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HomeMy WebLinkAbout99-06315..7 V rJ J ix v. ?lq i i kty't 5 Y ?a6a? +tYf G f ? 1 y == 4ty?k }d 4 i f?3 4 ; ? 1 7 A ? 4 y f 2 - ?,iGx , > ty 1 l ' ? f ( .15?Y Y Fi 2 a`¢ s y t t3y?utl? • w t?Y 4?G, y RIO if 5':i u t t. } d s? M { f of ?cr>y i : o a t: }t :a f' FEDERMAN AND PHELAN By: Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 Attorney for Plaintiff NORW EST NORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217 V. RAWNELL L. WELSH, JR. OR OCCUPANTS 268 BRINDLE ROAD MECHANICSBURG, PA 17055 : Court of Common Pleas Civil Division : CUMBERLAND County : Term . No. qq CIVIL ACTION - EJECTMENT - 3020 NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for and other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 oftlee set forth below to Mid out where you can get legal help. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1. Plaintifris NORWEST NORTGAGE, INC.. 2. Defendant is RAWNELL L. WELSH, JR. OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 268 BRINDLE ROAD, MECHANICSBURG, PA 17055, a legal description of which is attached. 4. Plaintiff became owner of said premises by a Deed from the Sheriff of CUMBERLAND County, which Deed was lodged and settlement made with the Sheriff (Abstract of Title). 5. Plaintiff, by virtue of the above, is the owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without tight and so far as the plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. RAttorney for Plaintiff DESr'RIPTION ALL THAT CERTAIN piece or parcel of land with improvements thereon, situate in Monroe Township, Cumberland County, Pennsylvania, being bounded and described according to a survey made by Gerrit J. Betz, Registered Surveyor, dated May 21, 1980, as follows, to wit: BEGINNING at an iron pin on the Western side of Brindle Road (T-562) (60 feet wide) at the dividing line between Lots 22 and 23 on the hereinafter mentioned plan of lots: said point being measured 372.40 feet to Epply Road (T-588), thence along the dividing line between Lots 22 and 23 on said plan, North 87 degrees 30 minutes 00 seconds West the distance of 190.00 feet to a point at the dividing line between Lots 16 and 23 on said plan: thence along said dividing line North 02 degrees 30 minutes 00 seconds East the distance of 173.36 feet to an iron pin at the dividing line between Lots 28 and 24 on said Plan: thence along said dividing line, South 82 degrees 22 minutes 30 minutes 00 seconds Western side of Brindle Road; 1 South 2 degrees feet to an iron pin on the 30 sseconds East thence the distance of 156.32 feet to a thence along said road, point, the plan of BEGINNING. BEING Lot No. 23. Block C on Plan of L-E High Subdivision as recorded in the Cumberland County Recorder's Office in Plan Book 24, page 8. HAVING thereon erected a single story dwelling known and numbered as 268 Brindle Road. Mechanicsburg. Pennsylvania. TAX PARCEL H22-274901-032. TtTt F TO SAID PREMISES iS VESTED 1LJ Rawnell L. Welsh, Jr. and Susan L. Welsh, his wife by Deed from GHF, Inc., Trustee dated 4/11/96, recorded 4/15/96, in Deed Book 137 page 607. VERIFICATION TIMOTHY P. O'BRIEN hereby states that he is ASSISTANT VICE-PRESIDENT of NORWEST MORTGAGE, INC. (NC) mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Ejectment . are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. ZOE:- DATE: 5L C%l < lrn :, C? vz t , iiz ? J J w U \J SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-06315 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST MORTGAGE INC VS. WELSH RAWNELL L JR R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: WELSH RAWNELL L JR but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOTICE NOT FOUND as to the within named defendant WELSH RAWNELL L JR DEFT. NO LONGER LIVES AT ADDRESS STATED, NO OCCUPANTS, HOUSE IS VACANT, PAPER EXPIRED 11/15/99 Sheriff's Costs: So answers, Docketing 18.00 Service 6.20 Not Found Return 5.00 .