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HomeMy WebLinkAbout99-06759q 1 _. plaintiff CUMBERLAND COUNTY. PENNSYLVANIA VS. : NO. 99- CIVILTERM William Savagc. Defendant CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached complaint. it is hereby directed that the parties and their rgpective;counsel appear before 1\ ; { y <? theconciliator,ati't?i,.'•?< ;onthcL-dayof3an ., ;5ti.,foraPrc-Ilearing 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. By the Court. -A- A Date 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 Olt TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 'Pile Court of Common Pleas of Cumberland County is required by la%v 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. (f i ?? ?:,r??±w?.rw.v it Gi ?:, jl.: j i c. ;tt.age. : IN'rln COUR f 0r• COi\aa9ON PLEAS OF Pl,,imirf . CLJA913ERL,AND COLJN'I'Y. PENNSYLVANIA vs. : N0. 99_ = CIVIL TERM avaae. Dclcnd.mt CUS'T'ODY COMPLAINTFOR CUSTODY 1. The plaintiff is Eileen Savage. residing at Stewart Ilouse. 20 E. Pon,liet St. Carlisle. Cumberland County. Pennsylvania. 17013. 2. The defendant is William Savage, residing at 203 Meadow Lane. Apartment 32. Harrisburg, Dauphin County, Pennsylvania. 17104 . 3. The plaintiff seeks custotlyofthc following children: Name Present Residence Age Victoria E. Savage 20 E. Pomfret St.. Carlisle 10 Cameron 11. Savage 20 IL Pomfret St.. Carlisle 7 Alexandra M. Savage 20 1. Pomfrct St.. Carlisle 6 Liam G. Savage 20 E. Pomfret St.. Carlisle 4 The children were not born out of wedlock. The children are presently in the custody ol'Eilecn Savage, who resides at 20 E. Pomfret St., Carlisle. Pennsylvania. During the children's lifetime. Ihe) have resided with the following persons and at the foilowim, addresses: Name Address Date Plaintiff Stewart House 7/99- present 20 1.. Pon,lret St. Carlisle. PA 17011 Plaintiff anti 1 117 Columbus Avenue 9/98- 7/99 Defendant Apartment 5 Lemoyne. PA 17043 Plaintiff 22 Munden house Bromley High St. Bow. London. England Plaintiff anti Dawn %endre. Plaintiff's mother I Benson House Old Nichol St. Bethnal Green London. E.2.71ih. England Plaintiff. Defendant and John Savage. Defendant's father 628 Mineral Ave. Scranton. PA 18509 7/98- 9/98 8/97- 7/98 8188- 8/97 The mother of the children is Eileen Savage, currently residing at 20 E. Pomfret Street, Carlisle. Pennsylvania. She is married but in the process of getting a divorce. -fhe father of the children is William Savage, currently residing at 203 Meadow Lane, Apt. 32. 1larrisburg. Pennsylvania. 17104. He is married. 4. "fhe relationship of plaintiff to the children is that of mother. The plaintiff currently is residing at Stewart Mouse. 20 L'. Pomfret St.. Carlisle, PA 17013. 5. The relationship of defendant to the children is that of father. The plaintiff has no knowledge with whom the defendant currently resides. 6. The plaintiff has participated as a party in litigation concerning the custody ofthe children in the Court of Common Pleas of Lackawanna County, which had scheduled an emergency Custody I learim, when the mother had lived with the children in England and the father had lived in Lackawanna County. At the time of the entry of the stipulation and Custody Order on June 9. 1999, the parties resided in Lemoyne. Pennsyh•ania. Cumberland County: paragraph four (4) of that order prohibited relocation of the children from Cumberland County absent agreement. Since the father moved to Dauphin County and the mother established residence in Carlisle. Cumberland County, the lather never exercised primary phvsical custody pursuant to the Lackawanna County Order. In fact. the mother maintained primary physical custody. A copy of this Order is attached as Exhibit A and incorporated herein by reference. 7. 'file plaintiffhas no information ofa custody proceeding concerning the children pending in a court of this Commonwealth. 9. 'file plaintiff floes not know of a person not a party to the proceedings who has physical custody of tile children or claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the children will be served by granting the plaintiff mother priman' physical custody of the children for reasons including the following: 1) 'File mother has been the children's primary care giver since their births and can continue to provide for their needs. b) The mother is the parent who can best provide for the children's needs. including a nurturing environment and appropriate housing. c) "file father is not acting in the children's best interest for reasons including the following: i. 'fhe father has no beds for the children and inadequate furnishings. ii. The father returns the children dirty and hungry from visits. iii. "fhe rather is unstable and has exhibited behavior which causes the r inother concern for the children's well being including: threatening to commit suicide on several occasions both in the presence of the mother and the children and becoming enraged and screaming at the mother and children such that the security officers at the mother's residence told him to leave the premises. 10. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHERETORE, the plaintiff requests this Court to modify the June 9. 1999, Court Order from Lackawanna County and grant primary physical custody of the children to the plaintiff and partial custody, not including overnights, to the defendant at times agreed upon by the parties, conditioned upon his having appropriate housing and provisions for the children. "fhe plaintiff requests any other relief which is just and proper. Respectfully submitted, Joan Carey Attorney for Plaintiff LEGAL SERVICES, INC. S Irvine Row Carlisle, PA 17013 (717) 243-9400 WILLIAM P. °14AL01 LP,L'i.= , COUNTY Nil _. -9 P ;: (;n "A L WILLIAM RICHARD SAVAGE, III THE COURT OF COI.DION PLEAS Plaintiff OF LACKAWANNA COUNTY CIVIL ACTIO14 LAW VS. EILEEN PATRICIA SAVAGE, Defendant 96-Civ-2792 .................................................... O R D E R ??h}L _? ?1 AND NOW, this day of 1999, this matter set for emergency heariand after consulting i with the respective attorneys for the parties, the following Stimulation is hereby entered as an order of Court. (1) William Richard Savage and Eileen Patricia Savage shall have shared legal custody of their four minor children, Victoria Savage, Cameron Savage, Alexandra Savage, and Liam Savage. (2) At the present time, the parties are residing together in Lemoyne, Pennsylvania. However, it is anticipated that Eileen Savage will short1yFa verto her own residence in the Harrisburg area, shall have primary custody of the four children until further Order of Court. Once Eileen Savage has established a proper residence for herself to and the children, it is the intent of the parti between equally divide the physical custody periods themselves with the minor children. It is hoped that they will amicably divide the shared custody schedule which can accommodate the parties respective work schedule. i I I I i I:xibiL A I: (3) Upon separation of the parties, the children's legal address sha11 remain as 1117 Columbus Avenue Apartments, Lemoyne, PA. (4) Neither parent may relocate out of the Cumberland County, Pennsylvania area with the children, unless they first receive prior permission from this Court, or written permission from the other party. Y THE CURT: C-- ak -i+I VERIFICATION 1. Gileen P. Savage. verify that 1 am the plaintiff as designated in the present action and . ; that the facts and statements contained in the above Complaint are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of' 18 a Pa.C.S. § 4904. relating to unsworn falsification to authorities. Dated: Fileen P. Savage, I'Iaintilf ?- ?. , ?? ?_, , . -. ?:.. - ,, ? ;.: ?? = - "LEGAL 8 `CARLISLE, >r Eileen P. Savage. Plaintiff IN "I HP COURT OP COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA William Savage. Defendant N0. 99- CIVIL TERM PRAECII'E TO PROCEED IN FORMA PAUPERIS To the Prothonoutrv: Kindly allow. Eileen 1'. Savage. Plaintiff. to proceed in forma ate! eris. L.Io:m Carey. attorney Liu the party proceeding in liirma pauperis, ccrtily that I believe the party is unable to pay the costs and that 1 am providing Irce legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. j. Joan Carl`)' Attornev for Plaintiff LEGAL SERVICES. INC. R Irvine Row Carlisle. PA 17013 (717) 243-9100 Eileen 11. Savage. IN THE COURTOF C'ONINION PLEAS OF Plaintiff CUMBERLAND C'OUNT'Y, PENNSYLVANIA NO. 99-c: CIVIL TERM William Savage, Defendant AFFIDAVIT IN SUPPORT Or PETITION FOR LFAVF TO PROC'I'PD IN 1:01M9A PAIJPFRIS 1. 1 am the Plaintiffin the above matter and because of my financial condition am unable to pay the Ices and costs of prosecuting, defending, orappealing the action or proceeding. 2. 1 am Unable to obtain funds Iiom anyone, including my family and associates, to pay the costs of- litigation. 3. 1 represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Eileen P. Savage Address: Stewart House. 20 E. PornlFet St.. Carlisle. PA 17013 Social Security Number. 172-70-8776 (b) Ifyou are presently employed, state Employer: Weis Nlarkel Address: 351 E. High St. Carlisle. PA 17013 Salary or wages per month: I'ypeof work: Cashier If you are presently unemployed, state N Date of last employment: n/a salary or wages per month: n/a Type of work: (c) Other income within the past twelve months Business or profession:, other self-employment: Interest: n/_? Dividends: n/a Pension and annuities: Social Security benefits: n/a Support payments: 142.68/week. started Se tember. 21 1999 Disability payments: Unemployment compensation and supplemental benefits: n/a Worker's compensation: nla Public Assistance: n/a only medical-no cash or food scam s Other: (d) Other contributions to household support (I lusband) Name: If aour (husband) is employed, state Employer: n/a Salary, or wages per month: _ Type of work: n/a Contributions from children: (e) Property, owned Cash: $0.00 Checking Account: $36.00 Savings Account: n/a Certificates of Deposit: n/a Real Estate (including home): n/a Motor vehicle: Make n/a Year n/a Cost n/a Amount owed n/a Stocks: bonds: n/a Other: n/a (f) Debts and obligations Mortgage: n/a Rent: nays 33%of wages and child support to Salvation Army- $252/mo. Loans: n/a Monthly Expenses: $63.72/mo. for furniture storage. $160/mo. clothing $200 credit card debt. $50 mo. food. $100/ mo. Toiletries/laundry (g) Persons dependent upon you for support Children, ifany: Name: Victoria F. Sava,e Age: 10 Cameron 11. Savage Alexandra M. Savage Liam G. Savage 4_(on Nov. 5. 1999) 4. 1 understand that I have it continuing obligation to inform the court of improvement in my financial circumstances which mould permit me to pay the costs incurred herein. 5. 1 verily that the statements made in this affidavit are true and correct. I understand that Ihise statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date:, Eileen P. Savage ,. MART, ON DLAIt OO RIP \Wri.uw .? p I ,,, MDW&O CAr hL I'l I %A,'S [r Cnmi¢ I, 1Y!te»'Un 171113 EILL•-EN 1'. SAVAGE, Plaintiff WILLIAM SAVAGE, De6emlam IN'I'IIHC'OURTOPCONIMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 99-6759 CIVIL ACTION LAW IN CUSTODY PRAHCIPIi TOTHE PRO"1'1I0NO'I'AIZ)' Of CUMBERLAND COUNTY: Enter the appearmice of MARTSON DEARDORPP WILLIA,NIS S: OTTO on behalf of Defendant in the abovc matter. klARTSON DEARDORPI' WILLIA\IS & OTTO Thomas J. 11'illiatns, Esquire fell East Iligh Street Carlisle, PA 17011 (717) 243-3341 Attorneys for Defelldaill Dated: December 14, 1999 CEIZ*I'IFIC:\"I'I? O1 SI?R`'IC'F I, Tricia D. I_ckemoaJ, an authorized agent f'r,Marlson Dcar'dol-IT iIIizlms & Olto, hereby certifv Ihat a copy oI'the lixc?" oing Praccipe was served this date by depositing same in the Post 01'fice at Carlisle, PA, first class mail, postage prepaid, addressed as follows: lout C'arcy, Esquire Legal Services, Inc. S Irvine Row Carlisle, PA 17013 i•IARTSON DEARDORFF NILLIA\IS & OT-1-0 "fricr.t D. I:ckcnroad 1 Fell Gast High Street Carlisle, PA 17013 (717) 343-3341 Dated: December 14, 1999 f', ?.; .. . i IN T[ If, COURT' 01' COMMON PLEAS OF CU14BI::RLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW El LEEN 1'. SAVAGE, Plaintiff WILLIAM SAVAGE, Defendant No. 99-6759 Civ'sl': _rnt IN CUSTODY ORI3EII OF COURT AND NOW. this l,DAL day of 23702) . Z6 y J . upon consideration orthe attached Stipulation (or Entryora Custouly Order. IT IS HEREBY ORDERED AND DECREED that the terms Ihereorare approved and that custody and partial custody arc awarded as set forth in the Stipulation with the same force and erect as i fthe same had been decreed by the Courtrollowing an Evidentiary 1 learing. 