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HomeMy WebLinkAbout03-4235Paul J. Esposito, Esquire I.D. 925454 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P. 0. Bon 1268 Harrisburg, PA 17108-1268 (717) 2344161; (717) 2344161 (facsimile) Counsellor Plaintiff CHRISTINE L. McCORMICK, Plaintiff V. WILLIS J. McCORMICK, II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 - 7r433? LiutL? CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is CHRISTINE L. McCORMICK, whose current address is 4 Appaloosa Way, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is WILLIS J. McCORMIC1*'-,11, whose current address is 6015 William Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff is the Mother, and Defendant is the Father of the children, who are the subject of this action. 4. Plaintiff seeks shared legal and primary physical custody of. Name: Matthew Ryan McCormick, Date of Birth: November 10, 1993 Present Residence: 4 Appaloosa Way, Carlisle, Cumberland County, Pennsylvania; Name: Marissa Loraine McCormick, Date of Birth: June 3, 1996 Present Residence: 4 Appaloosa Way, Carlisle, Cumberland County, Pennsylvania Name: Melanie Christine McCormick, Date of Birth: May 4, 1998 Present Residence: 4 Appaloosa Way, Carlisle, Cumberland County, Pennsylvania The children were bom during the parties' marriage. 5. The parties continue to be married, but have lived separately since April 12, 2003. 6. From 1995 to April 12, 2003, the children resided with both parents at 4 Appaloosa Way, Middlesex Township, Cumberland County, Pennsylvania. From April 12, 2003 to the present, the children have resided with the Plaintiff only at 4 Appaloosa Way, Middlesex Township, Cumberland County, Pennsylvania 8. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 9. The best interests and permanent welfare of the children will be served by the relief requested. 10. Plaintiff has not participated as a party, witness or in another capacity or in other litigation concerning the custody of the children in this or another Court. 11. Plaintiff currently lives with the children. 12. Defendant lives with his mother, Jean B, McCormick, at 6015 William Drive, Mechanicsburg, Cumberland County, Pennsylvania. WHEREFORE, Plaintiff respectfully requests that the Court grant the parties shared legal custody and that she be awarded primary physical custody of her children, Matthew Ryan McCormick, Marissa Loraine McCormick, and Melanie Christine McCormick. Date: GCaC a&,,.2 003 Respectfully submitted, GO BER?C, KATZ AN & SHIPMAN, P.C. Paul J s ito Attorney . #25454 Goldberg, Katzman & Shipman 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 2344161 Attorney for Plaintiff VERIFICATION I verify that the statements contained in the foregoing COMPLAINT FOR CUSTODY are true and correct to the best of my knowledge, information and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa.C.S. Section 49044 relating to unworn falsification to authorities. / Date: 0 l? a l po C"c CHRISTINE L. McCORMICK CERTIFICATE OF SERVICE On this t90 day of August 2003, I certify that the original and one copy of the foregoing was served upon the following counsel of record for Plaintiff by placing the same in the United States mail, first class, postage prepaid, addressed as follows: Elizabeth S. Beckley, Esquire Beckley & Madden Cranberry Court 212 North Third Street P. O. Box 11998 Harrisburg, PA 17108-1998 GOLDBERG, KATZMAN & SHIPMAN, P.C. Paul J. po0 Supreme C6(xrt ID #25454 Goldberg, Katzman & Shipman 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Plaintiff rIj "6q cr, CHRISTINE L. MCCORMICK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-4235 CIVIL ACTION LAW WILLIS J. MCCORMICK, II IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, September 02, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, September 29, 2003 at 10:30 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/ Melissa P Greevy,Es¢, Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 4`?L-j-V 7- '*0-h-6 tr,NvAi'N,N2d uNn:;?? rP???? 9 1 :Z s.?j - ull5 "0 C(2-h -eJ coh-b OC I u 9 [003 ? U CHRISTINE L. MCCORMICK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 03-4235 CIVIL TERM V. CIVIL ACTION - LAW WILLIS J. MCCORMICK, II, Defendant IN CUSTODY INTERIM ORDER OF COURT AND NOW, this _ day of October, 2003, upon consideration of the attache Custody Conciliation Summary Report, pending further Order of Court or an agreement 01 the parties, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Christine L. McCormick and Willis J. McCormi II, shall have shared legal custody of the minor children, Matthew Ryan McCormick, be November 10, 1993, Marissa Loraine McCormick, born June 3, 1996, and Melanie Christi McCormick, born May 4, 1998. Each parent shall have an equal right, to be exercis jointly with the other parent, to make all major non-emergency decisions affecting 1 children's general well-being including, but not limited to, all decisions regarding their heal education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall entitled to all records and information pertaining to the children including, but not limited medical, dental, religious or school records, the residence address of the children and of 1 other parent. To the extent one parent has possession of any such records or informati( that parent shall be required to share the same, or copies thereof, with the other pan within such reasonable time as to make the records and information of reasonable use the other parent. 2. Physical Custody. Mother shall have temporary primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: A. To commence October 3, 2003, on alternating weekends from Friday at 5:00 p.m. until the following Monday morning when the children are returned to school. However, Father's custodial time with Matthew shall be extended until Tuesday mornings following his custodial weekend. B. Each Wednesday from 4:30 p.m. until 8:00 p.m., Father shall have custody of Marissa and Melanie. ?,???d??7?? 'Ua'?,??;1? ,,,? ,,,i 'J ?,? , _. ???,_:? ..» .J NO. 03-4235 CIVIL TERM 3. Holidays. The following holiday schedule shall take precedence over the regular schedule: A. Thanksgiving. Thanksgiving shall be divided into two segments, Segment A and Segment B. Segment A shall be from the Wednesday preceding Thanksgiving at 5:00 p.m. until the Friday following Thanksgiving at 7:00 p.m. Segment B shall be from the Friday following Thanksgiving at 7:00 p.m. until Sunday at 8:00 p.m. In odd-numbered years, Father shall have Segment A and Mother shall have Segment B. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. B. Christmas 2003. During the Christmas holiday school break, Father shall have custody for the following periods: (1) December 24th from 9:00 a.m. to 9:30 p.m.; (2) December 25th from 1:00 P.M. until December 28th at 8:00 p.m.; (3) December 3151 at 5:00 p.m. until January 1, 2004 at 8:00 P.M. Mother shall have custody for the Christmas 2003 holiday school break from December 24th at 9:30 p.m. until December 25th at 1:00 p.m. and December 28th at 8:00 p.m. until December 31St at 5:00 p.m. C. Alternating Holidays. The parties shall alternate custody for the following holidays commencing with Father having custody for New Year's Day 2004: New Year's Day, Easter, Memorial Day, Independence Day, and Labor Day. The custodial period for these holidays shall be from 9:00 a.m. until 8:00 p.m. 4. Vacation. Each party shall be entitled to two (2) non-consecutive weeks of custody for vacation which shall commence on the traveling parent's custodial weekend at 5:00 p.m. on Friday. The parties shall provide each other with at least thirty (30) days notice)) of their intended vacation. In the event of a conflict in vacation schedules, the parent to first) provide written notice to the other parent shall have choice of the vacation time. Prior toi departure, the traveling parent shall provide the other parent with written notice of the', address and telephone number where they can be reached during the vacation period. NO. 03-4235 CIVIL TERM 5. Mother's Day / Father's Day. Moth Mother's Day from Noon to 8:00 p.m. Father shall Day from Noon to 8:00 p.m. r shall have custody of the children for have custody of the children for Father's 6. Transportation. Father will provide transportation at the beginning of hi custodial periods and to school or the bus stop on those days when his custodial perio ends with the children's return to school. Mother will assist in the transportation by pickin up the girls from Father's custody at the end of his Wednesday evening visits. 7. Children's Birthday. The non-custodial parent shall be entitled to an hour a a half (1'/z) period of custody with each child on his or her birthday. 8. Telephone Contact. The non-custodial parent shall be entitled to two completed telephone calls with the children during the custodial parent's vacation w The children shall be entitled to make telephone calls to the non-custodial parent u request. 9. The parties shall submit themselves and their minor children to independent custody evaluation to be performed by Riegler, Shienvold & Associates. 7 costs associated with the evaluation shall be borne by Father. However, Father shall ret, the right to petition the Court for contribution from Mother subsequent to the completion the evaluation. The parties shall sign all necessary releases and authorizations for i evaluator to obtain medical and psychological information pertaining to the parties, if requested by the evaluator. Additionally, the parties shall extend their full cooperation completing this evaluation in a timely fashion and in the scheduling of appointments. 10. Following the completion of the custody evaluation, and within ten (10) days c counsel's receipt of the report from the evaluator, the Custody Conciliation Conference me be reconvened by a letter request to the Conciliator's office by counsel for either part Requests to reconvene the Conference outside that ten (10) day period shall be mad through the normal process. BY THE COURT: V Dist: ?Paul J. Esposito, Esquire, PO Box 1268, Harrisburg, PA 17108 /Elizabeth S. Beckley, Esquire, 212 North Third Street, Harrisburg, PA 17101 J Res ? 0-ID CHRISTINE L. MCCORMICK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. WILLIS J. MCCORMICK, II, Defendant NO. 03-4235 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent in litigation is as follows: NAME Matthew Ryan McCormick Marissa Loraine McCormick Melanie Christine McCormick formation concerning the children who are the subject of tf DATE OF BIRTH CURRENTLY IN THE CUSTODY OF November 10, 1993 Mother June 3, 1996 Mother May 4, 1998 Mother 2. A Custody Conciliation Conference was held on September 29, 2003 followin the filing of Mother's Complaint for Custody on August 27, 2003. Present for the conference were: the Mother, Christine L. McCormick, and her counsel, Paul J. Esposito, Esquire; th Father, Willis J. McCormick, II, and his counsel, Elizabeth Beckley, Esquire. 3. The parties reached an agreement that Mother should have temporary prima? physical custody of the children. However, they could not agree on the scheduling oT temporary partial custody for the Father. Additional agreements were reached regarding the sharing of holidays, vacation, transportation, and telephone contact. 4. Mother's position on custody is as follows: Mother presently resides with h4 parents. The marital residence has-been sold and a new purchase is planned for Novembe 2003 which would allow the children to continue to attend the schools which they previousl attended. Mother works on a part time basis selling Longaberger baskets. She seek primary physical custody and shared legal custody of the children. It is her opinion tha Father should have no overnights with the children which occur on a school night. Sh places great value on the consistency of a regular routine in making sure that the childre are in bed and all of their papers are in order for school the following morning. She doubt Father's parenting abilities and whether he can manage to get all three children ready fot NO. 03-4235 CIVIL TERM school and on the bus in time in the morning. Through counsel, she also suggested that Father needs to attend parenting classes. 4. Father's position on custody is as follows: Father would like to confirm the custodial schedule which had been arranged and negotiated by his previous counsel, Mr!. Connelly. This provided Father with custody on alternating weekends which were extende through Monday mornings in the Summer, each Wednesday evening and each Monday The agreement also provided for alternating holidays and custodial time in the Summer However, subsequent to this arrangement being negotiated, Father reports that Mothe unilaterally decided to discontinue the Monday periods of custody. In Father's experience he notes that the children seem to be less compliant with him and that at times when he ha gone to pick them up that they have run away from him. Father is seeking a custod evaluation because he believes that the children are being negatively influenced agains him by their Mother. Additionally, he disputes Mother's position that he needs to participat in parenting classes. He proposed the parties participate in a custody evaluation. He ha proposed to pay all the costs incident to the evaluation, subject to his right to petition th Court to subsequent contribution by Mother. Father reports that the minor child has bee seeing a counselor who has recommended that Father spend individual time with th parties' son. Father has proposed that this occur on Monday evenings, which coincides wit his Scouting activities, and have this visit be extended until Matthew returns to school o Tuesday mornings. Father would also like to have custodial time on Wednesdays with th girls and have that visit extended from after school until the next morning when the childre return to school. Father seeks to have Mother share responsibility for driving incident t custodial exchanges. If a custody evaluation is done, Father would also agree to return to Custody Conciliation Conference prior to the matter being heard by the Court. 5. Subsequent to the Custody Conciliation Conference, the Conciliator notified by counsel for Father that the parties had agreed to participate in the cuss evaluation. However, because the partial custody sche a as not fully agreed upon, Conciliator provides the attached Interim Order for th ourt's onsideration. Date Melissa Peel Greevy, Esquire Custody Conciliator :219131 MARIA P. COGNETTI & ASSOCIATES KRISTOPHER T. SMULL, ESQUIRE Attorney I.D. No. 69140 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff/Petitioner CHRISTINE L. McCORMICK, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIS J. McCORMICK, II, Defendant/Respondent No. 03-4235 CIVIL ACTION - LAW IN CUSTODY PETITION TO MODIFY CUSTODY ORDER AND NOW, comes the Plaintiff, Christine L. McCormick, by and through her attorney, Kristopher T. Smull, and with him Maria P. Cognetti & Associates, and files the following Petition to Modify Custody Order, and in support thereof avers as follows: Petitioner is Christine L. McCormick (hereinafter "Mother"), Plaintiff in the above-referenced action. 2. Respondent is Willis J. McCormick, II (hereinafter "Father"), Defendant in the above-referenced action. The parties hereto are the natural parents of three (3) minor children, namely: Matthew R. McCormick, date of birth November 10, 1993; Marissa L. McCormick, date of birth June 3, 1996; and Melanie C. McCormick, date of birth May 4, 1998. 4. The above minor children are the subject of an interim Custody Order dated October 10, 2003 in the Court of Common Pleas of Cumberland County, Pennsylvania. Said Order was entered on an interim basis by agreement of the parties pending custody evaluations. Said Order provided for Father to have custody of the three (3) children on alternating weekends from Friday through Monday morning. It further provided that Father have custody of Matthew on Monday overnight following his weekend, and that he have the girls on Wednesdays for a three (3) hour period. A true and correct copy of the October 10, 2003 Order is attached hereto and marked as Exhibit "A." 5. Said evaluations were completed and reports submitted by Dr. Shienvold dated July 20, 2004. In accordance with Dr. Shienvold's recommendation, the parties modified the visitation schedule of the October 10, 2003 Order. Said visitation schedule, that has been followed since September 2004, vests primary custody in Mother, with partial custody to Father, on alternating weekends from Friday through Monday, every Monday evening from 5:00 until 8:00 p.m., and Wednesday overnight to Thursday morning with all three children. A true and correct copy of the September 10, 2004 letter from Mother's counsel setting out the current custody schedule is attached hereto and marked as Exhibit "B." 6. The parties followed the above schedule until May 5, 2005 when Father unilaterally decided to change the schedule and revert to the schedule set out in the October 10, 2003 Order. Father contacted Mother via e-mail and informed her that the change was being made without any discussion. True and correct copies of Father's e-mails are attached hereto and made a part hereof and marked collectively as Exhibit "C." T Mother's counsel immediately attempted to contact Father's counsel in order to discuss the issue, however, Mother's counsel was informed that Father had fired his counsel and was to be retaining new counsel. Mother's counsel contacted Father's new attorney who informed Mother's counsel that she was not being retained for custody, and that Father would be proceeding Pro Se. 8. Mother believes that it is in the best interests of the children to modify the Order of Court of October 10, 2003 and to memorialize the schedule that the parties have been following for the past eight (8) months. Said schedule was in accordance with the parties' custody evaluation, which Father insisted on obtaining. 