shared
legal custody of Sarah Hamilton, born June 8, 1988, David Hamilton, born April 30, 1990, and Kristen
Hamilton, born July 7, 1995. Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the Children's general well-being
including, but not limited to, all decisions regarding their health, education and religion. Pursuant to
the terms of this paragraph each parent shall be entitled to all records and information pertaining to the
Children including, but not limited to, school and medical records and information.
3. The Mother shall have primary physical custody of Sarah and Kristen and the Father shall
have primary physical custody of David beginning on January 2, 2005.
4. The parties shall have partial physical custody of the Children as follows:
A. The Mother shall have partial custody of David on Mondays and Wednesdays from
5:00 p.m. until 8:00 p.m. and the Father shall have partial custody of Kristen on
Tuesdays and Thursdays from 5:00 p.m. until 8:00 p.m. This schedule is intended to
ensure that David and Kristen are with the same parent on the specified weekday
evenings.
B. The parties shall alternate having custody of the Children on weekends. The Mother
shall have custody on alternating weekends from Friday at 5:00 p.m. through Sunday at
8:00 p.m. The Father shall have custody of the Children on a rotating alternating
weekend basis, with his first alternating weekend period of custody to run from Friday
at 5:00 p.m. through Sunday at 8:00 p.m. and his second alternating weekend period of
custody to run from Friday at 5:00 p.m. through Sunday at 7:30 p.m. (when the Father
shall transport the Children to the Mother's church), with the Mother having a period of
custody on the Sunday morning from 9:00 a.m. until 1:00 p.m. for church.
5. The parties shall share having custody of the Children on holidays as arranged by agreement.
6. Each party shall be entitled to have custody of the Children for three weeks during each year
upon providing at least 30 days advance notice to the other party. The party who provides notice first
shall be entitled to preference on his or her selection of weeks under this provision.
7. In the event either party is unavailable to provide care for the Children during his or her
period of custody for a period of two overnights or more, that parent shall first contact the other parent
to offer the opportunity to provide care for the Children during the period of unavailability before
contacting third party caregivers.
8. The parties shall participate in therapeutic family counseling for the purpose of improving
communication patterns and skills between the parties to enable them to effectively co-parent the
Children. The parties shall attempt to identify and select a counselor within the Father's insurance
plan. All costs of counseling which are not covered by insurance shall be shared equally between the
parties.
9. The parties and their counsel shall attend a custody conciliation conference in the office of
the conciliator, Dawn S. Sunday, on Tuesday, May 10, 2005 at 9:00 a.m. for the purpose of reviewing
the trial custody arrangements set forth in this Order and to address concerns regarding all three of the
parties' Children.
10. The Children shall not be left alone in the company of their maternal grandmother, Muriel
Berry.
11. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY T ,
Edward E. Guido J.
cc: Marcus A. McKnight, III, Esquire - Counsel for Mother
Carol J. Lindsay, Esquire - Counsel for Father
TRUTZ
Ill P.9,i!11GI1y N!VR i"C iF, t r i."''' t ?ie4tl
a d hc? sera! of say Co ,-A Pa.
TI i ........3.o, 1.....
PAMELA L. HAMILTON
Plaintiff
VS.
THOMAS A. HAMILTON
Defendant
Prior Judge: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sarah Hamilton June 8, 1988 Mother
David Hamilton April 30, 1990 Mother
Kristen Hamilton July 7, 1995 Mother
2. A conciliation conference was held on December 23, 2004, with the following individuals in
attendance: The Mother, Pamela L. Hamilton, with her counsel, Marcus A. McKnight, III, Esquire, and
the Father, Thomas A. Hamilton, with his counsel, Carol J. Lindsay, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
ltce,? Date Dawn S. Sunday, Esq
Custody Conciliator
VERIFICATION
I verify that the statements made in the foregoing document are true and
correct. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities.
_/!?4 .1 r
Thomas A. amilton
Date:
SAUDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
CERTIFICATE OF SERVICE
I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY,
hereby certify that on this date a copy of the attached document was served on the following
individual(s), via first class mail, postage prepaid, addressed as follows.
Marcus A. McKnight, III, Esquire
60 West Pomfret Street
Carlisle, PA 17013
SAIDIS, SHUFF, FLOWER & LINDSAY
Carol J. Lindsay, E!