13Y THE COURT: /-//-00 R?3 h,lY 6-DJ,: r r . t''.. 1: sa PuVi •1S'r7 ?7???i;? i f k.. IN 'I'l lE COUI.'I' OI' C 0,\ \ION PI.I'.AS (W (•(i\IIII: Rl.:AND COON I'Y PENNSYLVANIA (•IVII.:VTION - LAW EI LEEN 11. SAVAGE, Plaintiff No.99-6759 CIFil'll'1•In WILLIAM SAVAGE IN CUSTOD)' 1)cfell dant S'1'IPUI.,\7•I0N FOR ENTRY OP CUSTODY ORDP.R The parties to thisaction.1.11-1.1 I'. SA\'AGE (hcreinal'tcrrclen'ed to as"\90'IIiI:R").and WILLIAM SAVAGE. (hereinafter relcrred to as " PATI IEIC). desiring to atnicablY settle and resolve all outstanding issues cvutcerning Custody and partial custody "ith respect to the minor children: VICTORIA F. SAVAGE. horn December 20. 1935: C'ANIFRON 11. SAVAGE. horn Nlay 27. 1992: AUXANDR:A \d. SAVAGE. born June 25. 1993: and LIrA\I G. SAVAGE. horn November 5. 1995. hereby stipulate and agree to the entry of an Order of Court awarding custody and partial custody LAW CA\IEIZON. M.FNe\NDR:\ and LI:A\t as follows: I. 'I'hc parents agree that they shall share Icgal casual' of the minor children. All major decisions affecting the children's growth and development shall be made by the parents after discussion and lonsahaliOn veith each other and with a view towards obtaining and following an harmonious policy in the children's hest interests. "These decisions include those regarding medical. religious and educational matters. Each parent agrees to keep the other inti;rmed of the progress of the children's educational and social atfjList menu. Fach parent shall have the dut\ ur notilj'theothcrol'any event oractk ity that could reasonably he CXpected to he of significtutt concern to the other parent. (loth parents agree to give support to the other in their role as "parent" and to take into account the concerns ol'the other for the physical and emotional smll-being ol'the children. While in the presence ol'the children. neither parent shall make. or permit any other person to make. any remarks or do anything tyhich could in am Way be construed as derogatory or unconyplintentar to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. The parents shall communicate directly with one another concerning any parenting issues requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule. %\ hich may Isom time to time become necessary. Gash parent shall provide the other with it current telephone number and address Im contact. kVith regard toanyemergency (fee isions tyhich must be made. the parent with physical custody ot'the children at the time shall be permitted to make the decision necessitated by the emergency yyithout consulting the other parent in advance. I-lotyeyer. the parent with physical custody making an emergency decision shall inform the other ol'the emergency and consult with her/him as soon as possible. Day-to-day decisions of a routine nature. including those relating to medical care. shall be the responsibility ol'the parent haying physical custody at the time. Each parent shall be entitled to complete and fill information from any doctor. dentist and/or teacher and have copies of any reports given to them as a parent. Such documents include medical reports and academic and school report cards. Both parents may. and are cncouragal to, attend school conferences and activities. as their schedules permit. Both parents' names shall be listed with the school. however. it will be NIOTI IHR's primary responsibility to provide PATIiI R with copies of report carats and all notifications ol'majorschool events. 3. The parents agree that they shall share physical custody of the minor children. The primary residence of the children shall he "it W11111R. ;. Ise nmenns agree that FA'fl IFR shall have custody lions Saturday at noon until Sunday, at 9:00 p.nl. each %%cck. except. hoyyewcr. that %U fl IER shtdl have the opportLill ity to spend it wveckend vvitl the children Ocry six ((,) N%ccks. or as otherN%ise agreed by the parents. Nyith seventy- two (72) hours notice to FATI]FR. In the event that the children do not have school on a Monday lollowing FATI 11'.R's yweckeIId. excluding the major' holidays herein. the parents agree that FATHER shall have custody 10111 Saturday at noon until Nlonday at 3:00 p.nt. 4. The parents agree that the li 110%ving holidays shall be alternated bemcen then each year: Easter, Memorial Day. the Fourth of July. Labor Day and Thanksgiving. The hours shall be front 10:00 a.m. until 5:00 p.m. unless otherwise agreed by We parents. In 2000 and in all even years thereaRm \40lliER shall have luster. the fourth ofJuly anti Thanksgiving. and Mn IER shall have N/l ntorial Day and labor Day. In 2001 and in all Odd years thereafter. I:AI IIER shall have luster. the fourth of.luly and Thanksgiving'. and X101HER shall have DAcorodul Day and Labor Day. >. M OTT TER and FATHER agree that they 01011 alternate Christmas each year. In 2000 and in all even years therealler. NNYMER shall have from 9:00 P-111-011 Christmas Eve until 9:00 p.m. on Christmas Day. In 2001 and in all odd years thereafien FKM MR shall have from 9:00 p.m. on Christmas Eve until 9:00 p.nl. on Christmas Day. 6. The parents agree that FATI IER shall have the minor children on father's Day and yum mil. shall have the minorchildren on \totlicr*s Day. I'IIC hours shall he Iron 10:00 a.nt. until 910 p.m, Lill ICSS otherwise agreed by the parents. 7. The parents agree that each shall have three ( 3) weeks ol'summer custody with the minor children each year. These weeks need not lie taken consecutively. \IOTI IIiR and PATI IER shall give each olhcr written notice of her/his chosen period of Sumner custody by May 1 S"bfcach year. il'possible. In the event that both parentschoose the same week(s) of summer custody. the parent who gives first notice shall prevail. S. Both parents agree that they shall each have the opportunity to see the minor children on their birthdays. Whichever parent does not have custody on the children's birthdays shall have two (Z) hours i I'that day is a school day. and IbUr (d) hours if that day is not a school day. The specific tinges shall be agreed upon by the parents. In addition. the parents shall have the opportunity' to see the minor children on their own birthdays. The tunount ol'time and the specific tines shall be agreed upon by the parents. 9. MOTI IER and h'ATI IF R agree that the residence of the minor children shall remain in Cumberland County. Pennsylvania unless othencisc agreed by the parents in writing or by further Order ol'Court. 10. "1'hc parents agree that whenever the minor children arc taken out ol'the Conunomcr<dth of Pcnusylvania. at (cast one (I ) week prior to the trip the parent removing them must advise the other and. if it is an overnight visit. provide the other parent with a telephone number and address for contact. Under no circumstances shall the ininorchi Idren be removed Irons the United States without writtenagrecnhent ol'hotlh parents or fitrtherOrder ofC'ourt. The parents agree that neithershaII apply for ncwpassports lorthechildren orrenew the children's current passportswithout written agrecnhent of hoth parents or fti then Order ol'Court. 11. LMOTI IER and PATI IFR agree that the schedules Iorall holidays. vacations and special occasions shall take priority over the usual weekly schedule. 13. Both parents agree to permit reasonable telephone access between the Children and the other parent. The children shall he permitted reasonable telephone access to place Calls u0 each or their parents while they are with the other. Both parents shall provide the other kith it current telephone nun0bcr and address at all times. 13. Bolt parents agree that, by their nu« wl consenm a revised SCIMIL le may be agreed upon bel0vccit them fir and in the hest interests or the ntinorc wri. 14. The parents agree that this Agreement shall be submitted tx> the Court orConunon Pleas urCumherland C'ouriq% Pennsylvania Rw approval and Ar entry Oran Order awarding custody and partial custody as set Ibrth herein. and the parents hereby request that this I lunorable Court enter such an Order. IN WITNESS JVII REOF. the parties haveexecuted this Stipulation 1101- 8na'y 01'a Custody Order on the date indicated below. 1 -- ? ? j i ; 'J ,t..?C/. -- Date 1Viutess \1'II.I.IAM SAVAC ' , 2-;; Date witness' ?' P.ILFFN1.SAVAGF JAN 2 4 2000 f/ L"ILELN P. SAVAGE. IN TI11 COUIt'f 017 COM\-ION PLEAS OP Plaintiff ClJ\-11313RLAND COUNTY. PIiNNSYLVANIA CIVIL ACTION - LAW WILLIANI SAVAGE, NO. 99-G759 CIVIL Defendant IN CUSTODY COURTORDER C'r AND NOW, this J day of January, 2000, the Conciliator having appeared for a Custody Conciliation Conference and the parties having advised the Conciliator that they have submitted a Stipulation to the Court for a Court Order, the Conciliator relinquishes jurisdiction. BY THE COURT. (v ?Ad Flubert Y. Gilroy, -squire _ o, ?' '- ' ,1' ; - c•: - C: _ :.? ?? EILEEN P. SAVAGE IN TIII: COURT OP COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 99-6759 CIVIL ACTION LAW WILLIAM SAVAGE DEFENDAN'r IN CUSTODY O MER OF COURT AND NOW, Wednesday, Mar 08, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Ilubert X. Gilroy, Esq, the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on 'T'hursday, May 23, 2002 at 9;30 Ai11 fora Pre-clearing Custody Conference. At such conference, an efl'ort 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 ofa 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 THE COURT, By: Est Hubert X droy?_ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act 01'1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business beliore the court, please contact our office. All arrangements must be made at (cast 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 MTORNEY AT ONCE. IF YOU DO NOT HAVE AN A77ORNIiY OR CANNOT AFFORD ONE, GO TO OR TELEPI ZONE TIIE OFFICE SE I' FORTH BELOW TO FIND OUTWIIERE YOU CAN GI 1' LIiGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 'T'elephone (717)249-3166 > 7 G?GIr? r' D? 57 c MARTSON DEAROORFF WILLIAMS & OTTO m DW&O TEN PAST HR:11 STREET CARLISLE. PENNSYLVANIA 17013 EILEEN P. SAVAGE, PI ainti ff/Respondent WILLIAM SAVAGE, Defcndanl/Petitioner per, (? MAY 0 2 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTY, PENNSYLVANIA NO. 99-6759 CIVIL ACTION - LAW IN CUSTODI' ORDER OF COUR"I' AND NOW,this_dayof ,nponconsideralionofthealtachcdComplaint, it is hereby directed that the parties and their respective counsel appear before , tine conciliator, at on the _ day of , at m. for a Pre-Hcaring 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 riiveorolder may also be present at the conference. Failure to appear at tine conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act or 1990. For infor-niation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements nttlst be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or bearing. 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 r I I IJS Un I M 11A.(k.4 ...... it '1sl I'j, (.111d GI 1012 a145 13 AM ko-- U!'110: u: 58 IV Pm I ?aH I t I I j EILEEN P. SAVAGE, Plaintil?l%Respondcnt WILLIAM SAVAGE.., Dclcndant/Pclitioncr IN TI IF COURT Or C MNION PLEAS OF CUMBERLAND C'OUNT'Y, PENNSYLVANIA NO. 99-6759 CIVIL ACTION - LAW IN CUSTODY DEFENDANTS PL:TITION TO CHANGE CUSTODY AND NOW, comes the Dclcndant, \Villiam Savage, by and through his attorneys, NIARTSON DEARDORIT NILLIANIS & OTTO. and tiles this Pclition as follows: Defendant William Savage (hereinafter"Pclitioncr"ism adult individual whoresides at S East High Street, Apt. SA, Carlisle, PA 17013. 