- Surcharge 8.00 K/ Inomas , SnerILL PHELAN $37= 11/15/1999 Sworn and subscribed to before me this Cr- day of 19A.D. FEDERMAN AND PHELAN By: Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102.1799 (215) 563-7000 NORWEST NORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217 V. Attorney for Plaintiff : Court of Common Pleas Civil Division : CUMBERLAND County Term RAWNELL L. WELSH, JR. OR OCCUPANTS OCCUP PANTS No. 268 BRINDLE ROAD MECHANICSBURG, PA 17055 CIVIL ACTION - EJECTMENT - 3020 NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for and other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 TRUE (COPY FROM REOOPD In Tt Ornoml wfic-mot, I her' unto vit my haW and U?a 1 srlb toL'artlx4f, Pa. All FCDE(n(" ,r: p}?li(V1??? ?tl,? GCiF'Y ,wM WJS.n?w .rv?.t ...;?.a?rn. .... n..:a.. e. ....... ...y...»ti?r?..s«u..?.r...v - i WTir!:OF 7UE SN,; TF Oct 15 3 49 m '99 c PENUS LVANIA s s a e .v hy? F T' 44 . 1? °is r 1. Plaintiff is NORWEST NORTGAGE, INC.. 2, Defendant is RAWNELL L. WELSH, JR. OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 268 BRINDLE ROAD, MECHANICSBURG, PA 17055, a legal description of which is attached. 4. Plaintiff became owner of said premises by a Deed from the Sheriff of CUMBERLAND County, which Deed was lodged and settlement made with the Sheriff (Abstract of Title). 5. Plaintiff, by virtue of the above, is the owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without right and so far as the plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. RANK FEDERMAN Attorney for Plaintiff Fg)Er(F?'v7'AN\ANDF N COPY PIEIVSE PoUi,?J 2 ¢r R1PTI N ALL THAT CERTAIN piece or parcel of land with improvements thereon, situate in Monroe Township. Cumberland County, Pennsylvania, being bounded and described according to a survey made by Gerrit J. Betz, Registered Surveyor, dated May 21, 1980, as follows. to wit: the BEGINNING etween iron pin on the Los 2? and 23 on the hereinafter me Honed plan of feetsawipointde) dividing line b measured 372.40 feet to Epply Road (T-588), thence along the dividing line between Lots 23 and 3 of 190. poi on said viding line between eLots 16 30 minutes 00 seconds West the and 23 on said plan; hence alongas id dividiing0li a North 02nt at the dividing line the dividing 8_tdegrees 22 minutes degrees 30 minutes seconds East the 24 on said Plan: thence along said dividing, bet 30 sseconds e sid road, South 2 d ¢res t 30 minutes 00 seconds Western side of grindle Road: thence the distance of 156.32 feet to a thence along point, the plan of BEGINNING. BEING Lot No. 23. Block C on Plan of L-E High Subdivision as recorded in the Cumberland County Recorder's Office in Plan Book 24, page 8. HAVING thereon erected a single story dwelling known and numbered as 268 Brindle Road. Niechanicsburg. Pennsylvania. TAX PARCEL #22-27•1901•033. 96,in Deed Book his e 607 TITLE TO Sm GHFRIncI[STrustee dated 4D/11/96,arecorded 41151 by Deed from FEDERI'AN AND PHELAN AT q, Y FILE COPY PLEASE RC I URN Y:; TIMOTHY P. O'BRIEN hereby states that he is ASSISTANT VICE-PRESIDENT of NORWEST MORTGAGE, INC. (NC) mortgage servicing agent for Plaintiff in this matter, that hetshe is authorized to take this Verification, and that the statements made in the foregoing Civil Action in. Ejectment are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE: FEDSMIAN AND PHELAN ATTORNEY FILE COPY PLEASE RETURN p MARIE LOUISE ABRAM IN THE COURTOF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. ADAM COMBS ABRAM 00-6215 CIVIL ACTION LAW DEFENDANT IN CUSTODY AND NOW, Thursday, September 13, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at 214 Senate Avenue, Suite 105, Camp 11111, PA 17011 on Monday, October 01, 2001 at 1:00 PM for a Pre-hearing Custody Conference. Al such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR TIIE COURT, By: ls/ Melissa P. Gre_e Esn? 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 TELEPI [ONE TI IE 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 C i ??Pc1'1tiSYLl?op`JjY hNi . a? .rye, Y ?tf?ti s LAW OFFICE EDWARD J. WEINTRAUB 2650 NORTH THIQD STREET HARRISBURG, PENNSYLVANIA 17110 17171 238.2200 FAX (717) 238.9280 SEP 0 ? 