9. Each parent whose parental rights to the children have not been terminated, and the person who has physical custody of the children has been named as a party to this action. 10. A copy of this Petition to Modify has been sent to Father directly, as he is proceeding forward Pro Se. WHEREFORE, Mother respectfully requests that this Honorable Court grant her requested relief. Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES L?V Date: By: KRISTOP R T. SMULL, ESQUIRE Attorney I.D. No. 69140 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff/Petitioner VERIFICATION I, Christine L. McCormick, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: Xhristine L. McCormick OCT 0 0 2003 y CHRISTINE L. MCCORMICK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 03-4235 CIVIL TERM V. CIVIL ACTION - LAW WILLIS J. MCCORMICK, II, Defendant IN CUSTODY INTERIM ORDER OF COURT AND NOW, this - L-? day of October, 2003, upon consideration of the attached Custody Conciliation Summary Report, pending further Order of Court or an agreement of the parties, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Christine L. McCormick and Willis J. McCormick, II, shall have shared legal custody of the minor children, Matthew Ryan McCormick, born November 10, 1993, Marissa Loraine McCormick, bom June 3, 1996, and Melanie Christine McCormick, born May 4, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the 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. 2. Physical Custody. Mother shall have temporary primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: A. To commence October 3, 2003, on alternating weekends from Friday at 5:00 p.m. until the following Monday morning when the children are returned to school. However, Father's custodial time with Matthew shall be extended until Tuesday mornings following his custodial weekend. B. Each Wednesday from 4:30 p.m. until 8:00 p.m., Father shall have custody of Marissa and Melanie. t NO. 03-4235 CIVIL TERM 3. Holida s. The following holiday schedule shall take precedence over the regular schedule: A. Thanksgiving. Thanksgiving shall be divided into two segments, Segment A and Segment B. Segment A shall be from the Wednesday preceding Thanksgiving at 5:00 p.m. until the Friday following Thanksgiving at 7:00 p.m. Segment B shall be from the Friday following Thanksgiving at 7:00 p.m. until Sunday at 8:00 p.m. In odd-numbered years, Father shall have Segment A and Mother shall have Segment B. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. B. Christmas 2003. During the Christmas holiday school break, Father shall have custody for.the following periods: (1) December 24th from 9:00 a.m. to 9:30 p.m.; (2) December 25th from 1:00 p.m. until December 28th at 8:00 p.m.; (3) December 31st at 5:00 p.m. until January 1, 2004 at 8:00 P.M. Mother shall have custody for the Christmas 2003 holiday school break from December 24th at 9:30 p.m. until December 25th at 1:00 p.m. and December 28th at 8:00 p.m. until December 31St at 5:00 p.m. . C. Altemating Holidays. The parties shall alternate custody for the following holidays commencing with Father having custody for New Year's Day 2004: New Year's Day, Easter, Memorial Day, Independence Day, and Labor Day. The custodial period for these holidays shall be from 9:00 a.m. until 8:00 p.m. 4. Vacation. Each party shall be entitled to two (2) non-consecutive weeks of custody for vacation which shall commence on the traveling parent's custodial weekend at 5:00 p.m. on Friday. The parties shall provide each other with at least thirty (30) days notice of their intended vacation. In the event of a conflict in vacation schedules, the parent to first provide written notice to the other parent shall have choice of the vacation time. Prior to departure, the traveling parent shall provide the other parent with written notice of the address and telephone number where they can be reached during the vacation period. NO. 03-4235 CIVIL TERM 5. Mother's Dav i Father's Dav. Mother shall have custody of the children for Mother's Day from Noon to 8:00 p.m. Father shall have custody of the children for Father's Day from Noon to 8:00 p.m. 6. Transportation. Father will provide transportation at the beginning of his custodial periods and to school or the bus stop on those days when his custodial period ends with the children's return to school. Mother will assist in the transportation by picking up the girls from Father's custody at the end of his Wednesday evening visits. 7. Children's Birthday. The non-custodial parent shall be entitled to an hour and a half (1'/2) period of custody with each child on his or her birthday. 8. Telephone Contact. The non-custodial parent shall be entitled to two (2) completed telephone calls with the children during the custodial parent's vacation week. The children shall be entitled to make telephone calls to the non-custodial parent upon request. 9. The parties shall submit themselves and their minor children to an independent custody evaluation to be performed by Riegler, Shienvold & Associates. The costs associated with the evaluation shall be borne by Father. However, Father shall retain the right to petition the Court for contribution from Mother subsequent to the completion of the evaluation. The parties shall sign all necessary releases and authorizations for the evaluator to obtain medical and psychological information pertaining to the parties, if so requested by the evaluator. Additionally, the parties shall extend their full cooperation in completing this evaluation in a timely fashion and in the scheduling of appointments. 10. Following the completion of the custody evaluation, and within ten (10) days of counsel's receipt of the report from the evaluator, the Custody Conciliation Conference may be reconvened by a letter request to the Conciliator's office by counsel for either party. Requests to reconvene the Conference outside that ten (10) day period shall be made through the normal process. BY THE COURT: a J l? e. J. Dist: Paul J. Esposito, Esquire, -PO_BoX-1 26B, Harrisburg, PA _17108- ------ - --- - -- -- - - Elizabeth S. Beckley, Esquire, 212 North Third Street, Harrisbu 0 ??7?1CtOPY FROM !•'""" `") In Testimony whereof, I here unto ; r„y hand and the seal of sal Court at Carl' le, Pa. 03 Thi..... i.,, . /.Eqf.... ..., MARiA P. C®GNE= & Ass®ciATEs Attorneys & Counselors at Law 210 Grandview Avenue, Suite 102 ? Camp Hill, PA 17011 Telephone (717) 909-4060 ? Fax (717) 909-4068 Email Cognetg?w@aol.com Maria P. Cognetti* Practice Limited to Matrimonial Law Todd C. Hough Attorney at Law Attorney at Law *Fellow, American Academy of Matrimonial Lawyers Fellow, International Academy of Matrimonial Lawyers September 10, 2004 Elizabeth S. Beckley, Esquire BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108-1998 RE: McCORMICK x McCORMICK Our File No. 699 Dear Liesl: Kristi S. Wargo Paralegal In a recent meeting with my client it has come to my attention that your client seems to believe that he does not have an absolute obligation to continue to maintain health insurance for the parties' and their children. He has recently given my client some information with regard to the CHIP program and has told her that she "must" look into it and that, with regard to payment, paying for it may "be beyond his means." I am sure that you will advise your client that the minute he ceases to carry health insurance for my client and the parties' children he will be in contempt of court and we will take immediate steps to bring him in for such contempt. I am hopeful however that after you speak with him this will not become necessary. Along those same lines, in trying to review Attorney Esposito's file I find that there are somewhat spotted documents from IBM with regard to your client's dismissal from his employment. It appears that he was dismissed based upon an "inability to meet IBM standards of job performance." Although you may have previously discussed this with Paul, could you please enlighten me as to what the specific reasons were which caused your client to lose his job. Additionally, I have reviewed the Stipulation for Management of Assets, which appears to Elizabeth S. Beckley, Esquire September 10, 2004 Page 2 have been executed by the parties in late April of this year. Please advise as to whether you are willing to voluntarily turn over to me documentation of all of the various monetary assets transferred or moved by your client from one month prior to date of separation through the time of the freeze. If you are willing to do so, I would appreciate a quick response from you and would like to have that documentation within fifteen (15) days. If you are not willing to do so then I will simply prepare formal discovery and serve it upon your client. I am certainly hopeful that this will not be necessary. I would appreciate receiving the above information from you at your earliest possible convenience. Lastly, upon reviewing my letter dated September 8, 2004, I realize I was not as precise as I should have been. Allow me to clarify my client's position with regard to the current custodial arrangement. In accordance with Dr. Shienvold's recommendation of July 20, 2004, my client suggests that your client's alternating weekends of custody begin with his picking up the children at 5:00 p.m. on Friday and continuing through Monday morning at 7:45 a.m. when your client would drop the children off at my client's house prior to school. Additionally, on the Monday evenings following your client's non-custodial weekend, my client will drop the children off at your client's residence at 5:00 p.m. and your client should return the children to my client's residence at 8:00 p.m. that same evening. Additionally, the Wednesday overnight periods of custody would begin with your client picking the children up at 5:00 p.m. at my client's house and returning them to my client's residence Thursday morning at 7:45 a.m. prior to school. I should note that these custodial periods are for all three children. I hope this clarifies my client's position with regard to the parties' custodial arrangement and I would ask that you notify me of your client's position once you have had a chance to review this information with him. Very truly you s, Maria P. Zognetti MPC1slf cc: Ms. Christine McCormick Subl: Custody arrangement changes pate:. 5/512005 4:27:18 PM Eastern Davlipht Time From: billmccormick777@yahoo.com (Willis McCormick) To: clzu2@aotcom CC: rshadday@pacses.com (rickki shadday) Christine McCormick 18 Wheatfield Drive, Carlisle, PA 17013 Christine, May 5, 2005 I am writing to inform you that the Monday and Wednesday custody arrangements are not working. Therefore, I am notifying you that effective Monday, May 91' 2005, I am reverting to the most current order of the court, dated October 10th, 2003, for Matthew only on the current Monday schedule. I can pick him up at your residence as currently, but at 4:30PM vs. directly from/to school (as Matthew had expressed his desire to ride the bus to your residence/to school versus being picked up/dropped off at school) and drop him off at the bus stop or your residence Monday and Tuesday mornings between 7:45-8AM. The essence of this action is to have Matthew only on my custodial Mondays. On Wednesday's, I will pick up Melanie and Marissa at 4:30pm and you may pick them up at the designated time of 8pm at my residence. Friday, May 06, 2005 CompuServe: Wnzilch -1 w y Page 2 of 2 Please let me know what Monday you wish to start Matthew's custody cycle on, May 9th following my visitation or after your weekend as presently. If I do not hear from you regarding this matter prior to end of day, Sunday May 8th, I will pick up Matt after school on the nest Monday, May 16th at your residence at 4:30PM. Bill This letter will also be sent registered mail to your physical address and I will leave you a message on your home phone. Do You Yahoo!? Tired of spam? Yahoo! Mail has the best spam protection around http: i/mai!.yahoo. com Headers - Return-Path: <bi(Imccarmick777@yahoo.com> Received- from. r1y-yd01.mx,aol.com (r!y-yd01.mai .aol.com [172.18.141,651) by air-yd01.mail.aoI.com (vx) with ESMTP id MAIL(NYD12-1f1427a818ac7; Thu, 05 May 2005 16:27:17 -0400 Received`. from web51510.mail.yahoo.com (web51510.mail.yahoo.com [206.190.38.2021) by rly- yd0l.mx.aol.com (x105,26) with ESMTP id MAiLRELAYiNYD17-1f1427a818ac7; Thu, 05 May 2005 16:26:50 - 0400 Received: (gmail 34476 invoked by uid 60001); 5 May 2005 20:26:50 -0000 Comment: DomainKeys? See http://6htispam.yahoo.com/domainkeys DomainKeySignature: a=rsa-shat; q=dns; c=nofws; s=s1024;' d=yahco.com; Message-ID: <20050505202650.34474.gmall@web515fQ.maii.yehoo.com> Received: from [208.9.194.2011 by web51510.mail.yahoo.com via HTTP; Thu, 05 May 2005 13:26:50 PDT Dater Thu, 5 May 2005 13:26:50 -0700 (PDT) From. Willis McCormick <bi!lmccormick777@yahoo.com> Subject: Custody arrangement changes To: clzu2@aol.corn Cc: rickki shadday <rshadday@pacses.com> MIME-Version: 1.0. Content-Type: multipart/altemative; boundary="0-1 37797007-111532481 0=:33939" X-AO L-I P: 206.190.38.202 X-AO LSCO LL-SCORE: 0:2498845072:13153337 X-AOL-SCOLL-URL COUNT: 0 J9 Friday, May 06, 2005 CompuServe: Wnzilch CERTIFICATE OF SERVICE I, Kristopher T. Smull, Attorney for Plaintiff/Petitioner herein, do hereby certify that on this date I served the foregoing Petition to Modify Court Order by depositing a true and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Willis J. McCormick, II 2 Hearthstone Court Mechanicsburg, PA 17050 MARIA P. COGNETTI & ASSOCIATES Date: I? ( 5 By: KRISTO R . SMUL , ESQUIRE Attorney I.D. No. 69140 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff/Petitioner %.J ? ? ? ? C d cv ? \? ~? Y? _? ;_ ?, . , , __, n:? , ,- { _ ? CHRISTINE L. MCCORMICK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIS J. MCCORMICK, It DFFF,NDANT 03-4235 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 26, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at DJ Manlove's, 1901 State St., Camp Hill, PA 17011 on Thursday, July 07, 2005 at 11:00 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/ Melissa P. Greevp, Esq. ??__ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 mil"'"' ,,? .s ? ??. s Willis J. McCormick H 2 Hearthstone Court, Mechanicsburg, PA 17050 Telephone No. (717) 766-1561 Defendant/Respondent CHRISTINE L. MCCORMICK, Plaintiff/Petitioner V. WILLIS J. McCORMICK II, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03-4235 CIVIL ACTION - LAW IN CUSTODY DEFENDANT'S ANSWER TO PLANTIFF'S PETITION TO MODIFY CUSTODY ORDER 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted in part; denied in part. Defendant (hereinafter "Father") admits that Dr. Shienvold submitted his report on July 20, 2004. Father further admits that the parties have modified the custody order dated October 10, 2003 as per Dr. Shienvold's recommendation. Father denies that he agreed with Dr. Shienvold's recommendations, or that the custody schedule is in the children's best interests. Therefore, the Father demands strict proof at trial. 