Loading...
HomeMy WebLinkAbout07-415307- X153 06/19/07 YORK COUNTY COURTHOUSE CIVIL ACTION DOCKET REISSER, CHRISTINA R VS. REISSER, ERIK J CASE N0: 2006-FC-002255-Y32 YK FILING DATE: 12/15/06 JUDGE: ~' w~ (rt rw- PAG:~: 1 Y02 PARTY TYPE LITIGANT PARTY NAME ATTORNEY P001 SUMPLE-SULLIVAN, BARBARA PLAINTIFF FOR CIVI P001 REISSER, CHRISTINA R DEFENDANT FOR CIVI D001 REISSER, ERIK J DATE FEE./AMOUNT -------- ------------------------------------------------------ ----- 06/18/07 00089 00349 AS TO REISSER, CHRISTINA R 27.25 *ORDER TRANSFERRING CASE TO CUMBERLAND COUNTY 06/18/07 00089 00349 *PRAECIPE TO TRANSFER CASE TO CUMBERLAND COUNTY 03/12/07 00037 00392 AS TO REISSER, CHRISTINA R *ENTRY OF APPEARANCE BARBARA SUMPLE-SULLIVAN ESQ FOR PLTF 03/12/07 00037 00392 AS TO REISSER, CHRISTINA R *APPEARANCE WITHDRAWN JAMES F LOGUE ESQ FOR PLTF. 12/29/06 00168 00112 AS TO REISSER, CHRISTINA R *AFFIDAVIT OF SERVICE OF DIVORCE COMPLAINT BY CERTIFIED MAIL 12/22/06 00165 00407 AS TO REISSER, CHRISTINA R *CERTIFICATE OF SERVICE OF COMPLAINT 12/15/06 00162 00275 AS TO REISSER, CHRISTINA R *CUSTODY FEE RE: ACT 119-96 12/15/06 00162 00275 *COMPLAINT IN DIVORCE=UNDER SECTION 3301 W/CERT OF SERVICE TOTAL NUMBER OF ENTRIES: 8 REQUESTED BY: LJF ******* END OF REPORT ******* 6.50 235.00 un Pie Y ~ • 1 as f the Court of Cone I CFRTI re recur ~ I.e~. pY -~ ~ of A.D. 20 _ this O~A 0 • ~ ~ ~c' -6R- ~{k ~ V I J ~ ) ~} 1' zz ~ ~ _ 8 (j~~ 2b~0~J~- V 26~ Ot~* J ~ 26-Q~J+ D 101'~J~- D ;l~~U~.r:; ~ ~ 0•~ p {Z. P: N f_" c~ o 1 € ~ C° ""~ ,,F c _,' 1'- ~ . -:~: _ ~~ - ;,~^- ;rr? _' 4- ~ av cr: --c • ~ • Barbara Sample-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court LD. 32317 Attorney for Petitioner ~ ' CHRISTINA R. REISSER, : IN THE COURT OF COMMON PLEAS {°: `~' Plaintiff, :YORK COUNTY, PENNSYLVANIA ...fGv . ~~. ~ ~. v. : CIVIL A ION LAW ~sr NO. ~ ~~ ~' ERIK J. REISSER, 2006- ~ Z255-YI15 r a"~. ~. Defendant, :DIVORCE/CUSTODY ~"~ ORDER AND NOW, to wit, this day of °5,,~,vrt- , 2007, upon consideration of the attached Praecipe to Transfer Case to Cumberland County and on motion of Barbara Sample-Sullivan, Esquire, counsel for Plaintiff, Christina R. Reisser, and Gary G. Efstration, Esquire, counsel for Defendant, Erik J. Reisser, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the attached Praecipe are adopted as an Order of Court. BY THE COURT, w W N J. Pleas Y k Cou ty, ~s aria CER the record f the Court of Com t~ day of A.D. 20U ~~~~~3.----- Pamela S. Lee, Prothonotary ~ql~~~ .~ a • Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 CHRISTINA R. REISSER, :1N THE COURT OF COMMON PLEAS Plaintiff, :YORK COUNTY, PENNSYLVANIA p J - ~. :CIVIL ACTION LAW - ~ ' '~ .. NO. 2006-FC-2255-Y02 ~ °..r:~:_ r' - r :. co ', ERIK J. REISSER, 2006-CV-2255-Y03 Defendant :DIVORCE ~' `~ ' -~ '=' ~- r': f ~ ~ ~~ w - ~ - PRACIPE TO TRANSFER CASE TO CUMBERLAND COUNTY TO DOMESTIC RELATIONS OFFICE: The undersigned counsel request and concur in the transfer of the above captioned matter from York Cou~y to Cumberland County due to relocation of the parties. Barbara~Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. 