2001 MARIE LOUISE ABRAM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLANDCOUNTY,PENNSYLVANIA VS. NO. 00-6215 ADAM COMBS ABRAM, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2001, upon consideration of the attached complaint it is hereby directed that the parties and their respective counsel appear before , Esquire, the Conciliator, at Pennsylvania, on the day of 2001, at o'clock, _.m., for a Pre-Hearing 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 a temporary order. Either party may bring the child who Is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR 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. OFFICE OF THE COURT ADMINISTRATOR 1 COURTHOUSE SQUARE, 4TH FLOOR CARLISLE, PA 17013 (717)240.6200 MARIE LOUISE ABRAM, Plaintiff Va. ADAM COMBS ABRAM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLANDCOUNTY,PENNSYLVANIA NO. 00-6215 CIVIL ACTION - LAW IN CUSTODY PETITION TO MODIFY ORDER OF CUSTODY AND NOW, Plaintiff, by and through her attorney Edward J. Weintraub, Esquire, files a Petition to Modify Order of Custody, and in support thereof, avers the following: 1. Plaintiff Is Marie Louise Abram, Mother, who currently resides at 850 Walnut Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant Is Adam C. Abram, Father, who currently resides at 28 South Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The partias hereto are the parents of the following minor child who currently resides at 850 Walnut Lane, Carlisle, Cumberland County, Pennsylvania 17013: Marie Claire Abram Age 8 4. On November 29, 2000 the Court entered an Order of Custody, granting shared physical custody of the child to the Plaintiff and Defendant. A true and correct copy of this Order is marked Exhibit "A," attached hereto, and made part thereof. 5. The best Interest and permanent welfare of the child will be served by a modification of the Court's Order, specifically: Granting primary physical custody of the child to Plaintiff and partial physical custody to the Defendant. WHEREFORE, Plaintiff respectfully requests that this Honorable Court modify Its Order as follows: Granting primary physical custody of the child to Plaintiff and partial physical custody to the Defendant. ATTORNEY FOR PLAINTIFF 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 1. D. #17441 VERIFICATION I, Marie Louise Abram, verify that the statements made in this Petition to Modify Support 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 unswom falsification to authorities. Dated: 4 b f Marie Louise Abram, Plaintiff n 5.1 jSl r, >K i ? ?iayt irk, t'x?$ S Y EXHIBIT "A" it r ' 3= 't i%r{4 ? t `I:r ha _r im s j Yrxz?: f rt?, MARIE LOUISE ABRAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 00-6215 ADAM COMBS ABRAM, : CIVIL ACTION - t AW Defendant : CUSTODY ORDER OF COURT AND NOW, this 29+h day of 0014m e_,q_, 2000, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. LEGAL CUSTODY 1. The parties, Marie Louise Abram and Adam Combs Abram, shall share legal custody of their minor Child, Marie Claire Abram, born June 20, 1993. All decisions affecting the Child's growth and development including, but not limited to: choice of camp, if any; choice of daycare provider; medical and dental treatment; psychotherapy, or like treatment; decisions relating to actual or potential litigation involving the Child, directly or as beneficiary, other than custody litigation; education, both secular and religious; scholastic, athletic pursuits and other extracurricular activities; shall be considered major decisions and shall be made by the parents jointly, after discussion and consultation with each other, and with a view toward obtaining and following harmonious policy in the Child's best interest. 2. Each party shall keep the other informed of the progress of the Child's education and social adjustments. Each party shall not impair the other party's right to share legal or physical custody of the Child. Each party shall give support to the other in the role as parent and to take into account the consensus of the other for the physical and emotional well-being of the Child. 3. While in the presence of the Child, neither parent shall make or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the expressed duty of each parent to uphold the other parent as the one whom the Child should respect and love. 4. It shall be the obligation of each parent to make the Child available to the other in accordance with the physical custody schedule and to encourage her to participate in the plan hereby agreed and ordered. 5. Each parent shall have the duty to notify the other of any event or activity that could reasonably be expected to be of significant concern to the other parent. No. 00-6215 6. The parents shall communicate directly with one another concerning any parenting issue requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule, which may from time to time become necessary, and shall specifically not use the Child as a messenger. Furthermore, neither parent shall discuss with the Child any proposed changes to the physical custody schedule, or any other issue requiring consultation and agreement prior to discussing the matter and reaching an agreement with the other parent. 