6. Admitted. By way of further answer, Father had been obstructed by Plaintiff (hereinafter "Mother") in obtaining "family" therapeutic counseling as recommended by Dr. Shienvold; in addition to Father and son counseling. Furthermore, Plaintiff refused to obtain mandatory counseling as recommended by Dr. Shienvold. Father's attorney attempted to clarify the aforementioned counseling with Mother's attorney. A true correspondence dated January 31, 2005 is attached hereto and marked as Exhibit A. Mother's attorney subsequently replied: "my client has even agreed to allow your client to set-up counseling sessions for Matthew at a counselor of Bill's choice". A true correspondence dated February 8, 2005 is attached hereto and marked as Exhibit B. By way of further answer, Father notified Mother of a Father/son counseling appointment (after-school on the Father's custodial Monday, March 7, 2005). A true correspondence dated March 4, 2005 is attached hereto and marked as Exhibit C. The Mother replied to Father's email "Please do not communicate with me through email". A true correspondence dated March 4, 2005 is attached hereto and marked as Exhibit D. By way of further answer, on the morning of March 7, 2005, the Mother blocked the Father and son counseling appointment. Mother stated: "Your custodial time does not start until 5PM today and I did not give prior approval for you to take Matthew of any of the children for counseling at this time". By way of further answer, Mother's attorney overrode Father's attempt to consult with the children's additional counselor (unilaterally selected by Mother) by stating: "advise your client that I have directed my client to set up regular appointments with Melanie and Matthew". However, all scheduled appointments are during the Father's working hours. A true correspondence dated March 8, 2005 is attached hereto and marked as Exhibit E. In response, Father's attorney stated: "To now suggest the she is concerned about the children's counseling seems a bit disingenuous given that all along it has been Bill who has tried to make this happen". A true correspondence dated March 8, 2005 is attached hereto and marked as Exhibit F. By way of further answer, Father believes and therefore avers that the custody schedule set forth in the October 10, 2003 order should remain in full force and effect. 7. Admitted. 8. Denied. Father denies that the custody schedule as recommended by Dr. Shienvold is in the children's best interests and therefore demands strict proof at trial. 9. Admitted. 10. Admitted. WHEREFORE, Defendant respectfully requests that the Court deny Plaintiff's Petition to Modify Custody Order. Respectively Sub d: By: G Dated: July 6, 2005 Ilis I Mc ormick 2 Hearthstone Court, Mechanicsburg, PA 17050 Telephone No. (717) 766-1561 The Defendant/Respondent VERIFICATION I, Willis J. McCormick II hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn verification to authorities. Date: is J. c rmick lI BECSIXY$ MADDEN AMTorursrs aT Lsw CRANB=wr coo= 819 Noza T"M 97a roerw.,mzsoaai... Hsazussorur; FVagNS T Valar s 17108-1998 moss. M% 98i saz. rn%288.Q1740 ra`a bwWerftxA t €!1 45200 January 31, 2005 Maria P. Cognetti, Esquire Maria P. Cognetti & Associates 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 RE: McCormick v. McCormick Dear Maria: Just to confirm with you I spoke with your associate Todd again last week about reviewing Mr. McCormick's documents. Todd has rescheduled the review of our files from February 3 to February 24 as you have several trials scheduled You may recall that you, I and the McCormicks discussed family therapeutic counseling as recommended by Dr. Shienvold at the December support conference. You were going to have Christine look into the same and provide us with the practice that is covered by the parties' insurance and who Christine would be willing to see. I have mentioned the therapeutic counseling twice to Todd, but have yet to receive a response on the same. Bill has indicated to us that Christine can contact Capital Blue Cross at 1-800- 962-2242 for a Preferred Provider. She can also use the website www.capbluecross.com. Frankly, it is my belief that Christine is doing everything that she can to avoid this counseling. We provided several suggestions for this prior to your involvement in this case but Christine has failed to respond to the some. Bill's concern regarding his son's alienation is increasing by the day. While we would prefer not to seek Court enforcement on this issue, if we do not have an answer on which practice Christine is willing to go to in the next two weeks, we will have no choice but to file a petition requesting the parties be ordered to attend. I'm hopeful with your assistance this will not be necessary. 66,6-? A -Omv,a BEC ImY&X"DZW Maria P. Cognetti, Esquire January 31, 2005 Page 2 I look forward to hearing from you shortly. Very truly yours, BECKLEY & MADDEN Elizabeth S. Beckley cc: Bill McCormick EKwb ',+ N. ?a4l) MARIA P. CoGNB= & A1.ssocIATFs Attorneys & Counselors at Law 210 0mndview Avenue, Suite 102# Camp Hill, IPA 17011 Tekphona (717) 909-4060 ? Fax (717) 9094068 Email CogneaiLaw@aolx= Maria P. co Proodee Limited to Moolmonial Law Todd C. Hough Attorney at taw *Fellow. Matrimonial Amcmeen Academy of Fellow, hnenudonal Academy of Matrimonial Lawyers February 8, 2005 Elizabeth S. Beckley, Esquire BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108-1998 RE. McCORMIC%v. McCORMIC% Our File No. 699 Dear Liesl: This letter is sent as a follow-up to your letter dated January 31, 2005. Quite honestly, I am amazed at your take on this situation. After receiving your letter, I contacted my client with regard to Bill's concern. The truth of the matter is that not only have our clients talked to each other about this issue but, moreover, my client has even agreed to allow your client to set-up counseling sessions for Matthew at a counselor of Bill's choice. Far from avoiding counseling, my client is encouraging your client to take Matthew to counseling and address those outstanding concerns that he may have. In the future, it would be my hope that prior to threatening Court action, you would be in contact with your client and be aware of all the facts prior to sending out any sort of accusatory letter. Thank you for your attention to this matter. Should you have any questions or concerns, please feel free to contact this office. Very truly yo Maria P. ogn MPC1af cc: Ms. Christine McCormick E?h, ik Y$I'?f.?0 MAIL Date: Mon, 7 Mar 2005 19:16:14 -0800 (PST) From: "Willis McCormick" <blllmccormlck777QyahoD.com> Subject: Fwd: Monday, March 7th appt To: "elizabeth beckley" <lieslepa.net> Print - Close Window Elizabeth, My first note to Christine...) also left a voice message on her answering machine after work. Melanie picked up near the and, God Bless her, so I know Christine listened to it also. forwarded message attached. Celebrate Yahool's 10th Birthdayl Ya_hooi Netro¢pective7 100 Moments of the Web Forwarded Message subject: MoIMa March nn appt Date: Fri, 4 Mar 2005 16:32:18 -0500 ____..__--_._-- From: 'Bill McCormick" <BMCCORMICK?PSEN.COM> To: dzu21lila0l.com HTML Attachment Christine, I will be picking the kids up from school Monday, March 7th at 3:30PM for a counseling appt at 4PM in Carlisle. The counselor is a referral from Mazetti-Sullivan.. I will send the details later as I am off to see my mom at the hospital. Also, I am requesting the kids' medical records/payments thus for 2005. Thanks, Bill Exk?,VA- Q-1 MAIL Print - Close Window From: CIZU2@aol.com _ Date: ri, 4 Mar 2005 22:57:15 EST? Subject: Re: Monday, March 7th appt To: BMCCORMICK@PSECU.COM, billmccormick777@yahoo.com, CIZU2@aol.com Please do not communicate with me through email since I do not always check my email on a regular basis. Please communicate with me only through our lawyers, over the telephone, or during pickup and drop-off times for the kids. I especially do not like responding to you over your employer's email system because of privacy issues with our children, etc. Thanks, Christine os/18/2008 10:01 FAX 717 909 4068 MARIA F COQ7ETfI MARIA P. CoGmt I & Assocuims Aawn*w & Cowudicrs at baw 210 amdwkw Avmoy Salve 102 ? Camp Mk FA 17011 Tdeph= (717) 9094060 ? Fax (717) 9094068 r4wa COPWAXw®wl oom Maria P. Cogqn?eW* An maymLaw *Fdbw, An aIM AMI&W of Fdbw6 dA? of MarrW10601 Lwyas Practice anted to Mairaeon d Law March 18, 2005 BYFAC4HAffi?EANA BYMAIL (7X7) 233-3740 Elizabeth S. Beckley, Esquire BECE LEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108-1998 RE. MCCORMHCSv. MCCORMICK Our Frle No. 699 Dear Liesl: Q UUY TAW at 1 am now back from nay meeting which took me out of the office for most of last week It is my understanding that we are still having serious problems with regard to the issues surrounding the counseling of our clients' tbree children. It is my understanding that the parties have, in fact, agreed that Marissa may continue in her counseling with Teddy Spencer. It is also my understanding that your client has been or will be notified of all such appointments. However, and more importantly, there appear to be rem, ; ing problems with regard to the issues surrounding counseling for Marisa and Matthew. You will recall that it was Marissa and Matthew for whom Dr. Shienvold had recommended such counseling. As you know, they have attended a joint session with Steffie Divine who is in the same. office as Teddy Spencer. As I am sure you know, the children, Matthew and Marissa, were to have another appointment with Steflie last week Your client refused to agree to allow this to happen until such time as he was able to meet with Steffie. He was offered to take the children's appointment last week in order to accomplish his desired goal of meeting with her. For whatever reason, he chose to decline that offer. At this point in time he does not have a meeting set with Steffie until April 18, 2005. We believe that is far too long to wait exh,6+ a (142) 03/18/2008 10:02 FAX 717 909 4088 HARIA P COGNETTI I®003 Elizabeth S. Beckley. Esquire March 18, 2005 Page 2 for the children to get on a regular counseling schedule with her. Therefore, please advise your client that x have directed my client to set up regular appointments with Melanie and Matthew for Steffie and to make sure that your client is notified as soon as each such appointment is made. The current schedule is as follows: March 24,@ 2:00 p.m. - Matthew; March 30 @ 3:00 p.m. - Matthew; April 4 @ 3:00 pm. - Melanie; April 7 @ 3:00 p.m. - Matthew; and April 11 @ 3:00 p.m. - Melanie. Your client is welcome and encouraged to attend these sessions and sit with my client while the children are.in their respective sessions. Please pass this information on to your client immediately. MPC/cfw cc: Ms. Christine McCormick Very truly yo Maria P ogn? BECHIMY& MADDICN ATTORNBYs AT Lew . cs ?co e12NORM TU?ST HARPMMURG, PENNSYLVANIA 17108-1998 RHOdi&' e1171 888A881 P-117171888.8740 ?1tea. bed&7@pa.met . March 18, 2005 Maria P. Cognetti, Esquire Maria P. Cognetti & Associates 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 RE: McCormick v. McCormick Dear Maria: ra.>m xo. 45200 I am in receipt of your letter of today's date. You may recall that counseling of the children has been a problem since long before you got in the case for the reason that Christine has refused to cooperate regarding the same. She has repeatedly been given counselors names and numbers which were covered by the parties' insurance but has declined to respond. If you read Dr. Shienvold's report more carefully, you'll see that he has recommended therapeutic family counseling. Again, Christine has vehemently refused to participate in this. To now suggest that she is so concerned about the children's counseling seems a bit disingenuous given that all along it has been Bill who has tried to make this happen. Furthermore, Bill has been trying to get Christine to agree on a counselor for himself and his son to see together, but again, Christine has refused to respond. As I have told you, your client does not feel a need to inform my client about anything regarding the children. While I do believe you've tried to get her to discontinue this practice, her idea of informing my client is to leave him a voicemail message the day an event is to happen with no notice whatsoever. If Bill was unable to take the children's appointment, it's probably because he was given no notice and already had something scheduled. Christine's version of what she communicates to Bill and Bill's version of the same are, and always have been, dramatically different. I have encouraged Bill to communicate with Christine in writing to avoid the he said/she said nonsense. Christine has directed Bill not to communicate via email. I have also instructed him to save the voicemails she leaves him so that it is clear when she has actually done so. I will give Bill a copy of your correspondence and let him decide about the BECRIXY& MADDEN Maria P. Cognetti, Esquire March 18, 2005 Page 2 children's counseling. As you know, it is not up to Christine to unilaterally make this decision. If he chooses to allow them to participate, then fine, but if he doesn't, then the parties will have to come to a mutual agreement on what counselor their children are going to see. Very truly yours, BECKL & DEN eckley cc: Bill McCormick -' rn 2 r: Ci z T CO cn W YRECEIVED JUL 252006 CHRISTINE L. MCCORMICK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. WILLIS J. MCCORMICK, II, Defendant OLER, J. --- ORDER OF COURT NO. 03-4235 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY AND NOW, this a5 (? day of July, 2005, upon consideration of the attached Custody Conciliation Summary Report, pending further Order of Court or an agreement of the parties, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Christine L. McCormick and Willis J. McCormick, II, shall have shared legal custody of the minor children, Matthew Ryan McCormick, born November 10, 1993; Marissa Loraine McCormick, born June 3, 1996; and Melanie Christine McCormick, born May 4, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the 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. 2. Physical Custody. Mother shall have temporary primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: A. To commence July 15, 2005, on alternating weekends from Friday at 4:30 p.m. until the following Monday morning when the children are returned to school. B. Each Wednesday, effective from July 13, 2005, from 4:30 p.m. overnight until Thursday morning, Father shall have custody of all children. y 1`t (?,Jn i i L! :n1'>I'll LG '',';. r S5?Z y Icj' r NO. 03-4235 CIVIL TERM 3. Effective July 11, 2005, each Monday from 4:30 p.m. to 9 p.m., Father will have partial custody with Matthew only. 4. Holidays. The following holiday schedule shall take precedence over the regular schedule: A. Thanksgiving. Thanksgiving shall be divided into two segments, Segment A and Segment B. Segment A shall be from 5:00 p.m. Wednesday until Noon on Saturday. Segment B shall be from Noon on the Saturday following Thanksgiving until Monday evening or Tuesday morning at the option of the parent who has Segment B. The parent with Segment B will give notice to the Segment A parent by November 1gt of each year as to whether or not the children will be returned on Monday evening or Tuesday morning. In the absence of such notice, the presumption will be that the children will be returned on Monday evening. In odd-numbered years, Father shall have Segment A and Mother shall have Segment B. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. B. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 24th at 2:00 p.m. until December 25th at 2:00 p.m. Segment B shall be December 25th at 2:00 p.m. until December 26th in the morning. In odd-numbered years, Mother shall have Segment A and Father shall have Segment B. In even-numbered years, Father shall have Segment A and Mother shall have Segment B. C. Alternating Holidays. The parties shall alternate custody for the following holidays commencing with Father having custody for Labor Day 2005: New Year's Day, Easter, Memorial Day, Independence Day, and Labor Day. The custodial period for these holidays shall be from 9:00 a.m. on the holiday until 9:00 a.m. the day after the holiday. D. Mother's Day and Father's Day_. Mother shall have custody for Mother's Day and Father shall have custody for Father's Day. The custodial period for these holidays shall be from 9:00 a.m. on the holiday until 9:00 a.m. the next morning. E. In the event that the children are out of school on a Monday for Martin Luther King Jr. Day, Columbus Day or President's Day, the parent with the custodial weekend preceding these holidays shall have their weekend extended until Tuesday morning when the children return to school. NO. 03-4235 CIVIL TERM 5. Vacation. Each party shall be entitled to two (2) non-consecutive weeks of custody for vacation which shall commence on the traveling parent's custodial weekend at 5:00 p.m. on Friday. The parties shall provide each other with at least thirty (30) days notice of their intended vacation. In the event of a conflict in vacation schedules, the parent to first provide written notice to the other parent shall have choice of the vacation time. Prior to departure, the traveling parent shall provide the other parent with written notice of the address and telephone number where they can be reached during the vacation period. 