2. Plaintiff Eileen P. Radtke, (hereinafter "Respondent") is an adult individual who resides at 105 West Butler Street, Mount I folly, PA 17065. 3. The parties are the parents of'. Victoria E. Savage Cameron 11. Savage Alexandra NI. Savage Liam G. Savage Born December 20, 19SS Born IDJay 27, 1992 Born June 29, 1993 Born November 5, 1995. 4. On January 10, 2000, this Courtcntcrcd an OrdcrofCustodybased upon a Stipulation of Custody dated January 7, 2000 granting shared legal custodyofthechildren between the parties, with Respondent having primary physical custody of the children, and Petitioner having temporary physical custody of the children, a copy of each is attached hereto and marked respectively as Exhibit "A" and Exhibit "B." 5. From Tuesday, March 26, 2002 to the present, Petitioner has had primary physical custody Of tile oldest child, Victoria E. Savage. 6. Petitioner believes that Victoria would benclit front being in his care. WI-III'REI'ORE, petitioner prays your Honorable Court to issue an Order amending the Stipulation of January 7, 2000 wherein directing that he has primary physical custody of the child, Victoria E. Savage and Respondent shall have partial physical custody as the parties may agree. The balance of the January 7, 2000 Stipulation would remain in effect. N,IAR'I'SON DEARDORFI: WILLIAMS & OTTO Thomas J. willi?I ,Esquire I'm East High street Carlisle. PA 17013-3093 (717) 343-3341 Attorneys for Defendanpetitioner William Savage Date: JAN .t U [uUp, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW EILEEN P. SAVAGE, Plaintiff V. WILLIAM SAVAGE, Defendant AND NOW, this f!,- day of No. 99-6759 Civil Term IN CUSTODY -Z6, upon consideration of the attached Stipulation for Entry ofa Custody Order, IT 1S HEREBY ORDERED AND DECREED that the terms thereof are approved and that custody and partial custody are awarded as set forth in the Stipulation with the same force and effect as if the same had been decreed by the Court following an Evidentiary Hearing. BY THE COURT: 7 IT u.:0 I110 zeal of said cu:t Thid..1.>! }h... dy-, of .: rsultsrr ^A" . .,t ny hand sle, Pa. IN THE-COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW EILEEN P. SAVAGE, Plaintiff V. WILLIAM SAVAGE, Defendant No. 99-6759 Civil Term IN CUSTODY STIPULATION FOR ENTRY OF CUSTODY ORDER The parties to this action, EILEEN P. SAVAGE (hereinafter referred to as "MOTHER"), and WILLIAM SAVAGE, (hereinafter referred to as "FATHER"), desiring to amicably settle and resolve all outstanding issues concerning custody and partial custody with respect to the minor children: VICTORIA E. SAVAGE, born December 20,1988; CAMERON H. SAVAGE, bom May 27, 1992; ALEXANDRA M. SAVAGE, bom June 28, 1993; and LIAM G. SAVAGE, bom November 5,1995, hereby stipulate and agree to the entry of an Order of Court awarding custody and partial custody of VICTORIA, CAMERON, ALEXANDRA and LIAM as follows: 1. The parents agree that they shall share legal custody of the minor children. All major decisions affecting the children's growth and development shall be made by the parents after discussion and consultation with each other and with a view towards obtaining and following an harmonious policy in the children's best interests. These decisions include those regarding medical, religious and educational matters. Each parent agrees to keep the other informed of the progress of the children's educational and social adjustments. 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. Both parents agree to EXHtL'TT "n" give support to the other in their role as "parent" and to take into account the concerns of the other for the physical and emotional well-being of the children. While in the presence of the children, 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 express duty of each parent to uphold the other parent as one whom the children should respect and love. The parents shall communicate directly with one another concerning arty parenting issues requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule, which may from time to time become necessary. Each parent shall provide the other with a current telephone number and address for contact. With regard to any emergency decisions which must be made, the parent with physical custody of the children at the time shall be permitted to make the decision necessitated by the emergency without consulting the other parent in advance. However, the parent with physical custody making an emergency decision shall inform the other of the emergency and consult with her/him as soon as possible. Day-to-day decisions of a routine nature, including those relating to medical care, shall be the responsibility of the parent having physical custody at the time. Each parent shall be entitled to complete and full information from any doctor, dentist and/or teacher and have copies of any reports given to them as a parent. Such documents include medical reports and academic and school report cards. Both parents may, and are encouraged to, attend school conferences and activities, as their schedules permit. Both parents' names shall be listed with the school, however, it will be MOTHER'S primary responsibility to provide FATHER with copies of report cards and all notifications of major school events. 2. The parents agree that they shall share physical custody of the minor children. The primary 'residence of the children shall be with MOTI IER. 3. The parents agree that FATHER shall have custody from Saturday at noon until Sunday at 9:00 p.m. each week, except, however, that MOTHER shall have the opportunity to spend a weekend with the children every six (6) weeks, or as otherwise agreed by the parents, with seventy- two (72) hours notice to FATHER. In the event that the children do not have school on a Monday following FATHER's weekend, excluding the major holidays herein, the parents agree that FATHER shall have custody from Saturday at noon until Monday at 3:00 p.m. 4. The parents agree that the following holidays shall be alternated between them each year; Easter. Memorial Day, the Fourth of July, Labor Day and Thanksgiving. The hours shall be from 10:00 a.m. until 8:00 p.m. unless otherwise agreed by the parents. In 2000 and in all even years thereafter. MOTHER shall have Easter, the Fourth of July and Thanksgiving, and FATHER shall have Memorial Day and Labor Day. In 2001 and in all odd years thereafter, FATHER shall have Easter, the Fourth of July and Thanksgiving, and MOTHER shall have Memorial Day and Labor Day. 5. MOTHER and FATHER agree that they shall alternate Christmas each year. In 2000 and in all even years thereafter, MOTHER shall have from 9:00 p.m. on Christmas Eve until 9:00 p.m. on Christmas Day. In 2001 and in all odd years thereafter, FATHER shall have from 9:00 p.m. on Christmas Eve until 9:00 p.m. on Christmas Day. 6. The parents agree that FATHER shall have the minor children on Father's Day and MOTHER shall have the minor children on Mother's Day. The hours shall be from 10:00 a.m. until 8:00 p.m. unless otherwise agreed by the parents. 7. The parents agree that each shall have three (3) weeks of summer custody with the minor children each year. These weeks need not be taken consecutively. MOTHER and FATHER shall give each other written notice of her/his chosen period of summer custody by May 15" of each year, if possible. In the event that both parents choose the same week(s) of summer custody, the parent who gives first notice shall prevail. 8. Both parents agree that they shall each have the opportunity to seethe minor children on their birthdays. Whichever parent does not have custody on the children's birthdays shall have two (2) hours if that day is a school day, and four (4) hours if that day is not a school flay. Tire specific times shall be agreed upon by the parents. In addition, the parents shall have the opportunity to see the minor children on their own birthdays. The amount of time and the specific times shall be agreed upon by the parents. 9. MOTHER and FATHER agree that the residence of the minor children shall remain in Cumberland County, Pennsylvania unless otherwise agreed by the parents in writing or by further Order of Court. 10. The parents agree that whenever the minor children are taken out of the Commonwealth of Pennsylvania, at least one (I ) week prior to the trip the parent removing them must advise the other and, if it is an overnight visit, provide the other parent with a telephone number and address for contact. Under no circumstances shall the minor children be removed from the United States without written agreement ofboth parents or further Order of Court. The parents agree that neither shall apply for new passports forthe children or renew the children's current passports without written agreement of both parents or further Order of Court. 11. MOTHER and FATHER agree that the schedules for all holidays, vacations and special occasions shall take priority over the usual weekly schedule. r2. Both parents agree to permit reasonable telephone access between the children and the other parent. The children shall be permitted reasonable telephone access to place calls to each of their parents while they are with the other. Both parents shall provide the other with a current telephone number and address at all times. 13. Both parents agree that, by their mutual consent, a revised schedule maybe agreed upon between them for and in the best interests of the minor children, 14. The parents agree that this Agreement shall be submitted to the Court of Common Pleas of Cumberland County, Pennsylvania for approval and for entry of an Order awarding custody and partial custody asset forth herein, and the parents hereby request that this Honorable Court enter such an Order. IN WITNESS WHEREOF, the parties have executed this Stipulation for Entry ofa Custody Order on the date indicated below. yriL 1 I )UU 'N All, Date Veit toss WILLIAM SAV ! 7?;icca x/11 r? ;c ?l,':f ;Gl ' C ` li : or t a LF Date Witness i EILEEN P. SAVAGE J \ I?RIPI('ATInN The foregoing Petition to Modify is based upon in f arntation which has been gathered by illy counsel in the preparation of the lawsuit. The language of the document is that ofcounwl and not my own. I have read the document and to the extent that it is basal upon information which I have given to my counsel, his mIc and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel. I have relied upon counsel in making this verification. This statement and ved fication are made subject to the penalties of IS Pa. C.S. Section 4904 relating to unsworn fdsification to authorities, which provides that if I make knowingly false averments, I maybe subject to criminal penalties. Mlliant R. Savage CIiR'I'11? ICA'I'F. Oh Sb:RVICI: 1, Tricia D. Lckeoroad, an authorized agent for Nlartson Deardorff MVilliams & Otto, hereby certify that a copy oflhe foregoing Pelition to 1%4odify Custody was served this ihuc by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ryan .tones, Esquire Nlid Penn Legal Services S Irvine Row Carlisle, PA 17013 \IARTSON DEARDORPP WILLIANIS S OTTO Y t "Irtcm D. Lckcoroad Ten Gast 1-ligh Street Carlisle, PA 17013 (717) 243-3341 Dated: - I 301 ZAoZ ,; ?1 0 -.: ? a -? p T ?? ? ? J •• \ Q ^j ' ? ... r ^y I ,_ AIARTSON OEAR00111 WILLId A4 k OTTO w'`XI&O TEN EAST HI4n STRFE CARLISLE, FENNSI'P'ANIA 17013 EILEEN P. SAVAGE, Plainti fl7Rcspondent WILLIAM SAVAGE, Defcndant/Petitioncr IN THE. COURT OF CO\-1\tON PLEAS OF CUNIl3ERLAND COUNTY, PENNSYLVANIA NO. 99-6759 IN CUSTODY PRAECIPE -r0 THE PROTHONOTARY OF CUNIBERLAND COUNTY: CIVIL ACTION - LAW Please file the attached Affidavit of Service Rvith regard to Defendant's Petition for Special Relief Filed May 22, 2002. NIARTSON DEARDORFF LVILLIANIS R OTTO Tle m10 . Willia n ,Esquire "fen Easl I ligh SC et Carlisle, Pr\ 17013-3093 (717) 2=13-33=11 Attorneys for Defcndant/Pelitioner William Savagc Date: May 22, 2002 AFFIDAVIT OF SE'RVICI? AND NOW, this 22"" day of M, D Q2. L Itch D. Eckenroad, an :nnlurrized agent Wr Monism Deardorff \1'illiams 61 Otto, hereby certHY that a copy of tic Ibregoing Petition for Special Relief yeas sen ed this dote by depositing scone in the Post Office at (arlisle, PA, first class snail, postage prepaid, addressed as Mow: Rebecca Hughes, Inquire 60 West Pornfirt Street Carl isle. 4% 1701 3 Joan Cm'cy, Esquire MullInn Legal ScrAces S In ine Row Carlisle, PA 17013 Ms. Eileen Radike 105 West Butler Street Mount Holly, PA 17065 Mr. William Sa%,agc S East Fligh Street Apt. SA Carlisle. PA 17013 MARTSON DEARDORPI' WILLIA:.MS & OT TO rcyia D. fckenroad tin East Iligh Street Carlisle, PA 17013 (717) 213-3341 Swom and subscribed to me this ,)-,"a day of \9ay, 2002. NOTARIAL SEAL BARBARA S. W ILDAY, Notary Publlc , Camwe Bev, Cumberload rrtY MY Commission Expiros Feb. 18, 2006; CERTIFfCATE UI SI•:Itv ICI? 1, Tricia D. Eckenroad, an ;unhorized agent Ibr Martson Dcardod'I'WiIIiams & Otto, hereby certify that a copy of the foregoing Praccipc was screed this date by dcpositin same in the Post Office !It Carlisle, PA, first class moil, postage prepaid, addressed as Iollows; Rebecca Iiughes, Esquire 60 West Pomfret Street Carlisle, PA 17013 ,loan Carey, Esquire NIidPenn Legal Sen ices S (nine Row Carlisle, PA 17013 Nis. Eileen Radtke 105 West BLltICr Strcct Mount 1 lolly, PA 17065 Mr. William Sa%asc S East Iii.