7. With regard to any emergency decisions which must be made, the parent with whom the Child is physically residing at the time shall be permitted to make the decision necessitated by the emergency without consulting the other parent in advance. However, that parent shall inform the other of the emergency and consult with him/her as soon as possible. Day to day decisions of a routine nature shall be the responsibility of the parent having physical custody at the time. 8. Each parent shall be entitled to complete and full information from any doctor, dentist, teacher or authority and copies of any reports given to them as a parent. Such documents include, but are not limited to, medical reports, academic and school report cards, birth certificates, etc. Both parents may, and are encouraged to attend school conferences and activities. The Father's name shall be listed with the school as the alternative parent to be contacted in the event of an emergency and to be notified regarding school events. However, it will be Mother's primary responsibility to provide Father with copies of report cards and all notifications of major school events. 9. Neither parent shall schedule activities or appointments for the Child which would require their attendance or participation at said activity or appointment during a time when she is scheduled to be in the physical custody of the other parent without that parent's expressed prior approval. 10. The parties have acknowledged that they have discussed and jointly made the following decisions: A. Carlisle Pediatric, Lynn Hoffman and Holly Bower, will continue to be the Child's pediatrician and accordingly, will provide medical treatment to the Child when necessary. B. The Child's legal name shall be Marie Claire Abram. She shall be known by this name for all purposes. The parties shall instruct their respective families and friends that the Child should not be referred to by any other name. No. 00-6215 C. The parties shall expect the Child to attend college and post-high school training if she is a good student with the high probability of getting entrance and succeeding in college. The parties shall be both actively involved in the selection of an appropriate post-high school education for the Child and the choice of any college or institution shall be mutually agreed upon by Father, Mother and the Child taking into consideration the parents' then financial ability and economic circumstances, and the Child's needs, desires, talents and aptitudes for post-high school education. 11. PHYSICAL CUSTODY 1. The parents shall share physical custody of the Child. Father shall have custody according to the following schedule: A. On alternate weeks, to begin November 10, 2000, from 5:00 p.m. Thursday until Monday morning when Father shall return the minor Child to school, or to the care of her Mother, B. Alternating Tuesday evenings from 5:30 p.m, until 7:30 p.m, to commence November 14, 2000, C. Alternating Thursday evenings and overnight from 5:00 p.m. until Friday morning when Father shall return the Child to the care of her Mother, or to school, unless otherwise agreed, To commence November 16, 2000, D. To commence November 20, 2000, on alternate Mondays from 3:45 p.m. until Tuesday morning when Father shall return the Child to school or to the care of her Mother, unless otherwise agreed. 2. Father shall give a copy of his work schedule to Mother and shall provide Mother, at the time of the preceding custody exchange, of any days when he may be able to complete his work by noon and therefore be able to commence his 5:00 p.m. periods of custody at an earlier time. 3. Summer: The summer schedule shall follow the school year schedule with the following exceptions: A. Father's alternate Tuesday evening periods of custody shall be extended to the following Wednesday morning when the Child shall be returned to her Mother or daycare provider. No. 00-6215 B. Each parent shall have the right to 3 blocks of 7 days which would supercede the regular schedule, but not supercede not the holidays. Each parent shall elect one week each calendar month during the