32317 ary G. Efstration, Esquire Attorney for Defendant 232 E. Orange Lancaster, PA 17602 (717) 291-9292 Supreme Court I.D. cc. ~ --_ ~-; ~- ~- - c= ~'~ o F-- i- ~. t~~,~' - ~c~:= - ~, ~: . ~ ~c~:_. : `. ~` _ - ~ = y F-- ~ „ ~-- lJ C_, ~ ~~ 0~4 • • i CHRISTINA R. REISSER, Plaintiff, IN THE COURT OF COMMON PLEAS YORK COUNTY, PENNSYLVANIA v, : CIVIL A N LAW NO. 2006-FC-2255-Y02 ERIK J. REISSER, 2006-CtK-2255-Y03 Defendant, :DIVORCE PRAECIPE TO WITHDRAW APPEARANCE To the Prothonotary: Please withdraw our appearance on behalf of the Plaintiff in the above-captioned matter. Respectfully submitted, BENNLAWFIItM ~~ , Dated: By: James F. Logue, Esquire c.. . Attorney LD. #202170 `- ;r.~ 103-107 E. Market St. - P.O. Box 5185 ~ `~~~- ~ ' ~~ PA 17405-5185 York ,. ~ t'' - , (717} 852-7020 ~ ~y'r.,. _ ~ ~., 4, PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of the Plaintiff~e above-captioned matter. Dated: N ~, :.--~ N ~~. ~~ sv Bares a Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 Supreme Court I.D. 32317 ~ • ~. I ~BENNLAWFIRM IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYL', VVV,~AN__IA CHRISTINA R. REISSER, No. ~~.1~~ - p~a~j ~`-~(~a Plaintiff r .~, v CIVIL ACTION -LAW - ~ J ~~ r,. • c.ri ERIK J. REISSER, ''`'~. ~ Defendant DIVORCE ~= ~ -~- , ', ~~ -- NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment maybe entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the York County Court House. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer RefP~~? CP*~~~~i;; f the York Cour>~1j~~~ ~~~~tion York County Bar Center 137 East Market Street York, PA 17401 (717) 771-9361 103-107 E. MARKET ST. P.O. BOX 5185 YORK, PA 17405-5185 Il ~ .~ '~' • IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA I ~BENNLAWFIRIi1 CHRISTINA R. REISSER, No. Plaintiff • v CIVIL ACTION -LAW t_ ERIK J. REISSER, . Defendant DIVORCE r _. _-c.. NOTICIA (~' r__~ CJ c~? r°°+ c-~ c11 --'_ LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse , de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fencha de la demands y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomaro medidas y puede entrar una Orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion do demands. Usted puede perder dinero o sus propiedades o otros derechos importantes pars usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL ERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Lawyer Referral Service of the York County Bar Association York County Bar Center 137 East Market Street Yor (71 - 103-107 E. MARKET ST. P.O. BOX 5185 `; -~ ~:; ~a -> __, -, YORK, PA 17405-5185 I ~BENNt.AWFIRM 103-107 E. MARKET ST. P.O. BOX 5185 YORK, PA 17405-5185 • • IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CHRISTINA R. REISSER, No. ~v Plaintiff Cj~/~_ "` {C'' ~~5~~~-~l~ Z~ v CIVIL ACTION -LAW / ERIK J. REISSER, ~; Defendant DIVORCE r ~, ~-: c`~ c : _.. _ ~,,_ COMPLAINT ' ~ ' " `'' ~~ r_ , ~, -,.~ AND NOW, on this 14th day of December, 2006, comes the Plaintiff, by ai~c~ throw ~;: ' rv her attorney, BENNLAWFIRM, and files the following Complaint for Divorce: ~ ~ COUNT I -DIVORCE 1. Plaintiff, Christina R. Reiser, is an adult individual who currently resides at 220 E. Lauer Lane, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant, Erik J. Reiser, is an adult individual who currently resides at 3 Riverside Drive, Goldsboro, York County, Pennsylvania 17319. 3. Both Plaintiff and Defendant are sui juris and are citizens of the United States of America. 