-Ii Street Apt. SA Carlisle, PA 1701 3 NIARTSON DEARDORPP WILLIANIS & OTTO C Hera D. Eckcnroad Ten East High Street Carlisle, PA 17013 (71 7) 243-3311 Dated N1 ay 32, 2002 . 'r 9 2002 EILEEN 1'. SAVAGE, a/k/a : IN THE COURT OF COM'lON PLEAS OF I:ILF.I?N I'. RAD'rKE, : CUMBERLAND COUNTY, I'I:NNSYLVANIA Plaintiff . CIVIL ACTION - LAW WILLIAM SAVAGE, : NO. 99-6759 CIVIL Derend:mt : IN C.USTOOv COURT ORDER AND NOW, this 7 f6? da%, of Nla)•, 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 'This Court's prior Order or JanuarN. 10, 2000 is vacated 2. The Father, William Savage, shall have legal and physical custody of Victoria E. Savage, born December 20, 1988; Cameron H. Savage, born May 27, 1992; Alexandra IN1. Savage, born June 29. 1993; and Liam G. Savage, born November 5, 1995. This Order is a directive to the Mother to deliver custody of the mentioned minor children to the Father immediately, and this Order further authorizes appropriate law enforcement authorities to enforce the Order and to render all lawful assistance to the Father, mad/or the Father's attorney or designee, to deliver the minor children to the physical possession ofthe Father. 3. The 'Mother, Eileen F. Savage a/k/a/ Eileen P. Radtke, when located, legal counsel for the Father shall immediately make arrangements to serve a copy of this Order and the attached Custody Conciliation Report on the Mother. Y .? 4. The Nlother nun. at anv time retain counsel and have counsel contact the conciliator directly to schedule another custtuh conciliation conference which will he scheduled wilhin a few days of any' initial contact. BY THE COURT. cc: `T'homas .1. Williams, Esquire /Elleen P. Savage 105 Nest Buller Street Mt. Holly Springs, PA 17065 3 i .1. VesleyOler.(h'. Cam/ l? t3 C7 7 E'ILE,EN 1'. SAVAGE, a/k/a EILF.EN 1'. RADTKE' Plaintiff V WILLIAM SAVAGE., Defendant 111-ior.ludge:.1. Wesley Oler, .tr. IN'I'lll? COUR'1'OI? COAL\ION I'I,I?.AS O1? CU?IRIiRL:AN000UN'I'1',I'1?NNSI'1,A'ANIA CIVI L ACTION - LAW NO.99-6759 CIVIL IN CUS'T'ODY CONCILIATION CONFI RI_NCE SUMMARY REPORT IN ACCORDANCE' WITH THE, CUMBERLAND COUNTY CIVIL. RULE OF PROCF,DURE 1915.3-80b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Victoria G. Savage, horn December 20, 19S8; Cameron 11. Savage, born May 27, 1992; Alexandra NI. Savage, born .hoe 29. 1993; and Liam G. Savage, born November 5, 1995. 2. A Conciliation Conference was held on May 24, 2002, with the following individuals in attendance: 'kill Savage, with his counsel, Thomas J. Williams, Lsquire. The The Father, Willi, Mother did not attend. Attorney Williams had served Legal Services with notice of the hearing in that Legal Services was still attorney of record. Attorney Williams was notified by Legal Services that they no longer represented the Mother. Attorney Williams also had served Attorney Rebecca Hughes who had contacted Attorney Williams suggesting she may be representing the Mother. Also, written notice of the custody conciliation conference was sent to the Mother by regular nail by Attorney Williams at her Alt. Holly Springs address. 3. 'there was a Stipulation entered by the parties in .lanua?ti of 2000 whereby the Mother was provided primary physical custody of the four minor children. The Stipulation provided Father to have various periods of temporary custody including Saturday to Sunday each week and other various times. d. In March 2002, the minor child 1'ic•loria came to live with Father ant] fills been living with lather since that lime. Father filed a petition to change custoch• relating to Victoria on May 1, 2002. Subsequent to that filing. Mother then delivered custody of Cameron to the Father on or about Man 5, 2002 at which time Mother suggested to lather that she was going to Chicago %%ilh her new husband and the two minor children to "handle an Estate for the Mother's new husband."Mother suggested to the Father and to school officials dial the ;\lother would be back in five days. 5. Mother has not returned ft•ont Ihis trip to Chicago. She has left messages with the Father suggesting various reasons why she has not returned. However, circumstances at the Mother's home in Nit. Ifoll. Springs suggest the Mother may have vacated the propert,% and left the area permanently. 't'here was apparently a yard sale shortly before Mother left. Also, Father contacted the bit. Holly Springs police who went into file [ionic and verified that some furniture still is in the house, but that it is evident that a fair amount of belongings have been taken. Father understands that ;Mother left the Carlisle area with a vehicle and a U-Haul. Father has concerns that ;\lother may be attempting to remove the two minor children from Pennsylvania on a pernument basis. ;\lother is a British citizen, and Mother in the past took the children to England without approval of the court at which time Father was required to expend various sums of money to get an order returning the children back to the United Slates. 6. Father filed a Petition for Special Relief with file court on May 23, 2002 requesting an Order of Custody for all finu• children. That Petition for Special Relief has also been referred to the custody conciliator. 7. In light of the fact Thal Father has custody of' the two older children and in light of the circumstances related to the conciliator al the conference, the conciliator reconuuauls the entry of an order in the form as attached. DATE. Hubert X. Gilroy, Esquire- %r Custody Conciliator MARTSON DEARDORFF WILLIAMS K OTTD MDW?O IM,OUInnIG • Nm<E • Mm w,n TEN EAST Hiwi STREET CARLISLE. PENNSYLVANIA 17013 M ej2 3 200'2 EILEEN P. SAVAGE, P I ai n t i ff/Resp on dcn t WILLIAM SAVAGE, Defendant/Petitioner IN THE couR•r OF COMMON PLEAS Or CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6759 CIVIL ACTION - LAW IN CUSTODY 0RDE.R AND NOW, this -2 Iay of May, 2002, in accordance with the foregoing Petition for Special Relief, Respondent, Eileen P. Savage, is Ordered and Directed to appearwith Alexandra NI. Savage, born June 29, 1993 and Liam G. Savage, born November 5, 1995 in Courtroom No. Cumberland County Courthouse, on the /Qtit dayof ?'_?.?ri 2002 at //-!d 4,111. tJ_ 2S '? ?OthS J!!-LC1LYa? nv • , %r ont ID-r 51 ? F! ILLS LLWV'11.L 6C?. r.i .c1.l.1::- aa]I EILEEN 11. SAVAGE, Plaint i ft7Rcspottdcnt WILLIAM SAVAGE, Defendant/Pct i tioncr IN TI 11; COURT OF COMMON PI.l:AS 01: CUMBL-BLAND COUNTY, PENNSYLVANIA NO. 99-6759 CIVIL ACTION - LAW IN CUSTODY DEFENDANT'S PETITION FOR SPECIA1. RELIEF AND NOW, conies the Dclendant, William Savage (hereinafter, "1 :athcr'), by and through his attorneys, MARTSON D13AIZDORFF \VILLIANIS S OTTO, yid tiles Ibis Petition as follows: Petitioner is Father, William S:n:agc, an adult individual who resides at S East I ligh Street, Apt. SA, Carlisle, PA 17013. 2. Respondent is Eilcen 11. Radtke, (hcrcinatler, "Mother") an adult individual who has been residing at 105 West Butler St-M. A9ount Holly, PA 17065 for the past few gears. 3. There arc lourchildren who arc subject to the Court's Custotiy0rder. A copyof the most recent Custody Order, dated .1anuary 10, 2000 and the Stipulation for Envy of Custody Order. is attached hereto as Exhibit "A." 4. On Sunday, Nlav5, 2002, Mothcrlcli the two older children (Victoria E. Savage, born December 20, 1988 and Cameron 1-1. Savage, born May 27, 1992) with Father and took the two younger children (Alexandra M. Savage, horn June 29, 1993 and Liam G. Savage, born November 5, 1995) with her ostensibly to a funeral in Chicago. 5. Father has not seen or heard from Mother or the two younger children since Sunday, kfay 5, 2002. He has no way to get in touch with them. He doesn't know who they arc with or where they arc staying. The children have not been in school. 6. N'lother's house al the above address appears to have been boarded up and empty- Neighbors report seeing a U-Haul being used to remove the contents at about the time.Mother was leaving for the "funeral" in Chicago. 7. Mother is a British citizen and has preciously and illegally taken the children back to Britain. II was only after great (rouble and e\pcnse that Father was able to recover them by means of the Hague Convention on abducted children. S. FatI I crhas[lot had It ismoyotntgcrcI I iId renli6rthepcriodsofcusto (fyzmardedto I I int since Sunday. May, 5, 2002 by Order of.L•mu;uy 10, 1UTAL attached hereto as Exhibit -A.- "'HERI:PORE, PetilionerPalher pr;cvs YOU' 1-101101'ahlc ('ourt to Order and Direct Respondent/iMother to produce Alexandra Sage and Liam Savage, to explain where they were, their plans and give reason why she should not be held in contempt Ibr violation of the Order of January 10, 2000. NIARTSON DEARDORFF WILLIA\-IS & OTTO fhonrasJ. 1Nilliams I. quire fen East high SII'LC Carlisle, PA 17013-3093 (71 71 243-3341 Attorneys liar Dcfcndant/Pctitioner "'illiant Savage Date: Nlay 22, 2002 Exhibit A JAN 1 U ZUV I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW EILEEN P. SAVAGE, Plaintiff No. 99-6759 Civil Term V. WILLIAM SAVAGE, Defendant AND NOW, this Ic day of IN CUSTODY attached Stipulation for Entry of a Custody Order, J= upon consideration of the HEREBY ORDERED AND DECREED that the terms thereof are approved and that custody and partial custody are awarded as set forth in the Stipulation with the same force and effect as if the same had been decreed by the Court following an Evidentiary Hearing. In T.