months of June, July and August, providing at least a 60-day notice to the other party as to their intended vacation times. In the event that both parents plan the same week for vacation, the person who first provides notice to the other shall have the chosen week. 4. Holidays: A. Thanksgiving: Thanksgiving 2000 and subsequent even-numbered years shall be with Father. Thanksgiving 2001 and subsequent odd-numbered years shall be with Mother. The Thanksgiving period of custody shall be from the Wednesday preceding Thanksgiving after work until the following Monday morning. B. Christmas and Spring Vacation. Shall be defined by the period of time from after school adjournment until the night before school resumes, and shall be shared equally by the parties. The first half of Christmas break 2000 and subsequent even-numbered years shall be with Mother. The second half of Christmas break 2000 and subsequent even-numbered years shall be with Father. The first half of Christmas break 2001 and subsequent odd-numbered years shall be with Father, and the second half of Christmas break and subsequent odd-numbered years shall be with Mother. The first half of spring break 2001 and subsequent odd- numbered years shall be with Father. The second half of spring break 2001 and subsequent odd-numbered years shall be with Mother. In even- numbered years, Father shall have the second half of spring break and Mother shall have the first half of spring break. C. At the end of the last night of Spring, Christmas and Thanksgiving breaks, the parents who had custody for the first half of the holiday period shall have the Child from 6:00 p.m. overnight, unless otherwise agreed by the parties. D. Memorial Day and Labor Da v: The parties shall alternate Memorial Day and Labor Day. In 2001 and subsequent odd-numbered years, unless otherwise agreed, Father shall have Memorial Day from 5:00 p.m, Friday until 8:00 a.m. Tuesday. In 2001 and subsequent odd-numbered years, Mother shall have Labor Day from 5:00 p.m. Friday until 8:00 a.m. Tuesday. In even-numbered years, Mother shall have Memorial Day from 5:00 p.m. Friday until 8:00 a.m. Tuesday and Father shall have Labor Day from 5:00 p.m. Friday until 8:00 a.m. Tuesday. No. 00-6215 E. Independence Dav: Independence Day celebration shall be alternated annually by the parties. The period of custody for this holiday shall be from July 3rd at 5:00 p.m. until July 5th at 8:00 a.m. In 2001 and subsequent odd-numbered years, Father shall have the Independence holiday. In 2002 and subsequent even-numbered years, Mother shall have the Independence holiday. F. Mother's Day/Father's Day: Mother's Day and Father's Day shall be observed from Sunday at 8:30 a.m. until Monday at 9:00 a.m. Mother shall have custody for Mother's Day and Father shall have custody for Father's Day. 5. The parties shall endeavor to provide each other with at least a 72-hour notice with regard to a change in the overnight schedule. Prior to engaging the services of a third party to provide childcare, each party shall be obligated to contact the other parent in the event that they are not able to exercise their period of custody in the event of work emergencies or for overnight custodial times. Additionally, this obligation to contact the other parent shall be extended to apply in the summer and including periods of vacation time. 6. Mass: During Father's periods of custody it shall be acceptable for the Mother to take the Child to Mass between 8:30 a.m. and 10:30 a.m. on Sundays unless Father has other plans and notifies Mother by 8:00 p.m. the preceding Saturday. 7. Special Family Events: Each party shall be entitled to a period of custody for such family events including, but not limited to, weddings, funerals, anniversaries and other such similar celebrations or family gatherings, upon reasonable notice to the other party. 8. Telephone Calls: The Child may contact either parent by telephone at any time. The parties may make one call each day to the Child at the other parent's home between 5:00 p.m. and 7:30 p.m. 9. Relocation: Either party may relocate upon a 90-day notice to the other party. 10. This Order is temporary in nature. The parties may modify this Order by mutual agreement. In the absence of mutual agreement, the Order shall control pending further Order of Court. C'l f 1* ; W k u t7 ?? lN1 `?i n- 211 O