4. Both Plaintiff and Defenda~t,~,g~j?gg,~,~,pna fide residents of the 349091~202~5 Commonwealth of Pennsylvania for at least six (6 months previous to the filing of this Complaint. 5. Defendant is not a member of the Armed Services of the United States or any of its Allies. ,. _, - :~ ., _~ _~ • • 6. Plaintiff and Defendant were married on October 9, 1999, in New ~BENNLAWFIRM Cumberland, Pennsylvania, at Baughman United Methodist Church by a minister of the gospel. 7. There are three (3) children of this marriage. 8. There have been no prior actions of Divorce or Annulment between the parties. 9. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff avers that the marriage is irretrievably broken, pursuant to 23 Pa.C.S.A. § 3301 (c) and/or (d)(1). 11. In the alternative, Plaintiff avers that Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome, and that this action is not collusive. WHEREFORE, Plaintiff requests this Honorable Court enter a Decree in Divorce, divorcing Plaintiff and Defendant, upon completion of all of the economic issues set forth in the following paragraphs and other relief as the Court deems appropriate. COUNT II: EQUITABLE DISTRIBUTION 12. Paragraphs 1 through 11 arw•i~eer~wrwt~.herein by reference hereto as fully 349091620215 as though the same were set forth at length. 13. Plaintiff and Defendant have legally acquired property, both real and personal, during their marriage from October 9, 1999, to the present, all of which is "marital 103-107 E. MARKET ST. property". P.O. BOX 5185 YORK, PA 17405-5185 • • 14. Plaintiff or Defendant or both have acquired, prior to the marriage or I ~BENNLAWFIRM subsequent thereto, "non-marital property" which has increased in value since the date of the marriage or subsequent to its acquisition during the marriage, which increase in value is "marital property". 15. Plaintiff and Defendant have been unable to agree as to an equitable division of said property to the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property of the parties. COUNT III: ALIMONY PENDENTE LITE COUNSEL FEES COSTS AND EXPENSES 16. Paragraphs 1 through 15 are incorporated by reference hereto as fully as though the same were set forth at length. 17. Plaintiff has employed the BENNLAWFIRM as counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel, as well as related costs and expenses. 18. Plaintiff is in need of hiring various experts to appraise the parties' marital assets and does not have the funds to pay the necessary and reasonable fees. 19. Plaintiff is unable to sustain 17Pr~Plf~iirina the course of this litigation. 34909620215 WHEREFORE, Plaintiff requests this Honorable Court to enter an award of Alimony 103-107 E. MARKET ST. P.O. BOX 5185 Pendente Lite, interim counsel fees, costs and expenses and to order such additional sums hereafter as maybe deemed necessary and appropriate and at final hearing to further award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. YORK, PA 1 7405-5 1 85 • • COUNT IV: ALIMONY 20. Paragraphs 1 through 19 are incorporated by reference hereto as fully as ~BENNLAWFIRII though the same were set forth at length. 21. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 22. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of Alimony. COUNT V: CUSTODY 23. Paragraphs 1 through 22 are incorporated by reference hereto as fully as though the same were set forth at length. 