•s!..;?;?ny a.hucuf, I 'r. at my hand and the seal of said fcuir/ft Carlisle, Pa. j BY THE COURT: i EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW EILEEN P. SAVAGE, Plaintiff No. 99-6759 Civil Term V. WILLIAM SAVAGE, IN CUSTODY Defendant STIPULATION FOR ENTRY OF CUSTODY ORDER The parties to this action, EILEEN P. SAVAGE (hereinafter referred to as "MOTHER"), and WILLIAM SAVAGE, (hereinafter referred to as "FATHER"), desiring to amicably settle and resolve all outstanding issues concerning custody and partial custody with respect to the minor children: VICTORIA E. SAVAGE, born December 20,1989; CAMERON H. SAVAGE, born May 27, 1992; ALEXANDRA M. SAVAGE, born June 28, 1993; and LIAM G. SAVAGE, born November 5, 1995, hereby stipulate and agree to the entry of an Order of Court awarding custody and partial custody of VICTORIA, CAMERON, ALEXANDRA and LIAM as follows: 1. The parents agree that they shall share legal custody of the minor children. All major decisions affecting the children's growth and development shall be made by the parents after discussion and consultation with each other and with a view towards obtaining and following an harmonious policy in the children's best interests. These decisions include those regarding medical, religious and educational matters. Each parent agrees to keep the other informed of the progress of the children's educational and social adjustments. Each parent shall have the duty to notify the otherof any event or activity that could reasonably be expected to be of significant concern to the other parent. Both parents agree to give support to the other in their role as "parent" and to take into account the concerns of the other for the physical and emotional well-being of the children. While in the presence of the children, 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 express duty of each parent to uphold the other parent as one whom the children should respect and love. The parents shall communicate directly with one another concerning any parenting issues requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule, which may from time to time become necessary. Eachparent shall provide the other with a current telephone number and address for contact. With regard to any emergency decisions which must be made, theparent withphysical custody of the children at the time shall be permitted to make the decision necessitated by the emergency without consulting the other parent in advance. However, the parent with physical custody making an emergency decision shall inform the other of the emergency and consult with her/him as soon as possible. Day-to-day decisions ofa routine nature, including those relating to medical care, shall be the responsibility of the parent having physical custody at the time. Each parent shall be entitled to complete and full information from any doctor, dentist and/or teacher and have copies of any reports given to them as a parent. Such documents include medical reports and academic and school report cards. Both parents may, and are encouraged to, attend school conferences and activities, as their schedules permit. Both parents' names shall be listed with the school, however, it will be MOTHER'S primary responsibility to provide FATHER with copies of report cards and all notifications of major school events. 2. The parents agree that they shall share physical custody of the minor children. The primary 'residence of the children shall be with MOTHER. 3. The parents agree that FATHER shall have custody from Saturday at noon until Sunday at 9:00 p.m. each week, except, however, that MOTHER shall have the opportunity to spend a weekend with the children every six (6) weeks, or as otherwise agreed by the parents, with seventy- two (72) hours notice to FATHER. In the event that the children do not have school on a Monday following FATHER's weekend, excluding the major holidays herein, the parents agree that FATHER shall have custody from Saturday at noon until Monday at 3:00 p.m. 4. The parents agree that the following holidays shall be alternated between them each year; Easter, Memorial Day, the Fourth of July, Labor Day and Thanksgiving. The hours shall be from 10:00 am. until 8:00 p.m. unless otherwise agreed by the parents. In 2000 and in all even years thereafter, MOTHER shall have Easter, the Fourth of July and Thanksgiving, and FATTIER shall have Memorial Day and Labor Day. In 2001 and in all odd years thereafter, FATHER shall have Easter, the Fourth of July and Thanksgiving, and MOTHER shall have Memorial Day and Labor Day. 5. MOTHER at.- FATHER agree that they shall alternate Christmas each year. In 2000 and in all even years thereafter, MOTHER shall have from 9:00 p.m. on Christmas Eve until 9:00 P.M. on Christmas Day. In 2001 and in all odd years thereafter, FATHER shall have from 9:00 p.m. on Christmas Eve until 9:00 p.m. on Christmas Day. 6. The parents agree that FATHER shall have the minor children on Father's Day and MOTHER shall have the minor children on Mother's Day. The hours shall be from 10:00 a.m. until 9:00 p.m. unless otherwise agreed by the parents. i 7. The parents agree that each shall have three (3) weeks of summer custody with the minor children each year. These weeks need not be taken consecutively. MOTHER and FATHER shall give each other written notice of her/his chosen period of summer custody by May 15'h of each year, if possible. In the event that both parents choose the same week(s) of summer custody, the parent who gives first notice shall prevail. 8. Both parents agree that they shall each have the opportunity to seethe minor children on their birthdays. Whichever parent does not have custody on the children's birthdays shall have two (2) hours if that day is a school day, and four (4) hours if that day is not a school day. The specific times shall be agreed upon by the parents. In addition, the parents shall have the opportunity to see the minor children on their own birthdays. The amount of time and the specific times shall be agreed upon by the parents. 9. MOTHER and FATHER agree that the residence of the minor children shall remain in Cumberland County, Pennsylvania unless otherwise agreed by the parents in writing or by further Order of Court. 10. The parents agree that whenever the minor children are taken out of the Commonwealth of Pennsylvania, at least one (1) week prior to the trip the parent removing them must advise the other and, if it is an overnight visit, provide the other parent with a telephone number and address for contact. Under no circumstances shall the minorchildren be removed from the United States without written agreement of both parents or further Order ofCourt. The parents agree that neither shall apply fornewpassports for the children or renew the children's current passports without written agreement of both parents or further Order of Court. 11. MOTHER and FATHER agree that the schedules for all holidays, vacations and special occasions shall take priority over the usual weekly schedule. r2. Both parents agree to permit reasonable telephone access between the children and the other parent. The children shall be permitted reasonable telephone access to place calls to each of their parents while they are with the other. Both parents shall provide the other with a current telephone number and address at all times. 13. Both parents agree that, by their mutual consent, a revised schedule maybe agreed upon between them for and in the best interests of the minor children, 14. The parents agree that this Agreement shall be submitted to the Court of Common Pleas of Cumberland County, Pennsylvania for approval and for entry of art Order awarding custody and partial custody as set forth herein, and the parents hereby request that this Honorable Court enter such an Order. IN WITNESS WHEREOF, the parties have executed this Stipulation for Entry of a Custody Order on the date indicated below. Date Wi ess WILLMM SAVAt; Date Witness % EILEEN P. SAVAGE VFRIPICATION The foregoing Petition forSpecial ReIiefis based upon in(oI Inatioil which has been gathered bynlycounscli]I thcprcPau;uiOil ofthelawsuiI. Thclantg1111"eofthedocumentis thatol'counseland not 111yown. I have read the document and to the extent that it is based upon inlin-mution Which I have given to mycounsel, it is true and correct to ibc best ofnty knowledge, information and belief. To the extent that the content of the document is that of counsel. I KlVe relied upon counsel in making this verification. 'this statement and verification arc made subject to the penalties of IS I'll. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. William Savage G'` CERTIFICATE. 01, SFR1'ICI- 1, Tricia D. Lckenroad, an authorized agent lot. Nlartson Deardorff Williams S, Otto, hereby eertilj, that a copy of the foregoing Petition for Special Relief was served this (late by depositing same in the Post Off ice at Carlisle, PA, first class mail, posta,,c prepaid, addressed as follotvs: Rebecca Hughes, Esquire GO Nest Pomfret Slrccl Carlisle, PA 17013 \IARTSON DEARDORFF NILLIANIS & OT-1-0 HY_ -`- nciu D. Lckc _nroad Ten Last Iligh Shcet Carlisle, PA 17013 (717) 241-3341 Dated: May 22, 2002 ?? C ? v ?- r. \ _ CL ? ?\ ?. .. `?} \ Q ?. __ I ;_ __ -_'_ lJ MARTSnN DWDORFF WILLIAMS & OTTO MEW&O INI ??IUI \n??N • Ar nnr • AtAi,twi? TEN BAST H um STRLET CARLISLE, PENNSYLVANIA 17013 EILL'EN P. SAVAGE. Plaintif I' V. WILLIAM SAVAGE, Defendant IN THE COURT O]" COLMINION PLEAS Or CUMBERLAND COUNTY, PENNSYLVAN IA NO. 99-6759 CIVI L ACTION - LAW IN CUSTODY PRAGCIPE TO THE PRO'rilONOTARY OF CUMBERLAND COUNTY: Please withdraw Defendant's Petition ter Special Relief which wits filed May 22, 2002. MARTSON DEARDORFF WILLIAMS & OTT-40 t Thomas J. Willi: s, Esquire Ten East I Iigh Street Carlisle, PA 17013-3093 (717) 2=13-33=11 Attorneys for DefcndanVPetilioncr Williarn Savage Data May 30, 2002 1, Tricia D. Gckenroad, an authorized agent fin' \ :u'tsoI I IX;u'dol-11'WiIIivus'\ Oilo, hereby certify that a copy of the foregoing I'raccipc was served Ibis date by depositing Some ill the Pose Office at Carlisle, PA, III'st class mail, postage prepaid, addt'esscd ?s III) llows: Rebecca I lughes, Esquire 60 West Ponilrct Street Carlisle, PA 17013 .loan Carey. Inquire \iidPenn Legal Services S Irvine Row Carlisle, PA 17013 Nis. Eileen Radtke 105 West 13ut1crStrcet Mount I lolly, PA 17065 \iARTSON DEARDORFF WILLIAMS &OTTO L3_vW,ia D. Gckenro:ul -? Ten Gast I ligh Street Carlisle, PA 17013 (717) 213-3341 Dated May 30, 2002 = ?:, r . ?r. ,; - ; : -, ,, .. '? ?- - ?, ?_? - EILEEN 1'. SAVAGE. IN TI[I.: COURT Op COMMON PLEAS OI' Plaintiff Ct I1\1111FRIAND COUNTY, PENNSYLVANIA N'. CI V 11, ACTI ON - LA W WILLIAM SAVAGE. Defendant NO. 99-6759 CIVIIAT'R\4 ORDFR OF COURT AND NOW. this 1 day of'.tune. 2002, upon consideration of the praccipc to withdraw Deicndant's Petition Im- Special Relicl: filed on May 3(). 2002, the hearing scheduled Ior June 10. 2002, is cancelled. BY TI IE COURT. Rebecca Hughes, Esq. 60 West Ponul'rct Street Carlisle. PA 17013 Attorney for Plaintiff Thomas.l. Williams, Esq. Ten l=ast I ligh Street Carlisle. PA 17013 Attorney Ior Defendant AV IN'I'I It-, C'Ol1R"I' OI COMMON PLEAS OF I`:ILIi1iN 11. SAVAGE ! I'L:\INI'IPI; C'U\11WRLNI) COON 1'1', PFNN51'LV:\NL\ 99-6719 CIVI1. AC]ION L:\\\' WILLIAM R. SAVAGE IN C'US'I'ODl' DITFNI)AN'I olmliR OI' COURT NOM', IYidtp-, september 23_2005--_. upon consideration or the attached Complaint. AND _ - - Gsl . the conciliator it is hereby directed thnt parties and their respective counsel appear hefori 1111ctobt.' I ilroyS ;u 9:30 AM at 4t1__ ! Fluot'• Cun11)"It "l County Cnurthnu±?, C°!rr?Ic - nn _- ---- -- tbr a I'ro-liearin_ C'usto(Ip C'unference, r\t such conference, an et rt will be made to resolve the issues in dispute; or Willis cannot be accomplished. to deline and narrow the issues to he heard he the coon. and m enter into it temporaq :a the xnt(ercnce, Pailtire to appear at the conference m:n order. All children ace lice or older ntav also be present pnrvi(Ic grou,,(Is for entry ol'a temporary or permanent order. I'he court I'rotcction from Abuse orders, hereby directs the parties to furnish any and all ccistim? Special Relict' or leer and Cuslo(I orders to the conciliator 48 boars prior to schedule(' Ilea Sp FOR TO Ili C'OUR'I. C'ustod) Conciliator 'lcas of Cumberland County is require(' by law to comply with the Americans The Court ofCommon I nd reasonable with I)isabilites Act o1.1990. For inlin'ntation about aceeesible facilities a acconutu I;uions available to disabled individuals having business before the court. please contact our ollice. All arrangements hearin; or business before the court. You must intend the schedule(' nuut be made at least 72 hours prior toany conrercnce or hearing. YOU SHOULDI-AKI: "1'I IIS 1'1'0 POUR A'I'"I ORNBY AT ONCE. IF YOU DO NOT Fly\Vf: r\N A"I"1'ORNIiI' UR Cr\\NO'I' AFFORD ONI.CiU'I'OOR'1'HLHp1I0NIi'I'11LC)FPICB SII' POR'I'li \\'FIIiRI: YOU I. III LP. 13I L0\V'I'O FIND OUT CAN GF I' LfC\ Cumberland Cotmq Bar Association 32 South lie(Ilitrd Street Carlisle, Pcans)'IVania 17013 Telephone (717)'_-19.3166 ?r? -' CV (y-GG(' ??L? %N2tX-;l1 Ile- GliLy ?C/?:CL r ,I - - y" RECEIVED SEP 20290055/ EILEEN P. SAVAGE : IN THE COURT OF COMMON PLEAS V Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 99-6759 CIVIL TERM WILLIAM R. SAVAGE, : CIVIL ACTION - LAW Defendant :CUSTODY ORDER OF COURT AND NOW, this day of 2005, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before , Esq., the Conciliator, at on the day of 2005, at .M., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary order. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Custody Conciliator 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3165 Pi r° EILEEN P. SAVAGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-6759 CIVIL TERM WILLIAM R. SAVAGE, : CIVIL ACTION - LAW Defendant :CUSTODY PETITION TO MODIFY CUSTODY i i I i I t. 1. Plaintiff is EILEEN P. SAVAGE, an adult individual, currently residing at 1837'/2. Sterretts Gap Avenue, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is WILLIAM R. SAVAGE, an adult individual, currently residing at 107 E. Northern Parkway, Baltimore, Maryland 21212-2902. 3. Plaintiff seeks custody of her children: Victoria E. Savage, born December 20, 1988; Cameron H. Savage, born May 27, 1992; Alexandra M. Savage, born June 28, 1993; and Liam G. Savage, born November 5, 1995. 4. The children have been adjudicated into legal and physical custody of the Defendant since 2002 (Exhibit 1), but in actual physical custody of Plaintiff Monday afternoon through Friday morning, and sometimes additionally, since August 30, 2005. 5. Since the end of defendant's lease on June 30, 2005, the children have resided at the residence of the paramour of defendant, in Baltimore, Maryland. 6. The relationship of the Plaintiff to the children is that of natural mother. 7. The relationship of the Defendant to the children is that of natural father. 8. The Plaintiff and Defendant were married on June 1, 1988. 9. A Complaint for Divorce was filed in Cumberland County, Pennsylvania and the divorce decree was granted in June 2000. 10. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. 11. The best interest and perrranent welfare of the children will be served by granting the relief requested for the following reasons: A. Plaintiff, mother, lives in Carlisle, Pennsylvania. B. All children go to school in the West Shore School District, Cumberland County, Pennsylvania. C. Plaintiff, mother, takes each child to the relevant school, Tuesday through Friday. D. Plaintiff, mother, picks up all children from school, Monday 11 through Thursday. E. Plaintiff, mother, lakes each child to their sports or other after- school activities. F. The youngest child, Liam Savage, has been prescribed daily medication, but defendant does not always give plaintiff mother an adequate amount of the medication for the time Liam is in his mother's care. G. Plaintiff, mother, receives no compensation from defendant for these services. H. Plaintiff, mother, has and provides adequate living and sleeping arrangements for children, including a bed for each child. I 1. Plaintiff, mother, has fulltime employment as a nurse on the daytime shift at Messiah Village in Mechanicsburg, Pennsylvania. J. Plaintiff, mother, can provide the children a stable home and social environment. K. Plaintiff, mother, can legitimately enroll children in schools in Pennsylvania. L. Plaintiff, mother, currently has no court-ordered legal or physical custody of the children. M. Defendant has no permanent residence of record. N. Defendant resides with his paramour in Baltimore, Maryland. O. Plaintiff has no knowledge of the personal/criminal history of the paramour with whom the Defendant resides. P. Children do not have adequate sleeping arrangements at defendant's paramour's house. Q. Defendant is employed on night-shift work by The Patriot-News newspaper, in Harrisburg, Pennsylvania. R. The children travel from Baltimore, Maryland to their respective schools in Cumberland County, Pennsylvania in the pre-dawn hours on Monday morning. s. The oldest child, Victoria Savage, aged 16 years, is frequently required to provide parental care to her siblings. T. The oldest child, Victoria Savage, aged 16 years, is frequently li required to prepare meals for her siblings. 12. Each parent whose parental rights to the children have not been- terminated and the person who has physical custody of the children have been named as parties to this action. No other persons are known to have or claim to have any right to custody or visitation of the children other than the parties to this action. 13. Plaintiff is unaware of any legal representation for Defendant. 14. A copy of this Petition was sent by certified mail, return receipt requested, first class, postage prepaid to the Defendant. i"I WHEREFORE. Plaintiff requests this Honorable Court grant Plaintiff's request for shared legal custody and primary physical custody of the minor children to the mother with partial physical custody with the father. Da Respectfully Submitted, TURO LAW OFFICES - /I , Richard Koch, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff ,I ?yl ?i Of 2 4 2002 EILEEN 1'. SAVAGE, a/Wa : IN 7'IIE COURT OF COMMON ('LEAS OF EILEEN P. RADTKE, : CUi ,1131:RLAND COUNTI',1'ENNSYI.VANIA Plaintiff CIVILACTION-LAW WILLIAM SAVAGE, : NO.99-1759 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this 7 Sit day of May, 2002, upon consideration of the attached Custodv Conciliation Report, it is ordered and directed as follows: 1. This Court's prior Order of Januan, 10, 2000 is vacated 2. The Father, William Savage, shall have legal and physical custody of Victoria E. Savage, born December 20, 1988; Cameron H. Savage, born May 27, 1992; Alexandra i1'I. Savage, born June 29, 1993; and Liam G. Savage, born November 5, 1995. This Order is a directive to the Mother to deliver custody of the mentioned minor children to the Father immediately, and this Order further authorizes appropriate law enforcement authorities to enforce the Order and to render all lawful assistance to the Father, and/or the Father's attorney or designee, to deliver the minor children to the physical possession of the Father. 3. The Mother, Eileen P. Savage a/k/a/ Eileen P. Radtke, when located, legal counsel for the Father shall immediately make arrangements to serve a copy of this Order and the attached Custody Conciliation Report on the Mother. y. EXHIBIT 9 ., d. The Mother may at any time retain counsel and have counsel contact the conciliator directly to schedule another custody conciliation conference n•hich will be scheduled within a few days of any initial contact. cc: `fliomas J. Williams, Esquire Eileen P. Savage 105 Nest Butler Street NJt. Holly Springs, PA 17065 BY,ri lE COURT; .J. 4? esley Oler,J?. U v 7L. AD 5 28-02 l R1 EILEEN P. SAVAGE, a/k/a EILEEN P. RADTKE Plaintiff V WILLIAM SAVAGE, Defendant Prior Judge:.). Wesley Oler, Jr. : IN T'IIFs COURT OF COMMON PLEAS OF : CUMIIERLAND COUNTI', PENNSYLVANIA CIVIL ACTION - LAW NO.99-6759 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(1)), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Victoria E. Savage, born December 20, 1988; Cameron H. Savage, born May 27, 1992; Alexandra M. Savage, born June 29, 1993; and Liam G. Savage, born November 5, 1995. 2. A Conciliation Conference was held on May 24, 2002, with the following individuals in attendance: The Father, William Savage, with his counsel, Thomas J. Williams, Esquire. The A4other did not attend. Attorney Williams had served Legal Services with notice of the hearing in that Legal Services was still attorney of record. Attorney Williams was notified by Legal Services that they no longer represented the Mother. Attorney Williams also had served Attorney Rebecca Hughes who had contacted Attorney Williams suggesting she may be representing the Mother. Also, written notice of tlue custody, conciliation conference was sent to the Mother by regular mail by Attorney Williams at her Mt. Holly Springs address. 3. There was a Stipulation entered by the parties in January of 2000 whereby the Mother was provided primary physical custody of the four minor children. The Stipulation provided Father to have various periods or temporary custody including Saturday to Sunday each week and other various times. 4. In March 2002, the minor child Victoria came to live with Father and has been living with rather since that time. I other filed a petition to change custody relating to Victoria on May 1, 2002. Subsequent to that filing, Mother then delivered custody of Cameron to the Father on or about Nlay 5, 2002 at which time Mother suggested to Father that she was going to Chicago with her new husband and the two minor children to "handle an Estate for the Mother's new husband." Mother suggested to the Father and to school officials that the Mother would be back in five days. 5. Mother has not returned from this trip to Chicago. She has left messages with the Father suggesting various reasons why she has not returned. However, circumstances at the Alolher's home in Mt. Holly Springs suggest the Mother may have vacated the property and left the area permanently. There was apparently a yard sale shortly before Mother left. Also, Father contacted the Nit. Holly Springs police who went into the home and verified that some furniture still is in the house, but that it is evident that a fair amount of belongings have been taken. Father understands that Mother left the Carlisle area with a vehicle and a U-Haul. Father has concerns that Mother may be attempting to remove the two minor children from Pennsylvania on a permanent basis. Mother is a British citizen, and Mother in the past took the children to England without approval of the court at which time Father was required to expend various sums of money to get an order returning the children back to the United States. 6. Father filed a Petition for Special Relief with the court on May 23, 2002 requesting an Order of Custody for all four children. That Petition for Special Relief has also been referred to the custody conciliator. 7. In light of the fact that Father has custody of the two older children and in light of the circumstances related to the conciliator at the conference, the conciliator recommends the entry of an order in the form as attached. DATE C- r wL? ?y, Hubert X. Gilroy, Esquire Custody Conciliator VERIFICATION I verify that the statements made in the foregoing Petition To Modify Custody are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. C7??6 -05 Eileen R. Savage U Date CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint for Custody upon William R. Savage, by depositing same in the United States Mail, certified, first class, postage pre-paid on the 19th day of September, 2005, from Carlisle, Pennsylvania, addressed as follows: William R. Savage 107 E. Northern Parkway Baltimore, MD 21212-2902 TURO LAW OFFICES 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff \;.? ?. /, !? n LJI'?r ?? ? ? f ` n `" ?-? C: T ? ` p V C : rJ_ C: ?J1 V LlJ l_? ? I? lL G !^ ? ?;; C+ ? v ? v dOV ? q 2005 I EILEEN 1). 1N TI!I E 000IZT Orr CONLNION PLE:%S OF P?aintiff CUMBERLAND COUNTY, PENNSYLVANIA NO.99-6759 c1VIL ACTION - LAW WILLIAM R. SAVAGE, IN CUS'I.ODV Dcfend:ut ORDER OF COUIt'1' ?CCC r7 LJ AND NOW, this I51L_ day of ?:oven}her, 2005, upon consideration of the attached CUstUdy Conciliation Report, it is ordered :uul directed that this Court's prior Order of May 28, 2002 is vacated and replaced «ith the follon'ing TKNIPORARY Order: 1. The Father, William R. Savage, :uul the Mother, Eileen P. Savage, shall enjoy shared legal custody of Victoria E. Savage, born on December 20, 1988, Cameron H. Savage, born on May 27, 1992, Alexandra AI. Savage, born on .June 29, 1993, and Liam G. Savage, born on November 5, 1995. 2. The Father shall enjoy primary physical custody of the minor children. 3. The Mother %hall enjoy periods of temporary physical custody as follows: of the minor children A. On alternating weekends, the weekends to be the dates Alother is off wort:. Unless agreed otherwise, the times for exchange of custody shall he Friday afternoon at 3:30 p.m. and Sunday evening at 6:00 p.m. Unless agreed otherwise, Mother shall pick the children at Father's home on Friday, and Father shall pick the children up at Mother's home on Sunday. 