6. Transportation. Father will provide transportation at the beginning of his custodial periods and to school or the bus stop on those days when his custodial period ends with the children's return to school. Mother will assist in the transportation by picking up the girls from Father's custody at the end of his Wednesday evening visits. 7. Children's Birthday. The non-custodial parent shall be entitled to an hour and a half (1'/:) period of custody with each child on his or her birthday. 8. The parties shall participate in therapeutic family counseling to assist them in improving their ability to parent the children cooperatively. Father will provide Mother's counsel with a list of mental health/counseling providers that participate with his health insurance plan no later than July 15, 2005 in order to assist the parties in selecting a therapist that maximizes available health insurance coverage. BY THE COURT J. Wesley ler, . Dist: Kristopher T. Smull, Esquire, 210 Grand View Avenue, Suite 102, Camp Hill, PA 17011 Willis J. McCormick II, 2 Hearthstone Court, Mechanicsburg, PA 17050 '7-a -7,o, "Y = F'VED JUL 25 2W5 CHRISTINE L. MCCORMICK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 03-4235 CIVIL TERM V. WILLIS J. MCCORMICK, II, Defendant CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Matthew Ryan McCormick November 10, 1993 Marissa Loraine McCormick June 3, 1996 Melanie Christine McCormick May 4, 1998 Mother Mother Mother 2. Mother filed a Petition to Modify the Custody Order on May 19, 2005. A Custody Conciliation Conference was held on July 7, 2005. Attending the Conference were: the Mother, Christine L. McCormick, and her counsel, Kristopher T. Smull, Esquire; the Father, Willis J. McCormick II, participated pro se. 3. Mother's position on custody is that the parties should continue to follow the custodial schedule which they had been following at Dr. Shienvold's recommendation from sometime after his July 24, 2004 report was generated until May 5, 2005 when Father decided to return to the schedule in the Interim Order of October 10, 2003. She reports that she does not think Matt should be staying overnight with Father on Mondays by himself because it is easier for him to be in his routine at home getting ready for bed and sleeping in his own bed. She relates that he has difficulty being alone with his Father when his sisters are not there. He experiences some level of anxiety when his sisters are not present. Mother produced reports from the children's therapists with regard to their progress and the counseling that they are receiving related to adjustment issues around the divorce. Marissa is being treated separately for anxiety. The reports were not disclosed to Father until the time of the Custody Conciliation. NO. 03-4235 CIVIL TERM 4. Father filed an Answer to Mother's Petition on the morning of July 7, 2005. At the Conciliation, he expressed concerns about the process of getting the arrangements for the children to be in counseling and not getting updates from the therapist. He also complained that he has difficulty participating in their therapy because doing so might require him to take off time from work. In particular, Father is concerned that Matt seems alienated from him. He wants to participate in counseling with Matt to address this concern and work on healing their relationship. Father sees the overnight time on Mondays as valuable because he thinks it would make for better involvement and attachment between he and Matt. Routine activities such as going through the bedtime ritual and making and sharing breakfast together are valuable to Father in parenting Matt. 5. The parties worked on a number of issues beyond the Monday overnight custodial periods. It is obvious that they are both still in distress and pain related to their past marital relationship. Despite this, they worked patiently and diligently to reach a number of agreed modifications to the existing order. Additionally, the parties agreed to participate in therapeutic family counseling to address their own ability to work cooperatively in decision-making and parenting their children. They made significant progress in the Custody Conciliation. With structure and neutral party involvement in guiding the dialogue, they were able to find ommon ground even in the present their differences. 24 D to elissa Peel Greev, Es ire Custody Conciliator' :254207 RECEIVED AU6 2 a 7005ge CHRISTINE L. MCCORMICK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. WILLIS J. MCCORMICK, II, Defendant OLER, J. --- ORDER OF COURT NO. 03-4235 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY AND NOW, this VJ__ day of August, 2005, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Christine L. McCormick and Willis J. McCormick, II, shall have shared legal custody of the minor children, Matthew Ryan McCormick, born November 10, 1993; Marissa Loraine McCormick, born June 3, 1996; and Melanie Christine McCormick, born May 4, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the 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. 2. Physical Custody. Mother shall have temporary primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: A. To commence July 15, 2005, on alternating weekends from Friday at 5:00 p.m. until the following Monday morning. Father shall put Matthew on the bus from his home and deliver Marissa and Melanie to Mother at 7:30 a.m. B. Each Wednesday, effective from July 13, 2005, from 5:00 p.m. overnight until Thursday morning, Father shall have custody of all children. Father will put Matthew on the bus from his home and deliver Marissa and Melanie to Mother at 7:30 a.m. :J V LLLJ 1 W o :7 0 v U NO. 03-4235 CIVIL TERM 3. Effective July 11, 2005, each Monday from 5:00 p.m. to 9:00 p.m., Father will have partial custody with Matthew only. 4. Holidays. The following holiday schedule shall take precedence over the regular schedule: A. Thanksgiving. Thanksgiving shall be divided into two segments, Segment A and Segment B. Segment A shall be from 5:00 p.m. Wednesday until Noon on Saturday. Segment B shall be from Noon on the Saturday following Thanksgiving until Monday evening or Tuesday morning at the option of the parent who has Segment B. The parent with Segment B will give notice to the Segment A parent by November 1st of each year as to whether or not the children will be returned on Monday evening or Tuesday morning. In the absence of such notice, the presumption will be that the children will be returned on Monday evening. In odd-numbered years, Father shall have Segment A and Mother shall have Segment B. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. B. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 24th at 2:00 p.m. until December 25th at 2:00 p.m. Segment B shall be December 25th at 2:00 p.m. until December 26th in the morning. In odd-numbered years, Mother shall have Segment A and Father shall have Segment B. In even-numbered years, Father shall have Segment A and Mother shall have Segment B. C. Alternating Holidays. The parties shall alternate custody for the following holidays commencing with Mother having custody for Labor Day 2005: New Year's Day, Easter, Memorial Day, Independence Day, and Labor Day. The custodial period for these holidays shall be from 9:00 a.m. on the holiday until 9:00 a.m. the day after the holiday. D. Mother's Day and Father's Day. Mother shall have custody for Mother's Day and Father shall have custody for Father's Day. The custodial period for these holidays shall be from 9:00 a.m. on the holiday until 9:00 a.m. the next morning. E. In the event that the children are out of school on a Monday for Martin Luther King Jr. Day, Columbus Day or President's Day, the parent with the custodial weekend preceding these holidays shall have their weekend extended until Tuesday morning when the children return to school. NO. 03-4235 CIVIL TERM 5. Vacation. Each party shall be entitled to two (2) non-consecutive weeks of custody for vacation which shall commence on the traveling parent's custodial weekend at 5:00 p.m. on Friday. The parties shall provide each other with at least thirty (30) days notice of their intended vacation. In the event of a conflict in vacation schedules, the parent to first provide written notice to the other parent shall have choice of the vacation time. Prior to departure, the traveling parent shall provide the other parent with written notice of the address and telephone number where they can be reached during the vacation period. 6. Transportation. Mother will provide transportation at the beginning of Father's custodial periods on Wednesdays at 5:00 p.m. Otherwise, Father will provide transportation incident to the custodial exchanges. The 7:30 a.m. time that Father is to drop off the girls with Mother on the alternating Mondays and Thursday mornings was selected prior to knowing the schedule for Matthew's bus schedule on those mornings at Father's residence. Therefore, the parties may need to be flexible to accommodate a different morning drop off time for the girls after the bus schedule for Matthew is known. Father and Mother will provide each other with a telephone call in the event that they would be more than 10 minutes ahead of schedule or behind schedule for custodial exchanges. 7. Children's Birthday. The non-custodial parent shall be entitled to an hour and a half (1'%) period of custody with each child on his or her birthday. 8. The parties shall participate in therapeutic family counseling to assist them in improving their ability to parent the children cooperatively. Father will provide Mother's counsel with a list of mental health/counseling providers that participate with his health insurance plan no later than July 15, 2005 in order to assist the parties in selecting a therapist that maximizes available health insurance coverage. With regard to therapeutic work to be done in the relationship with Father and Matthew, Matthew's therapist, Steffi Ambrose Devine will be consulted for a clinical determination as to whether she can serve in this role in light of her present relationship as Matthew's individual therapist. BY THE COURT: J. Wesley 119ler; 4. J. Dist: ,Xristopher T. $mull, Esquire, 210 Grand View Avenue, Suite 102, Camp Hill, PA 17011 ,,Allis J. McCk II, 2 Hearthstone Court, Mechanicsburg, PA 17050 V ` ilf' TV 0$' T CHRISTINE L. MCCORMICK, Plaintiff V. WILLIS J. MCCORMICK, II, Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: RECEIVED A?'G 2 3 2001)4? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4235 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY 1. The pertinent information concerning the children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Matthew Ryan McCormick November 10, 1993 Marissa Loraine McCormick June 3, 1996 Melanie Christine McCormick May 4, 1998 Mother Mother Mother 2. The parties' second Custody Conciliation Conference was held on July 7, 2005. Subsequent to the Conference, additional clarification of the Order was sought by the Father, pro se and by Mother's counsel. A telephone conference was held on August 16, 2005. The parties were able to reach an agreement with regard to the modification of the Order in the form 7ched. ate Melissa Peel Greevy, Esq ire Custody Conciliator :256938 MARIA P. COGNETTI & ASSOCIATES KRISTOPHER T. SMULL, ESQUIRE Attorney I.D. No. 69140 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff/Petitioner CHRISTINE L. McCORMICK, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIS J. McCORMICK, II, Defendant/Respondent No. 03-4235 CIVIL ACTION - LAW IN CUSTODY PETITION TO MODIFY CUSTODY ORDER AND NOW, comes the Petitioner, Christine L. McCormick, by and through her attorney, Kristopher T. Smull, and files the following Petition to Modify Custody Order, and in support thereof avers as follows: 1. Petitioner is Christine L. McCormick (hereinafter "Mother"), Plaintiff in the above- referenced action. 2. Respondent is Willis J. McCormick, II (hereinafter "Father"), Defendant in the above- referenced action. 3. The parties hereto are the natural parents of three (3) minor children, namely: Matthew R. McCormick, born November 10, 1993; Marissa L. McCormick, born June 3, 1996; and Melanie C. McCormick, born May 4, 1998. 4. The above minor children are the subject of a Custody Order dated August 23, 2005. Pursuant to the Order the parties share legal custody of the children with primary physical custody being vested in Mother, and partial physical custody in Father, on alternating weekends from Friday through Monday; every Monday evening from 5:00 until 9:00 p.m. with Matthew only; and Wednesday overnight until Thursday morning with all three children. A true and correct copy of said Order is attached hereto and marked as Exhibit "A." 5. Since the entry of the Order of Court of August 23, 2005 Father has voluntarily relinquished his Monday visitation with Matthew based upon the child's request. 6. Mother believes that it is in the best interest of the children to modify the Order of Court of August 23, 2005 to eliminate Father's Sunday overnight and his midweek overnight for the following reasons: a. When Father has overnight visitation with the children on school nights, he fails to have them prepared for school the next day, often leaving it to Mother to prepare the girls' homework assignments at the last minute in the morning before school. b. Father regularly drops the girls off at Mother's home prior to school without having fed them breakfast and Matthew is often sent to school without being fed a sufficient breakfast. C. Due to the children's schedule of activities, the midweek overnight visit becomes very disruptive for them. d. The children have expressed to Mother their displeasure with spending overnights during school with Father due to the disruption, and have pleaded with her to change the schedule. The children are growing more and more stressed about forgetting papers, books, and other important school items. e. The children have expressed to Mother that they do not feel safe and secure when they are with Father. f. The parties attempted to participate in therapeutic family counseling, as agreed upon in their prior Order; however, Father was so difficult and uncooperative that the counselor refused to continue the counseling after only two and one-half (21/2) sessions. 7. The best interest and permanent welfare of the children will be served by granting Mother's requested relief. 8. A copy of this Petition to Modify has been sent to Father directly, as he is proceeding Pro Se. WHEREFORE, Mother respectfully requests this Honorable Court grant her requested relief. Respectfully Submitted: MARIA P GNETTJ & ASSOCIATES Date: 9/27/06 By: KRIS HER T. SMULL, ESQUIRE Attorney I.D. No. 69140 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff/Petitioner I , CHRISTINE L. MCCORMICK, Plaintiff V. WILLIS J. MCCORMICK, ll, Defendant RrECEIVED AUG 2 3 2005 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4235 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY OLER, J. --- ORDER OF COURT AND NOW, this day of August, 2005, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Christine L. McCormick and Willis J. McCormick, ll, shall have shared legal custody of the minor children, Matthew Ryan McCormick, born November 10, 19.93; Marissa Loraine McCormick, born June 3, 1996; and Melanie Christine McCormick, born May 4, 1998. Each parent shall have an equ-al right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 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. 2. Physical Custody. Mother shall have temporary primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: . A. To commence July 15, 2005, on alternating weekends from Friday at 5:00 p.m. until the following Monday morning. Father shall put Matthew on the bus from his home and deliver Marissa and Melanie to Mother at 7:30 a.m. B. Each Wednesday, effective from July 13, 2005, from 5:00 p.m. overnight until Thursday morning, Father shall have custody of all children. Father will put Matthew on the bus from his home and deliver Marissa and Melanie to Mother at 7:30 a.m. ,A. ?, SC NO. 034235 CIVIL TERM 3. Effective July 11, 2005, each Monday from 5:00 p.m. to 9:00 p.m., Father will have partial custody with Matthew only. 4. Holidays. The following holiday schedule shall take precedence over the regular schedule: A. Thanksgiving. Thanksgiving shall be divided into two segments, Segment A and Segment B. Segment A shall be from 5:00 p.m. Wednesday until Noon on Saturday. Segment B shall be from Noon on the Saturday following Thanksgiving until Monday evening or Tuesday morning at the option of the parent who has Segment B. The parent with Segment B will give notice to. the Segment A parent by November 1St of each year as to whether or not the children will be returned on Monday evening or Tuesday morning. In the absence of such notice, the presumption will be that the children will be returned on Monday evening. In odd-numbered years, Father shall have Segment A and Mother shall have Segment B. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. B. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 24th at 2:00 p.m. until December 25th at 2:00 p.m. Segment B shall be December 25th at 2:00 p.m. until December 26th in the morning. In odd-numbered years, Mother shall have Segment A and Father shall have Segment B. In even-numbered years, Father shall have Segment A and Mother shall have Segment B. C. Alternating Holidays. The parties shall alternate custody for the following holidays commencing with Mother having custody for Labor Day 2005: New Year's Day, Easter, Memorial Day, Independence Day, and Labor Day. The custodial period for these holidays shall be from 9:00 a.m. on the holiday until 9:00 a.m. the day after the holiday. D. Mother's Day and Father's Dam Mother shall have custody for Mother's Day and Father shall have custody for Father's Day. The custodial period for these holidays shall be from 9:00 a.m. on the holiday until 9:00 a.m. the next morning. E. In the event that the children are out of school on a Monday for Martin Luther King Jr. Day, Columbus Day or President's Day, the parent with the custodial weekend preceding these holidays shall have their weekend extended until Tuesday morning when the children return to school. NO. 03-4235 CIVIL TERM 5. Vacation. Each party shall be entitled to two (2) non-consecutive weeks of custody for vacation which shall commence on the traveling parent's custodial weekend at 5:00 p.m. on Friday. The parties shall provide each other with at least thirty (30) days notice of their intended vacation. In the event of a conflict in vacation schedules, the parent to first provide written notice to the other parent shall have choice of the vacation time. Prior to departure, the traveling parent shall provide the other parent with written notice of the address and telephone number where they can be reached during the vacation period. 6. Transportation. Mother will provide transportation at the beginning of Father's custodial periods on Wednesdays at 5:00 p.m. Otherwise, Father will provide transportation incident to the custodial exchanges. The 7:30 a.m. time that Father is to drop off the girls with Mother on the alternating Mondays and Thursday mornings was selected prior to knowing the schedule for Matthew's bus schedule on those mornings at Father's residence. Therefore, the parties may need to be flexible to accommodate a different morning drop off time for the girls after the bus schedule for Matthew is known. Father and Mother will provide each other with a telephone call in the event that they would be more than 10 minutes ahead of schedule or behind schedule for custodial exchanges. 7. Children's Birthday. The non-custodial parent shall be entitled to an hour and a half (1'/2) period of custody with each child on his or her birthday. 8. The parties shall participate in therapeutic family counseling to assist them in improving their ability to parent the children cooperatively. Father will provide Mother's counsel with a list of mental health/counseling providers that participate with his health insurance plan no later than July 15, 2005 in order to assist the parties in selecting a therapist that maximizes available health insurance coverage. With regard to therapeutic work to be done in the relationship with Father and Matthew, Matthew's therapist, Steffi Ambrose Devine will be consulted for a clinical determination as to whether she can serve in this role in light of her present relationship as Matthew's individual therapist. BY THE COURT: J. Wes-ley OI Jr., J. Dist: Kristopher T. Smull, Esquire, 210 Grand View Avenue, Suite 102, Camp Hill, PA 17011 Willis J. McCormick II, 2 Hearthstone Court, Mechanicsburg, PA 17050 TRUE COPY ERONA RECORD In Tes 'many 4whnreof, he&utosset my hand and se f f said C a Pa. Thi ...... .. day o.. ry VERIFICATION I, Christine L. McCormick, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.. C.S.A. §4904 relating to unsworn verification to authorities. Date: ' hristine L. McCormick CERTIFICATE OF SERVICE I, Kristopher T. Smull, Attorney for Plaintiff/Petitioner herein, do hereby certify that on this date I served the foregoing Petition to Modify Custody Order by depositing a true and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Willis J. McCormick, II 2 Hearthstone Court Mechanicsburg, PA 17050 MARIA P. COGNETTI & ASSOCIATES At C/ Date: I By: v KRISTOPHER T. SMULL, ESQUIRE Attorney I.D. No. 69140 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff?etitioner V w W ? C -n -TA Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINE L. MCCORMICK Plaintiff V. NO. 03-4235 Civil Term WILLIS J. MCCORMICK, II ; Defendant CIVIL ACTION - CUSTODY PRAECIPE TO THE PROTHONOTARY: Please enter the appearance of Theresa Barrett Male, Esquire on behalf of Defendant in this proceeding. 0(-4OF hL- 1---1 - , Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Defendant Date: October 3, 2006 0 1[7- i _ A 7-7 Zrl G co ^ CHRISTINE L. MCCORMICK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIS J. MCCORMICK, II DEFENDANT 03-4235 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Thursday, October 05, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Tuesday, November 07, 2006 at 8:30 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/ Melissa P. Gree Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ?v -!Y? M7 * ?a -,? 0/ 4op --/v 4 f?mr? f:kn GO :Zj p! n AU 1_ a -? L Nov $12006 CHRISTINE L. MCCORMICK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 03-4235 CIVIL TERM V. CIVIL ACTION - LAW WILLIS J. MCCORMICK, II, IN CUSTODY Defendant OLER, J. - - ORDER OF COURT AND NOW, this _ , _L5 day of November, 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Each parent shall sign the appropriate authorization to release confidential information from the children's therapists, Teddy Spencer and Stephanie Devine, to Father's therapist, Debra Salem. The purposes of the contact between the therapist for Father and the therapist for the children is to assist Ms. Salem in understanding what might be helpful to assist Father with the difficulties in the relation between he and his children. Accordingly, the parties will cooperate with the exchange of this confidential information and if it is thought to be clinically appropriate to do so the children shall be permitted to participate in therapeutic sessions with Ms. Salem and Father and which may or may not include the children's therapists. 2. A hearing is scheduled in Courtroom Number 1 of the Cumberland County Courthouse, on the Qtk day of ' yXAt ,, c47, at o'clock _AL.M., at which time testimony will be taken. For th purposes of the hearing, the Mother, Christine L. McCormick, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of exhibits, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda, lists of exhibits, lists of witnesses and summaries of anticipated testimony of each witness shall be filed at least ten days prior to the hearing date. BY THE COURT: Oler, Dist: topher T. Smull, Esquire, 210 Grand View Avenue, Suite 102, Camp Hill, PA 1701 eresa Barrett Male, Esquire, 513 N. Second St., Harrisburg, PA 17101 4 ?p VINV'AIASWd AINn', . . iWO " ? •01 WV 8Z AON 9002 AUVIONC,HiVd'd 3Nl dU 30U.'o-omu CHRISTINE L. MCCORMICK, Plaintiff V. WILLIS J. MCCORMICK, II, Defendant mor 1120M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4235 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Matthew Ryan McCormick November 10, 1993 Mother Marissa Loraine McCormick June 3, 1996 Mother Melanie Christine McCormick May 4, 1998 Mother 2. Mother filed a Petition to Modify Custody Order on September 28, 2006. A Custody Conciliation Conference was held on November 7, 2006 with the following individuals in attendance: the Mother, Christine L. McCormick, and her counsel, Kris T. Smull, Esquire; the Father, Willis J. McCormick, and his new counsel, Theresa Barrett Male, Esquire. 3. Mother's Position on Custody is as Follows: Mother wants to discontinue the overnight periods of custody with Father on Sundays and Wednesdays. Mother complains of Father not doing homework with the children, Father not feeding them breakfast or insufficient breakfast, and the children being stressed about forgetting items they need for school. Mother reports that the children do not feel safe and secure with Father and that the present schedule is disruptive to them. She reports the parties participated in therapeutic family counseling but that the counseling was discontinued by the counselor after two and a half sessions. Mother attributes the counselor's decision to Father's behavior. Mother reports that Father belittles the children by questioning the teenage son's sexual orientation and making comments such as "I hope the ball hits you in the head." Mother also reports that Father did not allow the daughter to go to an end-of-season ice cream party with her soccer team. Since the filing of Mother's Petition she reports that Father has been a little bit better about overseeing the homework. Mother's counsel acknowledges that the parties do not communicate. Mother feels strongly that Father need to address certain issues in NO. 03-4235 CIVIL TERM individual psychotherapy before he will be able to work effectively on the relationship with his children. 4. Father's Position on Custody is as Follows: Father apparently began to see Deborah Salem for individual therapy last year upon referral from his attorney. Ms. Salem attempted to work with the children's counselors in order to better understand the trouble in the relationship between Father and the children. However, Ms. Salem reports that she was stonewalled by the counselors for the children. Accordingly she has not been able to work with him to understand the strain in the relationship. This has reportedly impaired her ability to assist Father. Father complains that Mother does not communicate with him and that Mother gives him no notice of school or medical events. He reports that the children do not bring their homework with them on Wednesdays on a consistent basis. Father complains there are difficulties at custodial exchanges because Mother's boyfriend's car blocks the driveway and because Mother objects to the children walking through the grass when he tries to pick up the children at curbside. Father also complains that Mother made a unilateral decision to start the children in CCD and raise them as Catholic. With regard to the concern raised about breakfast, Father reports that the children preferred to sleep later in the morning so that they could eat at Mother's home. Unfortunately, because the parties literally do not communicate with each other there was no discussion between the parents about his decision to stop feeding the children breakfast on Monday and Wednesday mornings. 5. The parties were able to reach an agreement, although Mother was reluctant, to sign consents for the release of confidential information so that Father's therapist, Deborah Salem, and the children's therapists, Teddy Spencer and Stephanie Devine, would be able to speak with each other regarding the children and the difficulty in the relation between Father and the children. Additionally, Father would like for Ms. Salem to be able to observe him with the children and to meet with the children so that she can better understand the dynamic in the relationship and be able to help him address the concerns. However, the parties have not reached an agreement with regard to Mother's request to further reduce Father's custodial time. Accordingly, a hearing will be necessary. Counsel have requested one day for purposes of this hearing. 6. It is noted that this family is one in which the tensions and conflict that existed when they first entered conciliation have not improved. The chronicity and level of conflict is of great concern because of the impact on the children. Whatever the Court may do with the schedule, if the parties cannot conduct themselves in a less conflictual fashion and the issues that are leading to the difficulties in the relationship between Father and the children are not adequately addressed; changing the schedule will have little impact. There has been concern that there is alienation between Father and the children. Both parties point 10 NO. 03-4235 CIVIL TERM the finger of blame at each other, but have not been able to garner th ility to focus on the children's need to address what needs to happen without regard to ho is at fault. l I (o Date Ntelissa Peel Greevy, Esquire Custody Conciliator :286594 I.. L\Chent Directory\McCormick-C\Pleadings\Custody Pleadings\Praecipe to Withdrawl Custody Modification.wpd MARIA P. COGNETTI & ASSOCIATES KRISTOPHER T. SMULL, ESQUIRE Attorney I.D. No. 69140 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 February 13, 2007 Attorneys for Plaintiff CHRISTINE L. MCCORMICK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 03-4235 WILLIS J. McCORMICK, IL : CIVIL ACTION - LAW Defendant : IN CUSTODY PRAECIPE TO WITHDRAW PETITION FOR CUSTODY MODIFICATION TO THE PROTHONOTARY: Kindly withdraw Plaintiff's Petition for Custody Modification filed September 28, 2006, in the above-captioned matter and cancel the Hearing scheduled for March 12, 2007. Respectfully Submitted: & ASSOCIATES Date: February 13, 2007 By: KRIVTOPHER T. SMULL, ESQUIRE Attorney I.D. No. 69140 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff f IAChent Directory\McCormick-C\Pleadings\Custody Pleadings\Praecipe to Withdrawl Custody Modificationmpd February 13, 2007 CERTIFICATE OF SERVICE I, Kristopher T. Smull, Esquire, Attorney for Plaintiffherein, do hereby certify that on this date I served the foregoing Praecipe to Withdraw Petition for Custody Modification by depositing a true and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Theresa Barrett Male, Esquire 513 North Second Street Harrisburg, PA 17101 Honorable J. Wesley Oler Jr. Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 MARIA P. COGNETTI & ASSOCIATES Date: February 13, 2007 By: KRIS'FOPHER T.`SMML? ESQUIRE Attorney I.D. No. 69140 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff OD Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINE L. MCCORMICK Plaintiff/Respondent V. NO. 03-4235 Civil Term WILLIS J. MCCORMICK, II Defendant/Petitioner CIVIL ACTION - CUSTODY DEFENDANT'S PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER The Petition of Defendant Willis J. McCormick, II, respectfully represents: 1. That on November 28, 2006, the Honorable J. Wesley Oler entered an Order regarding the parties' children, Matthew McCormick (dob: 11/10/93), Marissa McCormick (dob: 06/03/95) and Melanie McCormick (dob: 05/04/98). A true and correct copy of the order is attached to this petition as Exhibit 1. 2. Respondent has wilfully failed to abide by the order in that: a. In relevant part, the order provides: Each parent shall sign the appropriate authorization to release confidential information from the children's therapists, Teddy Spencer and Stephanie Devine, to Father's therapist, Debra Salem. The purposes of the contact between the therapist for Father and the therapist[s] for the children is to assist Ms. Salem in understanding what might be helpful to assist Father with the difficulties in the relation between he and his children. Accordingly, the parties will cooperate with the exchange of this confidential information and if it is thought to be clinically appropriate to do so the children shall be permitted to participate in therapeutic sessions with Ms. Salem and Father and which may or may not include the children's therapists. Order at I I (emphasis added). b. Respondent refuses to execute the authorizations. 3. That on August 23, 2005, the Honorable J. Wesley Oler entered an Order which, inter alia, provided for shared legal custody of the parties' children. A true and correct copy of the order is attached to this petition as Exhibit 2. 4. Respondent has wilfully failed to abide by the order in that Respondent has disenfranchised Petitioner from all major decisions regarding the children, including medical and dental treatment, and even changed the children's religion without notice to or consultation with Father. 