24. Plaintiff and Defendant are the parents of three (3) minor children, Adriana Morgan Reiser (D.O.B. April 19, 1996); Aidan A. Reiser (D.O.B. November 3, 2000); and Adlai P. Reiser (D.O.B. July 25, 2005). 25. Since birth, the minor children have resided with the following persons and at the following addresses: Adriana Morgan Reiser 349091620215 Plaintiff Creekview Lane Birth-1998 New Cumberland, PA 17070 Plaintiff and Defendant Creekview Lane 1998-1999 103-107 E. MARKET ST. NeW Cumberland, PA 17070 P.O. BOX 5185 YORK, PA 17405-5185 ~BENNLAWFIRY Plaintiff and Defendant 19 John Randolph Drive 2000-2002 New Freedom, PA 17349 Plaintiff and Defendant 220 E. Lauer Lane 2002-11/24/2006 Camp Hill, PA 17011 Plaintiff 220 E. Lauer Lane 11/24/2006-Present Camp Hill, PA 17011 Aidan A. Reisser Plaintiff and Defendant 19 John Randolph Drive Birth-2002 New Freedom, PA 17349 Plaintiff and Defendant 220 E. Lauer Lane 2002-11/24/2006 Camp Hill, PA 17011 Plaintiff 220 E. Lauer Lane 11/24/2006-Present Camp Hill, PA 17011 Adlai P. Reisser Plaintiff and Defendant 220 E. Lauer Lane 2002-11/24/2006 Camp Hill, PA 17011 Plaintiff 220 E. Lauer Lane 11/24/2006-Present Camp Hill, PA 17011 26. Plaintiff has not participated a~ ?rt....; ~,sx~itness, or in another capacity, in 34909162021 other litigation concerning the custody of the minor children in this or another court. 27. Plaintiff has no information of a custody proceeding concerning the minor children pending in a court of this Commonwealth or any other state. 103-107 E. MARKET ST. P.O. BOX 5185 YORK, PA 17405-5185 I ~BENNLAWFIRM 28. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 29. The best interests and permanent welfare of the minor children will be served by granting the relief requested to Plaintiff. WHEREFORE, Plaintiff requests this Honorable Court to award primary custody of the minor children to Plaintiff. Respectfully submitted, BENNLAWFIRM James F. Logu uire Attorney LD. # 202170 103-107 East Market Street P.O. Box 5185 York, PA 17405-5185 (717) 852-7020 103-107 E. MARKET ST. P.O. BOX 5185 YORK, PA 17405-5185 • • VERIFICATION COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF YORK , I ~BBNNLAWFIRM I, Christina R. Reiser, being duly sworn according to law verify that the statements contained in the foregoing "Complaint" are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE: CHRISTINA R. ISSER 349091620215 '~, 103-107 E. MARKET ST. P.O. BOX 5185 II YORK, PA 17405-5185 • r • IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA ~BENNLAWFIRM CHRISTINA R. REISSER, No. ~ ~ ~ ~~"G ~ Z'~S S^~ Plaintiff v CIVIL ACTION -LAW ERIK J. REISSER, Defendant DIVORCE CERTIFICATE OF SERVICE 103-107 E. MARKET ST. P.O. BOX 5185 I, James F. Logue, Esquire, hereby certify that on the 14th day of December, 2006, I caused to be served a "Complaint" upon the following individual via first class U.S. mail, postage prepaid, and Certified Mail, Return Receipt No.: 7005 2570 0000 2059 5656 Erik J. Reiser 3 Riverside Drive ` Goldsboro, Pennsylvania 17319 -- ,_ ,~ t_.. Respectfully submitted, BENNLAWFIRM ~~- v j dames F. Logue, Esquire Attorney LD. # 202170 103-107 East Market Street P.O. Box 5185 York, PA 17405-5185 20 34909' 620215 r.,~ ~ , r~1 ~-~ - ; _.