13. At such other times as agreed upon by the parties. 4. For the upcoming 'thanksgiving and Chrisimas holida}, the parties shall communicate with each other in an effort to work out an arrangement whereby Mother has some lime with the minor children on those holidays. If the parties cannot reach an arrangement, legal counsel for the parties may contact the Conciliator for a telephone conference with the attorneys after which the Conciliator can recommend it further Order to this Coort addressing the holiday issues. - 7 A 5. This Order shall be temporary and each party reserves the right to advance it different position at a hearing in this case if a hearing is required. In the event the parties become dissatisfied with this Order, legal counsel for that party may contact the Conciliator directly and request another conciliation in a timely fashion. 13Y THE COURT, esley Oler, Judge Cc: Richard Koch, Esquire /y Thomas J. Williams, Esquire ! _?5 (? ?? EILEEN 1'. SAVAGE, Plaintiff vs. WILLIAINI 11. SAVAGE, Defendant IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6759 CIVIL ACTION - LAW IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNPfY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Victoria E. Savage, born on December 20, 1988 Cameron H. Savage, born on May 27, 1992 Alexandra M. Savage, born on June 29, 1993 Liam G. Savage, born on November 5, 1995 2. A Conciliation Conference was held on November 17, 2005, with the following individuals in attendance: The Mother, Eileen P. Savage, with her counsel, Richard Koch, Esquire The Father, William R. Savage, with his counsel, Thomas J. Williams, Esquire 3. Based upon the recommendation of the Conciliator, the parties agree to the entry of an Order in the form as attached. Date: 023-0 Hubert \. Gi oy, Esquire Custody Co cili, EILEEN P. SAVAGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-6759 CIVIL TERM WILLIAM R. SAVAGE, : CIVIL ACTION - LAW Defendant : CUSTODY PETITION TO MODIFY CUSTODY 1. Plaintiff is EILEEN P. SAVAGE, an adult individual, currently residing at 1837'/2 Sterretts Gap Avenue, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is WILLIAM R. SAVAGE, an adult individual, currently residing at 107 E. Northern Parkway, Baltimore, Maryland 21212-2902. 3. Plaintiff seeks custody of her children: Victoria E. Savage, born December 20, 1988; Cameron H. Savage, born May 27, 1992; Alexandra M. Savage, born June 28, 1993; and Liam G. Savage, born November 5, 1995. 4. The children have been adjudicated into legal and physical custody of the Defendant since 2002 (Exhibit 1), but in actual physical custody of Plaintiff Monday afternoon through Friday morning, and sometimes additionally, since August 30, 2005. 5. Since the end of defendant's lease on June 30, 2005, the children have resided at the residence of the paramour of defendant, in Baltimore, Maryland. 6. The relationship of the Plaintiff to the children is that of natural mother. 7. The relationship of the Defendant to the children is that of natural father. 8. The Plaintiff and Defendant were married on June 1, 1988. 9. A Complaint for Divorce was filed in Cumberland County, Pennsylvania and the divorce decree was granted in June 2000. 10. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. 11. The best interest and permanent welfare of the children will be served by granting the relief requested for the following reasons: A. Plaintiff, mother, lives in Carlisle, Pennsylvania. B. All children go to school in the West Shore School District, Cumberland County, Pennsylvania. C. Plaintiff, mother, takes each child to the relevant school, Tuesday through Friday. D. Plaintiff, mother, picks up all children from school, Monday through Thursday. E. Plaintiff, mother, takes each child to their sports or other after- school activities. F. The youngest child, Liam Savage, has been prescribed daily medication, but defendant does not always give plaintiff mother an adequate amount of the medication for the time Liam is in his mother's care. G. Plaintiff, mother, receives no compensation from defendant for these services. H. Plaintiff, mother, has and provides adequate living and sleeping arrangements for children, including a bed for each child. 1. Plaintiff, mother, has fulltime employment as a nurse on the daytime shift at Messiah Village in Mechanicsburg, Pennsylvania. J. Plaintiff, mother, can provide the children a stable home and social environment. K. Plaintiff, mother, can legitimately enroll children in schools in Pennsylvania. L. Plaintiff, mother, currently has no court-ordered legal or physical custody of the children. M. Defendant has no permanent residence of record. N. Defendant resides with his paramour in Baltimore, Maryland. O. Plaintiff has no knowledge of the personal/criminal history of the paramour with whom the Defendant resides. P. Children do not have adequate sleeping arrangements at defendant's paramour's house. Q. Defendant is employed on night-shift work by The Patriot-News newspaper, in Harrisburg, Pennsylvania. R. The children travel from Baltimore, Maryland to their respective schools in Cumberland County, Pennsylvania in the pre-dawn hours on Monday morning. S. The oldest child, Victoria Savage, aged 16 years, is frequently required to provide parental care to her siblings. T. The oldest child, Victoria Savage, aged 16 years, is frequently required to prepare meals for her siblings. 12. Each parent whose parental rights to the children have not been- terminated and the person who has physical custody of the children have been named as parties to this action. No other persons are known to have or claim to have any right to custody or visitation of the children other than the parties to this action. 13. Plaintiff is unaware of any legal representation for Defendant. 14. A copy of this Petition was sent by certified mail, return receipt requested, first class, postage prepaid to the Defendant. WHEREFORE, Plaintiff requests this Honorable Court grant Plaintiff's request for shared legal custody and primary physical custody of the minor children to the mother with partial physical custody with the father. Respectfully Submitted, TURO LAIN OFFICES Da Richard KocVEsc(uire? 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff M 4/24 2 0 0 2 EILEEN P. SAVAGE, a/k/a : IN THE COURT OF COMMON PLEAS OF EILEEN P. RADTKE, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v CIVIL ACTION - LAW WILLIAM SAVAGE, : NO. 99 - 6759 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this 7 S f-1 day of May, 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Court's prior Order of January 10, 2000 is vacated. 2. The Father, William Savage, shall have legal and physical custody of Victoria E. Savage, born December 20, 1988; Cameron H. Savage, born May 27, 1992; Alexandra M. Savage, born June 29,11993; and Liam G. Savage, born November 5, 1995. This Order is a directive to the Mother to deliver custody of the mentioned minor children to the Father immediately, and this Order further authorizes appropriate law enforcement authorities to enforce the Order and to render all lawful assistance to the Father, and/or the Father's attorney or designee, to deliver the minor children to the physical possession of the Father. 3. The Mother, Eileen P. Savage a/k/a/ Eileen. P. Radtke, when located, legal counsel for the Father shall immediately make arrangements to serve a copy of this Order and the attached Custody Conciliation Report on the Mother. VERIFICATION I verify that the statements made in the foregoing Petition To Modify Custody are and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. 7-16 -05 :?o GP- Date Eileen R. Savage CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint for Custody upon William R. Savage, by depositing same in the United States Mail, certified, first class, postage pre-paid on the 19th day of September, 2005, from Carlisle, Pennsylvania, addressed as follows: William R. Savage 107 E. Northern Parkway Baltimore, MD 21212-2902 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff V ZD 'b 4J r EILEEN P. SAVAGE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 99-6759 CIVIL ACTION LAW WILLIAM R. SAVAGE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, _ Friday, September 23, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, October 21, 2005 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Hubert X. Gilroy, Es T. 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 WI IERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717)249-3166 cS W!V 9Z GES SON -SO- ?r-L? Sv- ?-y 3ru do RECEIVED SEP 20100055/ EILEEN P. SAVAGE : IN THE COURT OF COMMON PLEAS V Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 99-6759 CIVIL TERM WILLIAM R. SAVAGE, : CIVIL ACTION - LAW Defendant :CUSTODY ORDER OF COURT AND NOW, this day of 2005, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before , Esq., the Conciliator, at on the day of 2005, at M., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary order. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Custody Conciliator 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 11. The best interest and permanent welfare of the children will be served by granting the relief requested for the following reasons: A. Plaintiff, mother, lives in Carlisle, Pennsylvania. B. All children go to school in the West Shore School District, Cumberland County, Pennsylvania. C. Plaintiff, mother, takes each child to the relevant school, Tuesday through Friday. D. Plaintiff, mother, picks up all children from school, Monday through Thursday. E. Plaintiff, mother, takes each child to their sports or other after- school activities. F. The youngest child, Liam Savage, has been prescribed daily medication, but defendant does not always give plaintiff mother an adequate amount of the medication for the time Liam is in his mother's care. G. Plaintiff, mother, receives no compensation from defendant for these services. H. Plaintiff, mother, has and provides adequate living and sleeping arrangements for children, including a bed for each child. 1. Plaintiff, mother, has fulltime employment as a nurse on the daytime shift at Messiah Village in Mechanicsburg, Pennsylvania. J. Plaintiff, mother, can provide the children a stable home and social environment. K. Plaintiff, mother, can legitimately enroll children in schools in Pennsylvania. L. Plaintiff, mother, currently has no court-ordered legal or physical custody of the children. M. Defendant has no permanent residence of record. N. Defendant resides with his paramour in Baltimore, Maryland. O. Plaintiff has no knowledge of the personal/criminal history of the paramour with whom the Defendant resides. P. Children do not have adequate sleeping arrangements at defendant's paramour's house. Q. Defendant is employed on night-shift work by The Patriot-News newspaper, in Harrisburg, Pennsylvania. R. The children travel from Baltimore, Maryland to their respective schools in Cumberland County, Pennsylvania in the pre-dawn hours on Monday morning. S. The oldest child, Victoria Savage, aged 16 years, is frequently required to provide parental care to her siblings. T. The oldest child, Victoria Savage, aged 16 years, is frequently required to prepare meals for her siblings. 12. Each parent whose parental rights to the children have not been- terminated and the person who has physical custody of the children have been named as parties to this action. No other persons are known to have or claim to have any right to custody or visitation of the children other than the parties to this action. 13. Plaintiff is unaware of any legal representation for Defendant. 14. A copy of this Petition was sent by certified mail, return receipt requested, first class, postage prepaid to the Defendant. WHEREFORE, Plaintiff requests this Honorable Court grant Plaintiffs request for shared legal custody and primary physical custody of the minor children to the mother with partial physical custody with the father. Da Respectfully Submitted, TURO LAW OFFICES ichard Koc , Es uire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Mkt'"? 