2 Wherefore, Petitioner requests that Respondent be held in contempt of court. //? X? Theresa Barrett Male, Esquire Supreme Court #46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Petitioner Date: October 22, 2007 3 NDV 1120 CHRISTINE L. MCCORMICK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 03-4235 CIVIL TERM V. CIVIL ACTION - LAW WILLIS J. MCCORMICK, II, IN CUSTODY Defendant OLER, J. - - ORDER OF COURT AND NOW, this ),9A day of November, 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Each parent shall sign the appropriate authorization to release confidential information from the children's therapists, Teddy Spencer and Stephanie Devine, to Father's therapist, Debra Salem. The purposes of the contact between the therapist for Father and the therapist for the children is to assist Ms. Salem in understanding what might be helpful to assist Father with the difficulties in the relation between he and his children. Accordingly, the parties will cooperate with the exchange of this confidential information and if it is thought to be clinically appropriate to do so the children shall be permitted to participate in therapeutic sessions with Ms. Salem and Father and which may or may not include the children's therapists. 2. A hearing is scheduled in Courtroom Number 1 of the Cumberland County Courthouse, on the day of CL&A . 7 Oft, at 9:30 o'clock J?_.M., at which time testimony will be taken. For the purposes of the hearing, the Mother, Christine L. McCormick, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of exhibits, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda, lists of exhibits, lists of witnesses and summaries of anticipated testimony of each witness shall be filed at least ten days prior to the hearing date. BY THE COUR ?S ?Jjf lj? A I I A J. Wesley Oler Jr., J. TRUE COPY FROM RECORD Dist: Kris rand view Avenue, Suite 102, Camp W.ftliflK ,.,_^t_ I In r 1;nto :,at my hand The r I i N. Second St., Harrisburg, PA 17101 _ lJ a t 1.... sea[ A ? e, Pa. NOV ....1.?.?_. :. ?Q ?....., 3 0 2006 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: October Z:L , 2007 14 10%03/2006 08:03 FAX 17176053OP" NETWORK 1x006 RECEIVED AUG 2 3 2005 sue,: CHRISTINE L. MCCORMICK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 03-4235 CIVIL TERM V. : . CIVIL ACTION - LAW - WILLIS J. MCCORMICK; II, IN CUSTODY Defendant OLEk, J. - ORDER OF COURT f? AND NQWI this day of August,' 2005, upon consideration of the attached Custody Conciliation Summary- Report, it is hereby ordered and directed as follows- L 1. Legal Custody. The parties, Christine L. McCormick and Willis J. McCormick, II, shall have shared legal custody of the minor children, Matthew Ryan McCormick, born - November 10, 1993; Marissa Loraine McCormick, born June 3, 1996; and Melanie Christine. McCormick, born *May 4, 1995. •• Each.parent shall have an equal right, to be exercised jointly with the other parent, to, make all, major non?bmergency decisions affecting the children's general well-being ihclud'ipg;. but not limited to, all decisions regarding their health, education and 'religion. Pursuant tq the terms of Pa. C. S. §5309, each parent shall be entitled. to all .records and information. peitoinin_4 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 pgssession of any such. records or information; fhat- parent shall be required .to share the same, or copies- thereof, with the other parent within such reasonable time as to make -the records and information • of reasonable use to the other parent. 2. Physical Custody. Mother..shall have temporary. primary physical custody subject to f .ather`s' rights of partial custody which shall pe errariged as follows: A:' To commence July 15, 20051 on alternating weekends from Friday * at 5:00 p.m. until the following Mbnday moming. Father shall put Matthew o0 the bus from his home and deliver Marissa and Melanie to Mother at 7:30• a.m. B. - Each Wednesday, .effective from July 13, 2005, from 5:00 p.m. overnight until .Thursday morning, Father shall have custody of all children. Father will put Matthew on the bus from his home and deliver Marissa and Melanie to -Mother at 7:30 a.m. 10'/03/2006 08:04 FAX 171760530F' NETWORK [a 007 l , NO. 03-4235 CIVIL TERM 3. Effective July. 11,, 2005, each Monday from 5:00 p.m. to 9:00 p.m., Father will have partial custody with Matthew only. 4. Holidays. The following holiday schedule shall take precedence over the regular schedule: A. Thanksgiving. Thanksgiving shall be divided into two segments, Segment A and Segment B. Segment A shall be from 5:00 p.m. Wednesday until Noon on Saturday: Segment B shall be from Noon on-the Saturday following Thanksgiving until Monday evening or-Tuesday-morning at the option of the parent who has Segment B. The parent with Segment B will give notice to. the Segment A parent by November 151 of each yeAr as to whether or not the children will be returned on Monday evening- or Tuesday morning. In the absence of such notice, the presumption will be that- the children. will be returned on Monday. evening. In odd-numbered .years, Father shall have. Segment A and. Mother shall have Segment B. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. B. Christmas. Christmas ..shall be- divided into two' segments, Segment A and- Segment B: Segment A shall be from December 24th- at 2:00 p.m. until December 25!' at 2:00 p.m. Segment B shall be December 25th at 2:00 p.m. until Becerriber-26th in the morning. In odd-numbered years; Mother shall i'iave Segment-A and Father shall have Segment B. In eyeri-numbered years, Father shall have Segment •A and Mother shall have Segmerit,B. C. Alternating Holidays. The parties shall alternate custody for the. following holidays commencing. With .Mother haying-custody for Labor Day 2005: New Year's Day, Easter, Memorial Day, Independence Day' and Labor Day. The custodial period for these holidays shall be frorri 9:00 a.m'. on the holiday.Lintil 9:00 a.m. the day after the holiday. D. Mother's Day and Father's Day. 'Mother shall have custody for Mother's Day and Father shall. have custody for Father's. Day. The custodial period for these holidays.'shall be from 9:00 a.m. on the holiday until 9:00 a.m. the next morn'irig. E. In the event that the children are out of school on a Monday for Martin Luther King Jr. Day, Columbus Day or President's Day, the parent with the custodial weekend preceding. these holidays shall have their weekend extended until Tuesday morning when the children retuFn to-school. 10'/03/20-06 08:04 FAY 171760530?P' NETWORK IM 008 NO. 03-4235 CIVIL TERM 5. Vacation. Each. party shall be. entitled to two (2) non-consecutive Weeks of custody for vacation which shall* commence on the traveling parent's-custodial•weekend at 5:00 'p.m. on Friday. The parties shall provide each other with, at least thirty (30) days notice of their intended vacation. In the event of a corifiict in vacation schedules, the parent to first provide written notice to the other parent shall have choice of the vacation time, prior to departure, the-traveling parent shall provide -the other parent With written notice of the address and telephone number where they can be reached during the vacation period. 6. Transportation. Mother will provide transportation at the beginning of Father's custodial periods on Wednesdays at 5:00 p.m. Otherwise, Father will provide transportation incident to the custodial exchanges. The 7:30 a.m. time that Father is to drop off the girls with Mother on the alternating, Mondays and Thursday mornings was selected prior to knowing the schedule for Matthew's bus schedule on those mornings at Father's 'residence. Therefore, the parties may need to be flexible to accommodate a 'different morning drop off time for the girls after the bus schedule for Matthew is known. Father and Mother will provide 'each other with a telephone call in the event that they would be More than 10 minutes ahead of schedule or behind schedule for custodial exchanges.. 7. Children's Birthday. The non-custodial parent. shall be entitled to an hour and a half (1 %) period of custody with each child on his or her birthday. .8. The 'parties shall participate in therapeutic-family counseling to assist them in improving their ability to parent. the children cooperatively. Father will -provide Mother's counsel with a list of mental- health/counseling providers that participate with ' his health insurance plan no' later than July. 15, 2005 in order to- assist the parties in selecting a therapist that maximizes available health insurance coverage. With regard to* therapeutic work to be done in the relationship with Father. and Matthew, Matthew's therapist, SteM Ambrose- Devine Will be 'consulted -for a. clinical determination as to whether she can serve -iri this role in light' of her present- relationship as Matthew's individual. therapist. BY THE COURT:' J. Wesley Ole, Jr., J. Dist: Kristopher T. Smull, Esquire, 210 Grand View Avenue, Sulte 102, Camp HUI, PA 17011- Willis J. McCormick li, 2 Hearthstone Court, Mechanicsburg, PA 17050 " TRUE COPY FRO RE" COR® In Tes mony. whereof, Y here u o set- my hand e rlisl$,'Pa. and se of. Said .X t . 7hi . 0 d &I i'm AIM 3 PROOF OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the persons and in the manner indicated below which service satisfies the requirements of Pa. R.C.P. 440: Service by first-class mail addressed as follows: Kristopher T. Smull, Esquire Maria P. Cognetti & Associates 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Attorneys for Plaintiff /Z"/? /?,-; Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Defendant Date: October 23, 2007 C'y na :. -?- . f ?Y . VI) CD A .40 CHRISTINE L. MCCORMICK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2003-4235 CIVIL ACTION LAW WILLIS J. MCCORMICK, II IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, October 30, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, November 27, 2007 at 12:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ Dawn S. Sunda Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 i :(, 1_,?d 1- AM L05Z DEC 17 2007#4 CHRISTINE L. McCORMICK Plaintiff vs. WILLIS J. McCORMICK, II Defendant Prior Judge: J. Wesley Oler IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2003-4235 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Matthew McCormick November 10, 1993 Mother Marissa McCormick June 3, 1995 Mother Melanie McCormick May 4, 1998 Mother 2. A custody conciliation conference was held on December 13, 2007, with the following individuals in attendance: the Mother, Christine L. McCormick, with her counsel, Kristopher T. Smull, Esquire, and the Father, Willis J. McCormick, II, with his counsel, Andrea H. Duffy, Esquire. The maternal grandparents and all three Children accompanied the Mother to the conciliator's office but did not participate in the conference. 3. The Father filed this Petition for Contempt seeking enforcement of the prior Order of this Court dated November 28, 2006 requiring both parties to sign the necessary authorizations to facilitate release of confidential information between the Children's therapists and the Father's therapist. 4. As the serious conflict and antagonism between the parties was clearly apparent at the conference, there was considerable discussion concerning the option of co-parenting counseling to establish a more constructive parenting relationship for the well-being of the Children. It is hoped that the parties will continue to consider this alternative as a means of resolving existing disputes and those arising in the future. 5. As all parties signed the authorizations which the Father provided from Debra Salem's office at the conciliation conference, the contempt issues have been resolved and there is no further need for an additional Order at this time. Date Dawn S. Sunday, Esquire Custody Conciliator cc:? ea Duffy, Esquire - Counsel for Father stopher T. Smull, Esquire - Counsel for Mother c ?? o V?WAIAS,NN3d ?anrm c, ? Z :ZI Wd 81 330 LODZ KdVI HiO8d 3HI Law Office of Theresa Barrett Male Theresa Barrett Male, Esquire ID # 46439 Andrea Hudak Duffy, Esquire ID # 60910 North Second Strut F;13 !'rrisburg„ PA 175.01-1058 (717) 233-3220 tbm@kbn?esaui re.corr? Attorneys for Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C"RISTINE L. MCCORMICK Plaintiff V, NO. 03-4235 Civil Term WILLIS J. MCCORMICK, II Defendant CIVIL ACTION - CUSTODY PRAECIPE To the Prothonotary: Pleas ? {bdt ? tie= ??r?ce of The Law Office of There - etTetfi=?4e ???,I,? on behalf of Defendant and enter the appearance of Willis J. McCormick,, II,- prom 2008 ? Date: May Theresa Barrett Male, Esquire ,. e Date: May , 2009 cC imic , 1 Cr c co CHRISTINE L. McCORMICK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. No. 03-4235 CIVIL TERM CIVIL ACTION - LAW WILLIS J. McCORMICK, H, IN CUSTODY Defendant The Honorable J. Wesley Oler PETTTION TO MODIFY CUSTODY 1. Petitioner is Christine L. McCormick, who resides at 18 Wheatfield Drive, Carlisle, Pennsylvania 17015. 2. Respondent is Willis J. McCormick, H, who resides at 2 Hearthstone Court, Mechanicsburg, Pennsylvania 17050. 3. Petitioner and Respondent are the natural parents of Matthew Ryan McCormick, born November 10, 1993, Marissa Loraine McCormick, born June 3, 1996, and Melanie Christine McCormick, born May 4, 1998. 4. An Order of Court entered by the Honorable J. Wesley Oler was entered on August 23, 2005, granting shared legal custody, with Mother having temporary primary physical custody subject to Father's rights of partial custody on alternating weekends and every Wednesday overnight until Thursday morning. 5. Since the entry of said Order, there has been a significant change in circumstances in that: a. On January 25, 2009, Father and Mother were at a basketball game, wherein a mandatory reporter for the Department of Welfare was present and the reporter contacted Children & Youth Services as well as the police department because of the way Father was treating the minor children. b. An investigation ensued, it was determined that the minor children are fearful of Father due to mental and physical abuse. c. Father's paramour has an 18 year old mentally challenged son who has inappropriately touched one of the minor daughters and the incident has been reported to the police. d. Father made indications he would be willing to give up visitation. 6. The best interest of the children will be served by the Court modifying said Order. WHEREFORE, Petitioner prays this Court to grant the modification ofthe Custody Order as follows: Mother having primary physical custody of the minor children with Father having periods of supervised visitation as agreed by the parties. RespecMy Submitted, Rominger & Associates Date: February 18, 2009 Karl E' Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 81924 Attorney for Petitioner CHRISTINE L. McCORMICK, Plaintiff V. WILLIS J. McCORMICK, II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03-4235 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY The Honorable J. Wesley Oler VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Modification Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unworn falsification to authorities. C Date: 1 b0 U q N?ib' Christine L. McCormic Petitioner/Plaintiff lip CHRISTINE L. MCCORMICK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 03-4235 CIVIL TERM V. CIVIL ACTION - LAW WILLIS J. MCCORMICK, II, Defendant IN CUSTODY OLER, J. -- ORDER OF COURT AND NOW, this day of August, 2005, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Christine L. McCormick and Willis J. McCormick, 11, shall have shared legal custody of the minor children, Matthew Ryan McCormick, born November 10, 19.93; Marissa Loraine McCormick, born June 3, 1996; and Melanie Christine. McCormick, born May 4, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all. major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining. to the 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. 2. Physical Custody. Mother shall have temporary primary physical custody subject to Father's rights of.partial custody which shall be arranged as follows: A. To commence July 15, 2005, on alternating weekends from Friday at 5:00 p.m. until the following Monday morning. Father shall put Matthew on the bus from his home and deliver Marissa and Melanie to Mother at 7:30 a.m. B. Each Wednesday, effective from July 13, 2005, from 5:00 p.m. overnight until Thursday morning, Father shall have custody of all children. Father will put Matthew on the bus from his home and deliver Marissa and Melanie to Mother at 7:30 a.m. SU "IL bjjl L4 /In log R 1E IC C A'JG 2 ? 2C55 NO. 03-4235 CIVIL TERM 3. Effective July 11, 2005, each Monday from 5:00 p.m. to 9:00 p.m., Father will have partial custody with Matthew only. 4. Holidays. The following holiday schedule shall take precedence over the regular schedule: A. Thanksgiving. Thanksgiving shall be divided into two segments, Segment A and Segment B. Segment A shall be from 5:00 p.m. Wednesday until Noon on Saturday. Segment B shall be from Noon on the Saturday following Thanksgiving until Monday evening or Tuesday morning at the option of the parent who has Segment B. The parent with Segment B will give notice to the Segment A parent by November 1st of each year as to whether or not the children will be returned on Monday evening or Tuesday morning. In the absence of such notice, the presumption will be that the children will be returned on Monday evening. In odd-numbered years, Father shall have Segment A and Mother shall have Segment B. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. B. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 24th at 2:00 p.m. until December 25th at 2:00 p.m. Segment B shall be December 25th at 2:00 p.m. until December 26th in the morning. In odd-numbered years, Mother shall have Segment A and Father shall have Segment B. In even-numbered years, Father shall have Segment A and Mother shall have Segment B. C. Alternating Holidays. The parties shall alternate custody for the following holidays commencing with Mother having custody for Labor Day 2005: New Year's Day, Easter, Memorial Day, Independence Day, and Labor Day. The custodial period for these holidays shall be from 9:00 a.m. on the holiday until 9:00 a.m. the day after the holiday. D. Mother's Day and Father's Day. Mother shall have custody for Mother's Day and Father shall have custody for Father's Day. The custodial period for these holidays shall be from 9:00 a.m. on the holiday until 9:00 a.m. the next morning. E. In the event that .the children are out of school on a Monday for Martin Luther King Jr. Day, Columbus Day or President's Day, the parent with the custodial weekend preceding these holidays shall have their weekend extended until Tuesday morning when the children return to school. NO. 03-4235 CIVIL TERM 5. Vacation. Each party shall be entitled to two (2) non-consecutive weeks of custody for vacation which shall commence on the traveling parent's custodial weekend at 5:00 p.m. on Friday. The parties shall provide each other with at least thirty (30) days notice of their intended vacation. In the event of a conflict in vacation schedules, the parent to first provide written notice to the other parent shall have choice of the vacation time. Prior to departure, the traveling parent shall provide -the other parent with written notice of the address and telephone number where they can be reached during the vacation period. 6. Transportation. Mother will provide transportation at the beginning of Father's Custodial periods on Wednesdays at 5:00 p.m. Otherwise, Father will provide transportation incident to the custodial exchanges. The 7:30 a.m. time that Father is to drop off the girls with Mother on the alternating Mondays and Thursday mornings was selected prior to knowing the schedule for Matthew's bus schedule on those mornings at Father's residence. Therefore, the parties may need to be flexible to accommodate a different morning drop off time for the girls after the bus schedule for Matthew is known. Father and Mother will provide each other with a telephone call in the event that they would be more than 10 minutes ahead of schedule or behind schedule for custodial exchanges. 7. Children's Birthday. The non-custodial parent shall be entitled to an hour and a half (1%) period of custody with each child on his or her birthday. B. The parties shall participate in therapeutic family counseling to assist them in improving their ability to parent the children cooperatively. Father will provide Mother's counsel with a list of mental health/counseling providers that participate with his health insurance plan no later than July 15, 2005 in order to assist the parties in selecting a therapist that maximizes available health insurance coverage. With regard to therapeutic work to be done in the relationship with Father and Matthew, Matthew's therapist, Steffi Ambrose Devine will be consulted for a clinical determination as to whether she can serve in this role in light of her present relationship as Matthew's individual therapist. BY THE COURT: 13. J. esley OI Jr., J. Dist: Kristopher T. Smull, Esquire, 210 Grand View Avenue, Suite 102, Camp Hill, PA 17011 Willis J. McCormick II, 2 Hearthstone Court, Mechanicsburg, PA 17050 TRUE COPY FROG RECORD In Tes 'mony wh: reof, h re u #o szt my hand ye . and__: _ se l of-slid 70f rli sPThi .. 2L. do Z47 P CHRISTINE L. MCCORMICK, Plaintiff V. WILLIS J. MCCORMICK, II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4235 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Matthew Ryan McCormick November 10, 1993 Mother Marissa Loraine McCormick June 3, 1996 Mother Melanie Christine McCormick May. 4, 1998 Mother 2. The parties' second Custody Conciliation Conference was held on July 7, 2005. Subsequent'to the Conference, additional clarification of the Order was sought by the Father, pro se and by Mother's counsel. A telephone conference was held on August 16, 2005. The parties were able to reach an agreement with regard to the modification of the Order in the form as a ched. 0 ate Melissa Peel Greevy, Esq ire Custody Conciliator :256938 CHRISTINE L. McCORMICK, Plaintiff V. WILLIS L McCORMICK,11, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03-4235 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY The Honorable J. Wesley Oler CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Petitioner, herby certify that I this day served a copy of the within Peddon to Modify Custody upon the following by depositing the same in the United States mail, first class, postage prepaid addressed as follows: Stephanie Divittore, Esquire One South Market Square P.O. Box 1146 Harrisburg, Pennsylvania 17108 Respectfully Submitted, Rominger & Associates Date: February 18, 2009 E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 81924 Attorney for Petitioner V . VO Cr L7 -^C N Stephanie E. DiVittore, Esquire RHOADS & SINON LLP One South Market Square, 12th Floor P.O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Willis J. McCormick, II CHRISTINE L. MCCORMICK V. Plaintiff WILLIS J. MCCORMICK, II, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003-4235 : CIVIL ACTON --LAW IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE TO: Curtis Long, Prothonotary Cumberland County Court of Common Pleas 1 Courthouse Square Carlisle, PA 17013 Kindly enter the appearance of Stephanie E. DiVittore and Rhoads & Sinon LLP as counsel on behalf of Defendant Willis J. McCormick, II in this action. Respectfully submitted, RHOADS & SINON LLP By: Stephanie E. DiVittore One South Market Square P. O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Willis McCormick, II 733391.1 ?`. 'r -r-s tom, cr, t PO ?? APR " 7 20096r CHRISTINE L. McCORMICK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2003-4235 CIVIL ACTION LAW WILLIS J. McCORMICK, II Defendant IN CUSTODY ORDER OF COURT AND NOW, this ?-b day of 4 , 2009, upon consideration of the attached Custody Conciliation Report, it Is ordered and directed as follows: 1. The parties agree to cooperate in pursuing resolution of the outstanding custody issues through the involvement of a counselor as discussed at the custody conciliation conference. 2. Within six (6) months of the date of this Order, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary. cc: ?arl E. Rominger, Esquire - Counsel for Mother ? Stephanie E. DiVittore, Esquire - Counsel for Father 01T 1.8 S rrl:at LL BY THE COURT, S q .6 Wd I Z SO 60oz U av- ;dd 3Hi ?G 301:U 4'x--1-11H CHRISTINE L. McCORMICK Plaintiff vs. WILLIS J. McCORMICK, II Defendant Prior Judge: J. Wesley Oler IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2003-4235 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Matthew Ryan McCormick November 10, 1993 Mother Marissa Lorraine McCormick June 3, 1995 Mother Melanie Christine McCormick May 4, 1998 Mother 2. A custody conciliation conference was held on April 15, 2009, with the following individuals in attendance: the Mother, Christine L. McCormick, with her counsel, Karl E. Rominger, Esquire, and the Father, Willis J. McCormick, II, with his counsel, Stephanie E. DiVittore, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator BAYLEY & MANGAN Mark F. Bayley, Esquire Attorney I.D. #: 87663 17 West South Street Carlisle, PA 17013 (717) 241-2446 CHRISTINE L. McCORMICK, Plaintiff V. OF , FILED-OFFICE 1010 DEC -3 PM 2: 59 CUMBERLAND COUNTY PENNSYLVANIA : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-4235 CIVIL TERM WILLIS J. McCORMICK, II, : CIVIL ACTION - LAW Defendant IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes Petitioner, Willis J. McCormick, II, by and through his attorney, Mark F. Bayley, and in support of the within petition avers as follows: I. Willis J. McCormick, II, Petitioner, (hereinafter referred to as "Father"), is the Defendant in the above caption-matter, and is an adult currently residing at 2 Hearthstone Ct., Mechanicsburg, PA 17050. 2. Christine L. McCormick, Respondent, (hereinafter referred to as "Mother"), is the Plaintiff in the above-captioned matter, and is an adult individual residing at 18 Wheatfield Dr., Carlisle, PA 17015. 3. The parties are the natural parents of: Matthew Ryan McCormick (date of birth 11/10/93). ?oa? Marissa Lorraine McCormick (date of birth 6/3/95). Melanie Christine McCormick (date of birth 5/4/98). 4. Relevant prior orders were entered on August 23, 2005, November 28, 2006, and April 20, 2009, by the Honorable J. Wesley Oler, Jr. (conies attached as Exhibits A, B, & C). 5. A change of circumstances has since occurred. 6. Father is requesting that the current order be modified as agreed upon by the parties or otherwise determined by the court to be in the best interests of the children. WHEREFORE, Petitioner requests this Honorable Court to schedule a custody conciliation conference. Date: I z J ?0 Respectfully submitted, BAYLEY & MANGAN Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 CHRISTINE L. McCORMICK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-4235 CIVIL TERM WILLIS J. McCORMICK, II, : CIVIL ACTION - LAW Defendant IN CUSTODY ATTORNEY VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney in relation to the within matter; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: ?z??_ tU U Mark F. Bayley, Esquire RECEIVED AUG 2 3 200 CHRISTINE L. MCCORMICK, ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO, 03-4235 CIVIL TERM V. CIVIL ACTION LAW WILLIS J. MCCORMICK, 11, IN CUSTODY Defendant OLER, J. --- ORDER OF COURT AND NOW, this _ day of August, 2005, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Christine L. McCormick and Willis J. McCormick, II, shall have shared legal custody of the minor children, Matthew Ryan McCormick, born November 10, 1993; Marissa Loraine McCormick, born June 3, 1996; and Melanie Christine McCormick, born May 4, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa.. C. S. §5309, each parent shall be entitled to all records and information pertaining to the 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. 2. Physical Custody. Mother shall have temporary primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: A. To commence July 15, 2005, on alternating weekends from Friday at 5:00 p.m. until the following Monday morning. Father shall put Matthew on the bus from his home and deliver Marissa and Melanie to Mother at 7:30 a.m. B. Each Wednesday, effective from July 13, 2005, from 5:00 p.m. overnight until Thursday morning, Father shall have custody of all children. Father will put Matthew on the bus from his home and deliver Marissa and Melanie to Mother at 7:30 a.m. Exhk- bI .t "A0 r Lo '. C=k u .CC C] C C? NO. 03-4235 CIVIL TERM 3. Effective July 11, 2005, each Monday from 5:00 p.m. to 9:00 p.m., Father will have partial custody with Matthew only. 4. Holidays. The following holiday schedule shall take precedence over the regular schedule: A. Thanksgiving. Thanksgiving shall be divided into two segments, Segment A and Segment B. Segment A shall be from 5:00 p.m. Wednesday until Noon on Saturday. Segment B shall be from Noon on the Saturday following Thanksgiving until Monday evening or Tuesday marring at the option of the parent who has Segment B. The parent with Segment B will give notice to the Segment A parent by November 1st of each year as to whether or not the children will be returned on Monday evening or Tuesday morning. In the absence of such notice, the presumption will be that the children will be returned on Monday evening. In odd-numbered years, Father shall have Segment A and Mother shall have Segment B. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. B. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 24th at 2:00 p.m. until December 25th at 2:00 p.m. Segment B shall be December 25th at 2:00 p.m. until December 26th in the morning. In odd-numbered years, Mother shall have Segment A and Father shall have Segment B. In even-numbered years, Father shall have Segment A and Mother shall have Segment B. C. Altemating_Holidays. The parties shall alternate custody for the following holidays commencing with Mother having custody for Labor Day 2005: New Year's Day, Easter, Memorial Day, Independence Day, and Labor Day. The custodial period for these holidays shall be from 9:00 a.m. on the holiday until 9:00 a.m. the day after the holiday. D. Mother's Day and Father's Day. Mother shall have custody for Mother's Day and Father shall have custody for Father's Day. The custodial period for these holidays shall be from 9:00 a.m. on the holiday until 9:00 a.m. the next morning. E. In the event that the children are out of school on a Monday for Martin Luther King Jr. Day, Columbus Day or President's Day, the parent with the custodial weekend preceding these holidays shall have their weekend extended until Tuesday morning when the children return to school. NO. 03-4235 CIVIL TERM 5. Vacation. Each party shall be entitled to two (2) non-consecutive weeks of custody for vacation which shall commence on the traveling parent's custodial weekend at 5:00 p.m. on Friday. The parties shall provide each other with at least thirty (30) days notice of their intended vacation. In the event of a conflict in vacation schedules, the parent to first provide written notice to the other parent shall have choice of the vacation time. Prior to departure, the traveling parent shall provide the other parent with written notice of the address and telephone number where they can be reached during the vacation period, 6. Transportation. Mother will provide transportation at the beginning of Father's custodial periods on Wednesdays at 5:00 p.m. Otherwise, Father will provide transportation incident to the custodial exchanges. The 7:30 a.m. time that Father is to drop off the girls with Mother on the alternating Mondays and Thursday mornings was selected prior to knowing the schedule for Matthew's bus schedule on those mornings at Father's residence. Therefore, the parties may need to be flexible to accommodate a different morning drop off time for the girls after the bus schedule for Matthew is known. Father and Mother will provide each other with a telephone call in the event that they would be more than 10 minutes ahead of schedule or behind schedule for custodial exchanges. 7. Children`s Birthday. The non-custodial parent shall be entitled to an hour and a half (1 /Z) period of custody with each child on his or her birthday. 8. The parties shall participate in therapeutic family counseling to assist them in improving their ability to parent the children cooperatively. Father will provide Mother's counsel with a list of mental health/counseling providers that participate with his health insurance plan no later than July 15, 2005 in order to assist the parties in selecting a therapist that maximizes available health insurance coverage. With regard to therapeutic work to be done in the relationship with Father and Matthew, Matthew's therapist, Stef i Ambrose Devine will be consulted for a clinical determination as to whether she can serve in this role in light of her present relationship as Matthew's individual therapist. BY THE COURT: J. Wesleyl9ier` Jf J. Dist: a rtrtistopher T. $mull, Esquire, 210 Grand View Avenue, Suite 102, Camp Hill, PA 17011 ,y lis J. Mcco ick II, 2 Hearthstone Court, Mechanicsburg, PA 17050 apw CHRISTINE L. MCCORMICK, Plaintiff V. WILLIS J. MCCORMICK, II, Defendant RECEIVED AEG 2 3103 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4235 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Matthew Ryan McCormick November 10, 1993 Mother Marissa Loraine McCormick June 3, 1996 Mother Melanie Christine McCormick May 4, 1998 Mother 2. The parties' second Custody Conciliation Conference was held on July 7, 2005. Subsequent to the Conference, additional clarification of the Order was sought by the Father, pro se and by Mother's counsel. A telephone conference was held on August 16, 2005. The parties were able to reach an agreement with regard to the modification of the Order in the form as a ched. 9/1 L&-- 6?!?a ate Melissa Peel Greevy, Esq ire Custody Conciliator :256938 Nov 11= CHRISTINE L. MCCORMICK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 03-4235 CIVIL TERM V. CIVIL ACTION - LAW WILLIS J. MCCORMICK, 11, IN CUSTODY Defendant OLER, J. - - ORDER OF COURT AND NOW, this day of November, 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Each parent shall sign the appropriate authorization to release confidential information from the children's therapists, Teddy Spencer and Stephanie Devine, to Father's therapist, Debra Salem. The purposes of the contact between the therapist for Father and the therapist for the children is to assist Ms. Salem in understanding what might be helpful to assist Father with the difficulties in the relation between he and his children. Accordingly, the parties will cooperate with the exchange of this confidential information and if it is thought to be clinically appropriate to do so the children shall be permitted to participate in therapeutic sessions with Ms. Salem and Father and which may or may not include the children's therapists. 