__ t~s! - , r~~ c.-1 ; YORK, PA 17405-5185 r IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA I ~BENNLAWFIRM CHRISTINA R. REISSER, Plaintiff ~/. ERIK J. REISSER, Defendant . 0.200 - C-2255-Y02 . 0. 2006-CU-2255- CIVIL ACTION -LAW DIVORCE ti~ ~_ , AFFIDAVIT OF SERVICE BY `~ ' MAIL PURSUANT TO Pa.R.C.P. 1920.4 ~- ~ `` - _ ~_~' COMMONWEALTH OF PENNSYLVANIA ~, ~ r , ~., COUNTY OF YORK ss. -~, ~ ^ _ :~=~ - __ _ I, James F. Logue, Esquire, being duly sworn accordingly to law, deposesrarid _~~ ~ _~ says that a true and correct copy of the Complaint in Divorce filed in the above-referenced matter has been served by certified mail, return receipt requested, restricted delivery on the Defendant on the 26th day of December, 2006. The retum receipt signed by the Defendant is attached hereto and incorporated herein as Exhibit "A" and is further evidence of delivery to Defendant. Respectfully submitted, BENNLAWFIRM 103-107 E. MARKET ST. '.O. BOX 5185 'ORK, PA 17405-5185 Sworn to and su s ribed before me this ~'~ day of December, 06. r~~ ~oii A. Eighty, Notary Pullfl~ Oily Of York, Ypk Courriy My Commieelon Expiros Sept.10, _2010 Member, Penn~ylvsni~ Anoolrtlon nt Nota~ .~~^~ By: ames F. Log squire ID #202170 103 East Market Street P.O. Box 5185 ,,,-,,,,,,~,,,~, York, PA 17405 0~Z0~1~8~ ~~)852-7020 I ~BENNLAWFINM N a si9\ I _ X ' ~ Aunt ~ ~~ ~E c. of Deli ``~ u`- Fv~ D. Is delivery address deferent from Item 1? es H YES, enter depvery address t~elow: ~ No s`''td' ~3~~ 3. Service lype ~Certlfbd Map O Exproes Mail ^ Repiaterod ~Retum Receipt for Merchandise ~ Insured Mali bD c.o.D. a. Resafcted Delivery? t~ Feel ^ Yes 7005 2570 0000 2059 6608 ^ complete Berns 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front 'rf space permits. 1. Article Addressed to: ~r,lc, J . i~e-sser 7~ ~ F~ores~ avenue. ~ hre.wsbur~ ,~11~ I`13i~, PS Form 3811, Febrtary 2004 Dortreetlc Return Receipt ,asesbaa~t~,aw EXHIBIT "A" 002091660112 103-107 E. MARKET ST. P.O. BOX 5185 YORK, PA 17405-5185 r I • _ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA I ~BENNLAWFINM CHRISTINA R. REISSER, Plaintiff v. ERIK J. REISSER, Defendant No.2006-FC-2255-Y02 2006-CV-2255-Y03 CIVIL ACTION -LAW DIVORCE AMENDED CERTIFICATE OF SERVICE I, James F. Logue, Esquire, hereby certify that on the 22°d day of December, 2006, I caused to be served a copy of the "Complaint" previously filed on December 15, 2006, upon the following individual via first class U.S. mail, postage prepaid, and Certified Mail, Return Receipt No.: 7005 2570 0000 2059 6608 r, ~_, ~- a Erik J. Reisser c-.7 73 E. Forrest Ave. ~.-_, ,: Shrewsbury, PA 17361 .-~ ~; f.. _. c., .- .. Respectfully submitted, = ~~~ ~~~ BENNLAWFIRM i _ James F. Logue, 're Attorney I.D. # 202170 103-107 East Market Street P.O. Box 5185 '~"~"~ "'~ 17405-5185 ~~~~~~'~~' 7020 103-107 E. MARKET ST. P.O. BOX 5185 YORK, PA 17405-5185 d7- `fr53 C;vat ~. YORK COUNTY COURTHOUSE 06/19/07 CIVIL ACTION DOCKET REISSER, CHRISTINA R VS. CASE NO: 2006-5E-002255-Y32 YK FILING DATE: 12/22/06 JUDGE: REISSER, ERIK J PAGE: 1 Y15 PARTY TYPE LITIGANT PARTY NAME PLAINTIFF FOR CIVI ----- P001 ------ --- REISSER, ------------------------------- CHRISTINA R DEFENDANT FOR CIVI D001 REISSER, ERIK J DATE --FEE/AMOUNT ------------------------------- __ _ ---------------- - 