4 2D02 EILEEN P. SAVAGE, a/k/a : IN THE COURT OF COMMON PLEAS OF EILEEN P. RADTKE, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v CIVIL ACTION - LAW WILLIAM SAVAGE, NO. 99 - 6759 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this 7 S fc? day of May, 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Court's prior Order of January 10, 2000 is vacated. 2. The Father, William Savage, shall have legal and physical custody of Victoria E. Savage, born December 20, 1988; Cameron H. Savage, born May 27, 1992; Alexandra M. Savage, born June 29, 1993; and Liam G. Savage, born November 5, 1995. This Order is a directive to the Mother to deliver custody of the mentioned minor children to the Father immediately, and this Order further authorizes appropriate law enforcement authorities to enforce the Order and to render all lawful assistance to the Father, and/or the Father's attorney or designee, to deliver the minor children to the physical possession of the Father. 3. The Mother, Eileen P. Savage a/k/a/ Eileen P. Radtke, when located, legal counsel for the Father shall immediately make arrangements to serve a copy of this Order and the attached Custody Conciliation Report on the Mother. EXHIBIT 4. The Mother may at any time retain counsel and have counsel contact the conciliator directly to schedule another custody conciliation conference which will be scheduled within a few days of any initial contact. RV TFIV rnrTRT J. cc: Thomas I Williams, Esquire Eileen P. Savage 7 105 West Butler Street Mt. Holly Springs, PA 17065 g- ? R s-z o?. EILEEN P. SAVAGE, a/k/a EILEEN P. RADTKE, Plaintiff v WILLIAM SAVAGE, Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.99-6759 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Victoria E. Savage, born December 20, 1988; Cameron H. Savage, born May 27, 1992; Alexandra M. Savage, born June 29, 1993; and Liam G. Savage, born November 5, 1995. 2. A Conciliation Conference was held on May 24, 2002, with the following individuals in attendance: The Father, William Savage, with his counsel, Thomas J. Williams, Esquire. The Mother did not attend. Attorney Williams had served Legal Services with notice of the hearing in that Legal Services was still attorney of record. Attorney Williams was notified by Legal Services that they no longer represented the Mother. Attorney Williams also had served Attorney Rebecca Hughes who had contacted Attorney Williams suggesting she may be representing the Mother. Also, written notice of the custody conciliation conference was sent to the Mother by regular mail by Attorney Williams at her Mt. Holly Springs address. 3. There was a Stipulation entered by the parties in January of 2000 whereby the Mother was provided primary physical custody of the four minor children. The Stipulation provided Father to have various periods of temporary custody including Saturday to Sunday each week and other various times. 4. In March 2002, the minor child Victoria came to live with Father and has been living with Father since that time. Father filed a petition to change custody relating to Victoria on May 1, 2002. Subsequent to that filing, Mother then delivered custody of Cameron to the Father on or about May 5, 2002 at which time Mother suggested to Father that she was going to Chicago with her new husband and the two minor children to "handle an Estate for the Mother's new husband." Mother suggested to the Father and to school officials that the Mother would be back in five days. 5. Mother has not returned from this trip to Chicago. She has left messages with the Father suggesting various reasons why she has not returned. However, circumstances at the Mother's home in Mt. Holly Springs suggest the Mother may have vacated the property and left the area permanently. There was apparently a yard sale shortly before Mother left. Also, Father contacted the Mt. Holly Springs police who went into the home and verified that some furniture still is in the house, but that it is evident that a fair amount of belongings have been taken. Father understands that Mother left the Carlisle area with a vehicle and a U-Haul. Father has concerns that Mother may be attempting to remove the two minor children from Pennsylvania on a permanent basis. Mother is a British citizen, and Mother in the past took the children to England without approval of the court at which time Father was required to expend various sums of money to get an order returning the children back to the United States. 6. Father filed a Petition for Special Relief with the court on May 23, 2002 requesting an Order of Custody for all four children. That Petition for Special Relief has also been referred to the custody conciliator. 7. In light of the fact that Father has custody of the two older children and in light of the circumstances related to the conciliator at the conference, the conciliator recommends the entry of an order in the form as attached. DATE Hubert X. Gilroy, Esquire Custody Conciliator VERIFICATION I verify that the statements made in the foregoing Petition To Modify Custody are and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. 7-?6 -05 Date ` Eileen R. Savage CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint for Custody upon William R. Savage, by depositing same in the United States Mail, certified, first class, postage pre-paid on the 19th day of September, 2005, from Carlisle, Pennsylvania, addressed as follows: William R. Savage 107 E. Northern Parkway Baltimore. MD 21212-2902 TURO LAW QFFICES 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff fv ?2 \i C ? ? c.> ?? ?. ?, ? n1? ` ? ?:? ;n .- c?? ., .D irk, -s' - ?rn t ? 1 _ 1 _ ` G ? y NOV 2 2005 EILEEN P. SAVAGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 99-6759 CIVIL ACTION - LAW WILLIAM R. SAVAGE, IN CUSTODY Defendant ORDER OF COURT ? ? AND NOW, this Isl day of November, 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's prior Order of May 28, 2002 is vacated and replaced with the following TEMPORARY Order: 1. The Father, William R. Savage, and the Mother, Eileen P. Savage, shall enjoy shared legal custody of Victoria E. Savage, born on December 20, 1988, Cameron H. Savage, born on May 27, 1992, Alexandra M. Savage, born on June 29, 1993, and Liam G. Savage, born on November 5, 1995. 2. The Father shall enjoy primary physical custody of the minor children. 3. The Mother shall enjoy periods of temporary physical custody of the minor children as follows: A. On alternating weekends, the weekends to be the dates Mother is off work. Unless agreed otherwise, the times for exchange of custody shall be Friday afternoon at 3:30 p.m. and Sunday evening at 6:00 p.m. Unless agreed otherwise, Mother shall pick the children at Father's home on Friday, and Father shall pick the children up at Mother's home on Sunday. B. At such other times as agreed upon by the parties. 4. For the upcoming Thanksgiving and Christmas holiday, the parties shall communicate with each other in an effort to work out an arrangement whereby Mother has some time with the minor children on those holidays. If the parties cannot reach an arrangement, legal counsel for the parties may contact the Conciliator for a telephone conference with the attorneys after which the Conciliator can recommend a further Order to this Court addressing the holiday issues. :? ii -- ,. . ?_ 5. This Order shall be temporary and each party reserves the right to advance a different position at a hearing in this case if a hearing is required. In the event the parties become dissatisfied with this Order, legal counsel for that party may contact the Conciliator directly and request another conciliation in a timely fashion. BY THE COURT, es ley Oler, , Ju ge Cc: Richard Koch, Esquire Thomas J. Williams, Esquire .tom' EILEEN P. SAVAGE, Plaintiff VS. WILLIAM R. SAVAGE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6759 CIVIL ACTION - LAW IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Victoria E. Savage, born on December 20, 1988 Cameron H. Savage, born on May 27, 1992 Alexandra M. Savage, born on June 29, 1993 Liam G. Savage, born on November 5, 1995 2. A Conciliation Conference was held on November 17, 2005, with the following individuals in attendance: The Mother, Eileen P. Savage, with her counsel, Richard Koch, Esquire The Father, William R. Savage, with his counsel, Thomas J. Williams, Esquire 3. Based upon the recommendation of the Conciliator, the parties agree to the entry of an Order in the form as attached. Date: 0-a3-D Hubert X. G' oy, Esquire Custody Co ciliator ,- i MAR 01 2010 EILEEN ROMANSKI F/K/A EILEEN IN THE COURT OF COMMON PLEAS OF SAVAGE, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff C c v. No. 99-6759 CIVIL ACTION L$, f'S"a r ,-, ' z ~" ,-, • :~ .-„ ... ~_. r-- ~ r-n ?~ WILLIAM R. SAVAGE IN CUSTODY U> ~ ~ _w ~- ~ w Defendant ~ ~= ° -~ ~; ~_ ~ -e~ ~ ~~i Prior Judge: J. Wesley Oler, Jr. ~'~ w ~ ~ ORDER OF COURT AND NOW this ~ day of March 2010, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: All prior Orders are hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, William R. Savage, and the Mother, Eileen P. Romanski, shall have shared legal custody of Cameron Savage, born 05/27/1992, Alexandra Savage, born 06/28/1993 and Liam Savage, born 11/05/1995. The parties shall have an equal right 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 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: Mother and Father shall arrange physical custody of the Children as follows: a. In week one, Mother shall have physical custody of the Children from Wednesday until Thursday morning and from Friday after school until Monday morning. b. In week two, Mother shall have physical custody from Wednesday until Thursday morning and from Friday after school until Saturday morning at 8:30 am or at some other agreed upon time. c. The parties shall mutually agree on times and circumstances for the custody exchanges. d. The parties shall arrange the transportation obligations in regard to taking the Children to school between themselves. e. The parties may arrange physical custody of the Children at such other times as the parties may mutually agree. 3. Counseling: The parties have agreed to explore the possibility of therapeutic family counseling. 4. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 5. Holidays: The holidays shall be arranged by mutual agreement and both parties shall have appropriate time during the holidays with the Children. 6. The parties to this action are strongly encouraged to meet at least one time per month to discuss the Children's well-being; especially the Children's medical issues and their educational situations. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. $. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 9. This Order is entered pursuant to 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. Dpi tribution: /William Savage, 412 Boller Ave., 2°d and 3rd Floor, Lemoyne, PA 17043 panne Costopoulos, Esquire ~hn J. Mangan, Esquire ~.o~! ACS' /'rla~Z I ~ l~ ~3 3~rv EILEEN ROMANSKI F/K/A EILEEN IN THE COURT OF COMMON PLEAS OF SAVAGE, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . v. No. 99-6759 CIVIL ACTION LAW WILLIAM R. SAVAGE, IN CUSTODY Defendant Prior Judge: J. Wesley Oler, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Cameron Savage 05/27/1992 Primary Father Alexandra Savage 06/28/1993 Primary Father Liam Savage 11/05/1995 Primary Father 2. A Conciliation Conference was held with regard to this matter on February O1, 2010, an Order was issued February 04, 2010 and a conference was held February 23, 2010 with the following individuals in attendance: The Mother, Eileen Romanski, with her counsel, Jeanne Costopoulos, Esq. The Father, William Savage, self-represented party 3. The parties agreed to the entry of an Order in the form as attached. Z ~ /o~ Date John a an, E - ire Cus dy onciliator