2. A hearing is scheduled in Courtroom Number 1 of the Cumberland County Courthouse, on the 4A day of 'Y7XAgJ.1 aQ07~, at o'clock ,A.M., at which time testimony will be taken. Forth purposes of the hearing, the Mother, Christine L. McCormick, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of exhibits, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda, lists of exhibits, lists of witnesses and summaries of anticipated testimony of each witness shall be filed at least ten days prior to the hearing date. BY THE Oler, \Bn -J: Dist: Ajikopher T. Smull, Esquire, 210 Grand View Avenue, Suite 102, Camp Hill eresa Barrett Male, Esquire, 513 N. Second St., Harrisburg, PA 17101 4 [X,?i bl, + TO FILED- IFFTE OF THE P poTH.OmOTARY 2006 NOV 28 AN 10: 4 4 PENNSYLMMA I& It 1% CHRISTINE L. MCCORMICK, Plaintiff V. WILLIS J. MCCORMICK,11, Defendant my $12006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4235 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Matthew Ryan McCormick November 10, 1993 Mother Marissa Loraine McCormick June 3, 1996 Mother Melanie Christine McCormick May 4, 1998 Mother 2. Mother filed a Petition to Modify Custody Order on September 28, 2006. A Custody Conciliation Conference was held on November 7, 2006 with the following individuals in attendance: the Mother, Christine L. McCormick, and her counsel, Kris T. Smull, Esquire; the Father, Willis J. McCormick, and his new counsel, Theresa Barrett Male, Esquire. 3. Mother's Position on Custody is as Follows: Mother wants to discontinue the overnight periods of custody with Father on Sundays and Wednesdays. Mother complains of Father not doing homework with the children, Father not feeding them breakfast or insufficient breakfast, and the children being stressed about forgetting items they need for school. Mother reports that the children do not feel safe and secure with Father and that the present schedule is disruptive to them. She reports the parties participated in therapeutic family counseling but that the counseling was discontinued by the counselor after two and a half sessions. Mother attributes the counselor's decision to Fathers behavior. Mother reports that Father belittles the children by questioning the teenage son's sexual orientation and making comments such as "I hope the ball hits you in the head." Mother also reports that Father did not allow the daughter to go to an end-of-season ice cream party with her soccer team. Since the filing of Mother's Petition she reports that Father has been a little bit better about overseeing the homework. Mother's counsel acknowledges that the parties do not communicate. Mother feels strongly that Father need to address certain issues in NO. 03-4235 CIVIL TERM individual psychotherapy before he will be able to work effectively on the relationship with his children. 4. Father's Position on Custody is as Follows: Father apparently began to see Deborah Salem for individual therapy last year upon referral from his attorney. Ms. Salem attempted to work with the children's counselors in order to better understand the trouble in the relationship between Father and the children. However, Ms. Salem reports that she was stonewalled by the counselors for the children. Accordingly she has not been able to work with him to understand the strain in the relationship. This has reportedly impaired her ability to assist Father. Father complains that Mother does not communicate with him and that Mother gives him no notice of school or medical events. He reports that the children do not bring their homework with them on Wednesdays on a consistent basis. Father complains there are difficulties at custodial exchanges because Mother's boyfriend's car blocks the driveway and because Mother objects to the children walking through the grass when he tries to pick up the children at curbside. Father also complains that Mother made a unilateral decision to start the children in CCD and raise them as Catholic. With regard to the concern raised about breakfast, Father reports that the children preferred to sleep later in the morning so that they could eat at Mother's home. Unfortunately, because the parties literally do not communicate with each other there was no discussion between the parents about his decision to stop feeding the children breakfast on Monday and Wednesday mornings. 5. The parties were able to reach an agreement, although Mother was reluctant, to sign consents for the release of confidential information so that Father's therapist, Deborah Salem, and the children's therapists, Teddy Spencer and Stephanie Devine, would be able to speak with each other regarding the children and the difficulty in the relation between Father and the children. Additionally, Father would like for Ms. Salem to be able to observe him with the children and to meet with the children so that she can better understand the dynamic in the relationship and be able to help him address the concerns. However, the parties have not reached an agreement with regard to Mother's request to further reduce Father's custodial time. Accordingly, a hearing will be necessary. Counsel have requested one day for purposes of this hearing. 6. It is noted that this family is one in which the tensions and conflict that existed when they first entered conciliation have not improved. The chronicity and level of conflict is of great concern because of the impact on the children. Whatever the "Court may do with the schedule, if the parties cannot conduct themselves in a less conflictual fashion and the issues that are leading to the difficulties in the relationship between Father and the children are not adequately addressed; changing the schedule will have little impact. There has been concern that there is alienation between Father and the children. Both parties point N0.03-4235 CIVIL TERM the finger of blame at each other, but have not been able to gamer th ility to focus on the children's need to address what needs to happen without regard to o is at fault. I l b ? t 0? fx?- Date lissa Peel Greevy, Esquire Custody Conciliator :286594 APR 17 2009 CHRISTINE L. McCORMICK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 20034235 CIVIL ACTION LAW WILLIS J. McCORMICK, II Defendant IN CUSTODY ORDER. OF COURT AND NOW, this Z- b day of 4101, 2009, upon consideration of the attached Custody Conciliation Report, it Is ordered and directed as follows: 1. The parties agree to cooperate in pursuing resolution of the outstanding custody issues through the involvement of a counselor as discussed at the custody conciliation conference. 2. Within six (6) months of the date of this Order, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary. cc: ?,,Karl E. Rominger, Esquire - Counsel for Mother Stephanie E. DiVittore, Esquire - Counsel for Father BY THE COURT, RLE"'I rICE OF THE PM?IQIOTARY 2009 APR 21 PM 3* b 5 PE•d"vSYLVA.NA ? IY CHRISTINE L. McCORMICK Plaintiff VS. WILLIS J. McCORMICK, II Defendant Prior Judge: J. Wesley Oler IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 20034235 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Matthew Ryan McCormick November 10, 1993 Mother Marissa Lorraine McCormick June 3, 1995 Mother Melanie Christine McCormick May 4,1998 Mother 2. A custody conciliation conference was held on April 15, 2009, with the following individuals in attendance: the Mother, Christine L. McCormick, with her counsel, Karl E. Rominger, Esquire, and the Father, Willis J. McCormick, II, with his counsel, Stephanie E. DiVittore, Esquire. 3. The parties agreed to entry of an Order in the form as attached. _&,,< < / 4 , aa? 9 / L/2- ? " J": 5,- & - Date Dawn S. Sunday, Esquire Custody Conciliator CHRISTINE L. McCORMICK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ; NO. 2003-4235 CIVIL TERM WILLIS J. McCORMICK, II, : CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Dated: ?- (0 Dv V Mark F. Bayley, squire BAYLEY & MANGAN Mark F. Bayley, Esquire Attorney I.D. #: 87663 17 West South Street Carlisle, PA 17013 (717) 241-2446 CHRISTINE L. McCORMICK, Plaintiff v. tj, 0 T.' ''t? i? O t EC - 3 P1 2: nEMS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-4235 CIVIL TERM WILLIS J. McCORMICK, II, : CIVIL ACTION - LAW Defendant IN CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Defendant, WILLIS J. McCORMICK, II, in the above-captioned matter. Date: - Mark F. Bayley, Esquire Bayley & Mangan 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 CHRISTINE L. McCORMICK, Plaintiff V. WILLIS J. McCORMICK, 11, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-4235 CIVIL TERM CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Karl Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Stephanie E. DiVittore, Esquire One South Market Square P.O. Box 1146 Harrisburg, PA 17108-1146 1 Mark F. Bayley, Esquire Dated: ?? J 1. CHRISTINE L. MCCORMICK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA C:) G O -n _ V. rri M 2003-4235 CIVIL ACTION LAW -1T7 r ?-r1 rn`- WILLIS J. MCCORMICK II ci = o , IN CUSTODY -ri ?=7 DEFENDANT w='a z :: c::: co C)177 ORDER OF COURT AND NOW, Tuesday, December 07, 2010 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, December 28, 2010 at 9:00 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. 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/ Dawn S. Sunda Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ix- 7., gyp) 6 A L Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 BAYLEY & MANGAN Mark F. Bayley, Esquire Attorney I.D. #: 87663 17 West South Street Carlisle, PA 17013 (717) 241-2446 CHRISTINE L. McCORMICK, Plaintiff P;) 0 20! 1 FEB 28 PM 2: UM B ERLi? a CQ1 i f a PEN ?SY' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-4235 CIVIL TERM WILLIS J. McCORMICK, II, : CIVIL ACTION - LAW Defendant IN CUSTODY MOTION FOR SCHEDULING OF HEARING AND NOW comes Defendant, by and through his attorney, Mark F. Bayley, and in support of the within motion avers as follows: 1. The Honorable J. Wesley Oler was previously assigned to the above captioned matter. 2. Defendant filed his Petition for Modification of Custody on December 3, 2010. 3. A conciliation conference with Dawn Sunday, Esquire, was attended by both parties on December 28, 2010. 4. At said conference an agreement was reached whereby the parties would participate in counseling in order to attempt to resolve outstanding issues; a follow-up conciliation was subsequently scheduled for February 21, 2011 in order to determine whether or not the parties could reach a final agreement based upon said counseling. 5. Counseling efforts have not resolved the parties' dispute to date and both parties agree that a hearing should be scheduled for a date approximately 3 months in the future without the necessity of an additional conciliation conference. 6. The parties attempt to resolve their outstanding dispute by conciliation was not successful and they now respectfully request a hearing. 7. Plaintiffs counsel, Karl Rominger, concurs with the within request. 8. Dawn Sunday, Esquire, indicated that she would relinquish her jurisdiction so that a hearing could be scheduled. 9. Counsel predicts that a hearing will take between a half and full day and therefore requests a full day hearing to be set. WHEREFORE, Defendant respectfully requests this Honorable Court to schedule a hearing. Date. Respectfully submitted, BAYLEY GAN Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 CHRISTINE L. McCORMICK, Plaintiff V. WILLIS J. McCORMICK, II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-4235 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ATTORNEY VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney in relation to the within matter; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: ^ Zv- I 2 l -"?'//V" Mark F. Bayley, Esquire CHRISTINE L. McCORMICK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-4235 CIVIL TERM WILLIS J. McCORMICK, II, : CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the foregoing document upon the following by hand-delivery to the following address: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 i Z?Z?' l Mark F. Bayley, E quire I Dated: CHRISTINE L. McCORMICK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2003-4235 CIVIL ACTION LAW WILLIS J. McCORMICK, II Defendant IN CUSTODY ORDER -; r-r Y ?,.?."?`'' :7 SIT-?•E AND NOW, this 23rd day of February, 2011 , the conciliator, being.` &ised by Petitioner's counsel that the Father intends to proceed to hearing rather than the follo cus dyC2 71 conciliation conference, hereby relinquishes jurisdiction. The custody conciliation co enaw j scheduled for February 21, 2011 is cancelled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator CHRISTINE L. McCORMICK, Plaintiff V. WILLIS J. McCORMICK, II, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-4235 CIVIL TERM CIVIL ACTION - LAW : IN CUSTODY 1 ORDER OF COURT AND NOW, this S 1 day of Vo 2.3 e ? , 2011, Defendant's Motion for Scheduling of Hearing is hereby GRANTED. A hearing is scheduled for the .'? day of 2011 at 9: 30 a m in Courtroom No. / of the Cumberland County Courthouse. Counsel for each party shall file with the Court and opposing counsel a memorandum setting forth each party's position of custody, a list of witnesses who will be expected to testify, and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least five days prior to the hearing date. Distribution: Mark F. Bayley, Esquire Karl Rominger, Esquire (°p,r-s ma.'Ied _7/y/ii P,Yt f -71 .ti^p • CHRISTINE L. McCORMICK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-4235 CIVIL TERM WILLIS J. McCORMICK II : CIVIL ACTION - LAW r" co l r i Defendant _V M IN CUSTODY cn ' STIPULATION e > - : _ ? Z 3 CD = - The undersigned parties are in agreement to the entry of the following order:" 1. All previous Orders are vacated; the hearing previously scheduled for June 13, 2011 is hereby cancelled. 2. The parties shall share legal custody of the minor children Matthew McCormick, age 17 (born I 1-10-93); Marissa McCormick, age 16 (born 6-3-95); and Melanie McCormick, age 13 (born 5-4-98). 3. Mother shall have primary physical custody of the children; it is Father's understanding that the children do not wish to have custodial periods with him at this time; Father encourages the children to reconsider and invites them to make contact with him to arrange a visit or to chat; Mother shall not interfere with visits arranged at reasonable times between one or more of the children and Father. 4. Father is permitted to make contact with the children through email, cards, letters, etc. 5. A copy of the within Order shall be shared with each child. b _ e7- _ // Karl Rominger, Esquire (Attorney for Mark F. Bayley, Esquire (Attorney for Father) Date Date CHRISTINE L. McCORMICK, Plaintiff V. WILLIS J. McCORMICK, II Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-4235 CIVIL TERM : CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW this t ,'! day of OJ Uh C, , 2011, upon agreement by the parties, Christine L. McCormick (hereafter "Mother") and Willis J. McCormick, II (hereafter "Father") it hereby directed as follows: 1. All previous Orders are vacated the hearing previously scheduled for June 13, 2011 is hereby cancelled. 2. The parties shall share legal custody of the minor children Matthew McCormick, age 17 (born 11-10-93); Marissa McCormick, age 16 (born 6-3-95); and Melanie McCormick, age 13 (born 5-4-98). 3. Mother shall have primary physical custody of the children; it is Father's understanding that the children do not wish to have custodial periods with him at this time; Father encourages the children to reconsider and invites them to make contact with him to arrange a visit or to chat; Mother shall not interfere with visits arranged at reasonable times between one or more of the children and Father. 4. etc. 5 Mark Bayley, Esquire 7Co??S ?`eGt Karl Rominger, Esquire Ghy Y ?`c;QBI Father is permitted to make contact with the children through email, cards, letters, A copy of the within Order shall be shared with each child. c? 4L