06/18/07 00089 00349 AS TO REISSER, CHRISTINA R 27.25 *ORDER TRANSFERRING CASE TO CUMBERLAND COUNTY 06/18/07 99999 99999 *PRAECIPE TO TRANSFER CASE TO CUMBERLAND COUNTY 01/02/07 00002 00293 *REFERRED TO DOMESTIC RELATIONS OFFICE/SETTLEMENT 12/22/06 00002 00293 AS TO REISSER, CHRISTINA R 50.00 *MOTION FOR APPOINTMENT OF DIVORCE MASTER APL ONLY 12/22/06 00165 00408 AS TO REISSER, CHRISTINA R *PETITION FOR ALIMONY PENDENTE LITE TOTAL NUMBER OF ENTRIES: 5 REQUESTED BY: LJF ******* END OF REPORT ******* CFRTIF P,#3~f~~1~,t~o records the Court of Com~ 1 s o r unty Pens a a ~ ~J1,~. ~~d~ of A. D. 20 _ 4~f- ela S. Lee, Prothonotaq C"~ vv c_~ C_. r•~~ --..: ri %__ ~ .~ " j °" E t7 i-= C3'' ; ~`- <~; -- -~ , ,- ~~ --- ~ . ~-a f~e" ~'1 N : :zJ . ~ . "C ' _ ~, _ _ ~- Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 Supreme Court I.D. 32317 Attorney for Petitioner CHRISTINA R. REISSER, : IN THE COURT OF COMMON PLEAS Plaintiff, :YORK COUNTY, PENNSYLVANIA . N v. :CIVIL ACTION LAW t ' c..._ NO. 2006-FC-2255-Y02 ~-~ = ', ERIK J. REISSER, ~~~~~ _ ~ --- Defendant, :DIVORCE/CUSTODY - ~'• ~ p e_. -.,-, ~~__ ~~ ORDER '" .: ~ w .. ,_, w _ .~, r~ AND NOW, to wit, this ~~ of , 2007, upon consideration of the attached Praecipe to Transfer Case to Cumberland County and on motion of Barbara Sumple-Sullivan, Esquire, counsel for Plaintiff, Christina R. Reisser, and Gary G. Efstration, Esquire, counsel for Defendant, Erik J. Reisser, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the attached Praecipe are adopted as an Order of Court. ~` J. nns n CFRTI from the record f the Court of Comm Pleas of r ounty> day of A'D' 20 ~ S. I,ee, Prothonotary' Chia ~.~.-.~- P n U r~ Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 CHRISTINA R. REISSER, : IN THE COURT OF COMMON PLEAS Plaintiff, :YORK COUNTY, PENNSYLVANIA v. :CIVIL ACTION LAW NO. 2006-FC-2255-Y02 ERIK J. REISSER, 2006-CV-2255-Y03 „ Defendant, :DIVORCE PRACIPE TO TRANSFER CASE TO CUMBERLAND COUNTY TO DOMESTIC RELATIONS OFFICE: r c c~-- •`'r = W .: ,. - ~ r., . The undersigned counsel request and concur in the transfer of the above captioned matter from York Bazbaza Su Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. 32317 to Cumberland County due to relocation of the parties. Esquire ary G. Efstration, Esquire Atton~iey for Defendant 232 E. Orange Lancaster, PA 17602 (717)291-9292 5~~~~.D. Christina R. Reisser PLAINTIFF 220 E. Lauer Lane STREET ADDRESS Came Hill, PA 17011 CITY-STATE-ZIP CODE IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE I ~BENNLAWFIRM 03-107 E. MARKET ST. '.O. BOX 5185 • • DOCKET NO 2006-~-2255- ~' PROTHONOTARY'S CERTIFICATION THE FOLLOWING FEES HAVE BEEN PAID: ALL CLAIMS $300 ( ) ALIMONY PENDENTE LITE ONLY X $50 VS MODIFICATION OF ALIMONY $200 Erik J. Reisser - DEFENDANT MODIFICATION OF A.P.L. $50 ( ) 3 Riverside Drive ,CJ/ '/ 7c : r - N STREET ADDRESS ~?3 ~- i=oie s-f ~vQ . ~ ~? Etters, PA 17319 ~' ~ Q °' S C~' ~~ ` - ~--i CITY-STATE-ZIP CODE yi ,-,, James F. Lowe, Esquire ATTORNEY FOR PLAINTIFF 103 E. Market Street P.O. Box 5185 STREET ADDRESS York, PA 17405-5185 CITY-STATE-ZIP CODE (717) 852-7020 PHONE NUMBER ATTORNEY FOR DEFENDANT `'~ - ' .