Supreme Court ID 1
26 West High Stree
Carlisle, PA 17013
717-243-6222
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATrORNCYS•AT•LAW
26 W. High Street
Carlisle, PA
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PAMELA L. HAMILTON
PLAINTIFF
THOMAS A. HAMILTON
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COON "FY. PENNSYLVANIA
99-3206 CIVI1, A(AIONLAW
IN CUS FODY
DI:FI(\DANT
ORDER OF COURT
?( Wednesday,
1. y, November ll9, 200.5 , upon consideration ol'the attached Complaint,
it is herehq clirccted that parties and their respective counsel appear belore Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, December 07, 2005 at 8:30 AM
lbra Pre-HcarinL Custody COnFelenCe. Al Such ConFOICnCc, an elfort will he made to reS0l c the iSSues in dispute; or
if this cannot he accomplished, to del me and narrow the issues to he heard by the court, and to enter into a tempormr
order. All children arc In e or older may also be present at the conference. Failure to appear M 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 Reliel'orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing,
FOR THE COURT.
Hp is/ _ Dawn S. Sunday, Esq.
('ustodk Conciliator
t he Court oFCommon Pleas of Cumberland County is required by la?? to comply with the Americans
?N ith DktIblllteS Act of 1990. For information about accessible I,'1611 ICS and reasonable accommodations
m ailuble to disahled individuals ha%ing business hcfore the court, please contact our oFlice. All arranLemettts
must be made at leant 72 hours prior to anv hearing or hnSilteu helbre the court. You must attend the Scheduled
amlErcnce or hearing.
YOU SHOULD TAKE THIS PAPER "FO YOUR ATTORNEY A F ONC'E. IF YOU DO NOW
11V1 AN A i I ORNEY OR CANNO I AFFORD ON[" 0010 OR TF I ITFIONE THE OFI ICE SF'F
FORTH BELOW TO FIND OUT \VIIFR6 YOU CAN GE-1 LLOAL HELP.
Cumberland County Bar Association
i2 South Hedford Street
Carlisle,Pcnns\kania 17013
Telephone (717)249-3166
orw,
Sa r
DEC 2 7 2095Y
PAMELA L. HAMILTON
Plaintiff
vs.
THOMAS A. HAMILTON
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this Z_?7 K- day of ])e-r_ , 2005, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Orders of this Court dated December 30, 2004 and May 17, 2005 shall continue in
effect as modified by this Order.
2. The Father shall have a make-up period of custody with the Children from Thursday after
school through Sunday at 8:00 p.m. upon providing at least two weeks advance notice to the Mother in
writing, including e-mail communication.
3. Each party shall be entitled to have custody of the Children for three weeks during each year
upon providing at least two weeks advance notice to the other party. The party providing notice first
shall be entitled to preference on his or her selection of weeks under this provision. Each party shall
provide the other party with advance notice of the address and telephone number (standard telephone
service) where the Children can be contacted during periods of custody under this provision.
4. The Father shall make arrangements for Kristen to participate in counseling with a
professional to be selected by the Father. The Father shall notify the Mother promptly upon selecting
the counselor and scheduling the initial appointment. The Father shall provide all transportation for
the counseling sessions and shall be responsible to pay all costs of counseling which are not covered
by insurance.
A/ I
5. All notices required by this Order or prior Orders shall be in writing.
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6. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by written mutual consent. In the
absence of written mutual consent, the terms of this Order shall control.
BY THE COURT,
I /
cc: Marcus A. McKnight, III, Esquire - Counsel for Mother
Carol J. Lindsay, Esquire - Counsel for Father
?S
PAMELA L. HAMILTON
Plaintiff
VS.
THOMAS A. HAMILTON
Defendant
Prior Judge: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3206 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
The pertinent information concerning the Children who are the subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sarah Hamilton June 8, 1988 Mother
David Hamilton April 30, 1990 Father
Kristen Hamilton July 6, 1995 Mother
2. A custody conciliation conference was held on December 20, 2005, with the following
individuals in attendance: The Mother, Pamela L. Hamilton, with her counsel, Marcus A. McKnight,
III, Esquire, and the Father, Thomas A. Hamilton, with his counsel, Carol J. Lindsay, Esquire.
3. The Father filed this Petition for Contempt alleging that the Mother had violated the existing
Orders by failing to provide him with the right of first refusal in October, by refusing to continue
counseling for the parties' daughter, Kristen, and by failing to provide notice to the Father of the
Mother's vacation in 2005. At the conference, the Mother acknowledged that she had not provided the
Father with an opportunity to provide care for the Children during her absence in October and also had
not provided notice of vacation time as required by the existing Order. However, the parties were able
to reach an agreement on the issues addressed at the conference as reflected in the attached
recommended Order.
Date Dawn S. Sunday, Esquire
Custody Conciliator