~-- d .:: ~ STREET ADDRESS CITY-STATE-ZIP CODE PHONE NUMBER MOTION FOR APPOINTMENT OF MASTER (PURSUANT TO Pa. R.C.P. 1920.74) ' PLAINTIFF MOVES THE COURT TO 4 ~~ASTER WI~I'H RESPECT TO THE FOLLOWING CLAIMS: RECEIVE ()ALL CLAIMS RAISED IN THE PLEADINGS DEC 2 8 1006 (X) ALIMONY PENDENTE LITE ONLY: (X) NEW CLAIM YORK COUNTY ( ) MODIFICATIONp~VORCE MASTEF 'ORK, PA 17405-5185 • ~ ()MODIFICATION OF EXISTING ALIMONY ORDER I ~BENNLAWFIRM AND IN SUPPORT OF THE MOTION CERTIFIES AS FOLLOWS: 1. DISCOVERY IS NOT COMPLETE AS TO THE ABOVE CLAIMS FOR WHICH THE APPOINTMENT OF A MASTER IS REQUESTED. 2. THE DEFENDANT HAS NOT APPEARED IN THE ACTION PERSONALLY. 3. THE STATUTORY GROUNDS FOR DIVORCE ARE 3301(c), 3301(d), and 3301(a). 4. THE COMPLAINT WAS SENT TO THE POST OFFICE ON: December 22, 2006 .. S-e ~ v .~ Cl Qr7 ~~~ ,n 6 ~ ~ ~~ ~~ 5. THE METHOD OF SERVICE OF THE COMPLAINT WAS: Certified Mail 6. THE FOLLOWING CLAIMS HAVE BEEN RAISED IN THE PLEADINGS: 103-107 E. MARKET ST. '.O. BOX 5185 CLAIM DATE OF FILING 3301(a) Divorce December 15, 2006 3301(c) Divorce December 15, 2006 3301(d) Divorce December 15, 2006 Alimony Pendente Lite December 15, 2006 Alimony December 15, 2006 Equitable Distribution _ December 15, 2006 Counsel Fees December 15, 2006 Costs and Expenses December 15, 2006 Interim Counsel Fees December 15, 2006 Modification of Alimony P endente Lite N/A Modification/Termination of Alimony N/A _,--- _ 3 ES F. LOGUE, E ATTORNEY FOR PLAINTIFF SUPREME COURT ID: 202170 103 E. MARKET STREET, P.O. BOX 5185 YORK, PA 17405-5185 x~ / ~~ ~ (717) 852-7020 ~ DATE: SC (ORK, PA 17405-5185 I ~BENNLAWFIRM i~ • • IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA S~ y ~ ~ CHRISTINA R. REISSER NO. 2006-~-2255-Y,A2 ~• CIVIL ACTION -LAW ERIK J. REISSER DIVORCE ORDER APPOINTING MASTER ( )AND NOW, THIS DAY OF , 200_, ,ESQUIRE IS APPOINTED MASTER WITH RESPECT TO THE CLAIMS RAISED IN THIS CASE. ~- (~;AND NOW, THIS ~~ DAY OF~C~ ~11~V1~1 bP1Y , 200~~, THIS MATTER IS REFERRED TO THE DOMESTIC RELATIONS OFFICE FOR FURTHER PROCEEDINGS ON THE CLAIM FOR ALIMONY PENDENTE LITE. BY THE COURT, ~; ~ ~~ 103-107 E. MARKET ST. P.O. BOX 5185 YORK, PA 17405-5185 D o ^CY 'ey C ~ ~ C3 TTI ~ ~ ~ r~ ~ D ~c r- ~ ~ .,;,, ~~ • ~ -~ ~ y -n ~ ~ - ~ ~ --r tv ~- , 0 • • IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA I ~BENNLAWFIRM CHRISTINA R. REISSER V. ERIK J. REISSER N0.2006-FC-2255-Y02 CIVIL ACTION -LAW DIVORCE SCHEDULING OF PRELIMINARY CONFERENCE AND NOW, THIS DAY OF , 200 , A PRELIMINARY CONFERENCE IS SCHEDULED FOR 200_, AT (A.M.) (P.M.) IN THE DIVORCE MASTERS HEARING ROOM, YORK COUNTY JUDICIAL CENTER, 45 NORTH GEORGE STREET, SUITE 4400, YORK, PA. THE PARTIES AND ATTORNEYS MUST ATTEND. THEY MUST BE PREPARED TO DISCUSS ANTICIPATED ISSUES AND MAKE A GOOD FAITH EFFORT TO SETTLE SOME OR ALL CLAIMS. ANY REQUEST FOR A CONTINUANCE MUST BE IN WRITING AND MUST COMPLY WITH THE REQUIREMENTS OF YORK RULE OF CIVIL PROCEDURE 1920.51(k). IF THIS CASE INVOLVES ANY ECONOMIC CLAIMS, THE RESPONDENT IS HEREBY DIRECTED TO PROVIDE THE DIVORCE MASTERS OFFICE WITH A COPY OF HIS/HER FILED INCOME & ~~~~~- ULU~TEMENT AND INVENTORY UI ft (IF APPLICABLE) ON OR BEFORE THE DAY OF , 200 SEE PA.R.C.P. 1920.31(a)(1) AND 1920.33(a), RESPECTIVELY. FAILURE TO DO SO WILL SUBJECT THE RESPONDENT TO SANCTIONS, WHICH MAY INCLUDE 1os-1o7 E. MARKET sT. THE INABILITY TO PRESENT TESTIMONY ON CERTAIN ISSUES. P.O. BOX 5185 YORK, PA 17405-5185 • • BOTH PARTIES ARE HEREBY DIRECTED TO COMPLETE ALL I ~BENNLAWFIRM 103-107 E. MARKET ST. P.O. BOX 5185 OUTSTANDING DISCOVERY ITEMS PRIOR TO THE PRELIMINARY CONFERENCE. FAILURE TO DO SO WILL SUBJECT THE RECALCITRANT PARTY TO SANCTIONS, WHICH MAY INCLUDE AN AWARD OF COUNSEL FEES OR COSTS OR BOTH. BY THE COURT, YORK, PA 17405-5185 • _- • ~-~ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA ACTION TO DETERMINE APL DRO Docket No PACSES No. -SA- (Person seeking APL) Petitioner : Civil Action -Law -Action in Divorce (Person seeking APL) Respondent :Docket No. SE/FC- -Y15 ,~, ~~'~~~r , amass= yx~ , PETITION FOR ALIMONY PEND _;.~_ ~.~ c-~ - TO THE HONORABLE, THE JUDGES OF SAID COURT: , -- ~J T. - ~t --T - The Petitioner respectfully represents: - --- --. ~ - - ~ c ..~ 1. That the Petitioner, C ~ ~ ` 5 ~' n `~ ~' ~Q ~ S s~ %- • ~ '~ -+ ~ ~ ~ ~ ~ Lon ~ w~ ~ , is an individual residin at ~~ ~ `- c - ~ / c~,M ~ ~ /~ ~ c~ ~o v :~ f ~,q j 7 G / ~ , is the (strike out one) Plaintiff /~e€ert in the underlying Divorce Action, and plea ed the issu o all ny pendente lite in his/her ~o, ~r ~`~ ~-~~ (name of pleading) filed with the Prothonotary on /a~/~~~~ 2. Tl~ the Respondent, ~°`' '~ ~ ~O~ SSQ ~~ is an individual re idin at -3 ~` `'` ° ' S ~ ~ Q ,ice ~ v ~ ; ; ~"f- f4 b''S ~ o r- ~ ~o c~~ ~ ~~ i '7 3 / ~ g ,and is the (strike out one~•~tiff / i,e endant in the underlying Divorce Action. 3. hat the Petitioner and Respondent were married on ~Q~ g ~ ~ ~ < at ~ocucfhyr~~ Ur, ,~~oj //~Q f.~b ~fs~ ~~~~-chi ,'vow ~~~b~--/ar~1~~~} and separated on ~~`-~' ~~ `~ 4. That the Respondent has not sufficiently provided support for the Petitioner. 5. That the Respondent is believed to be employed at ~''`~ ~~~ Sc' ~ ~ ~ ~,~ address ~ 3 ~ - ~ o" r25'~f`" J9VF , sh re w5 ~r ~ and earns $ 39'~ y 5`l'• O net per y~ ~ ~ %~ ~ GGs ~e Respondent's social security number is o?~' 7 -5 " O ~ ~3 . e,~l~/piyQ!- f5, <'a/'.~2.n`t/~j ~iTVe.sTJc: :nc / Fs~.7der'r7~ "5 ~i1e'v/1~~2 6. That the Petitioner is/as~ex employedd at ~~ f~~' % ~ I ~j C' ~ G~ e l' ~ address ~-3~S /"~ar~e7" S~ CaM /~%/I.t'/1 i7o~(andearns$ 8So?.cG net per y~~f ~,~ ~GGs The Petitioner s social security number is a `~ - O - -7 qGS~- ~~"t~"f.ca/(r_e' i S ~/,~,rn~vr~~(y ~ ~~j'f"aa~ a17' ~tar,i,ti /1~0~`i¢ 7. That the Petitioner,/is not receiving publ/ic assistance in/the amount of $ semi-monthly for persons. DPW No. 8. That the amount asked by the Petitioner for Alimony Pendente Lite is a`' e ~a X' jiti U,rYI ~y~ d ~~ '~"" yr, IM "A ~MNN'~ ~~ ,~ ,~ /a~~. WHEREFORE, Petitioner prays that the Court enter an Order of A~l ~)~ti#~' Lite against the Respondent, as well as require the Respondent to provide medical support for the Petitioner, if appropriate. I verify that the statements made in this complaint, and attached exhibits if any, are true and correct. I understand that false statements herein are made subject to the penalties of 18PA.C.S. sec. 4904, relating to unsworn falsification to authorities. Date 'loner/Counsel r etitioner Date Petitioner/Counsel for Petitioner CHRISTINE R. REISSER, Plaintiff V. ERIC J. REISSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2007-CV 4153 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Gary G. Efstration, Esquire in the above-captioned matter. Mary ~, Efstration, Esquire 232 East Orange Street Second Floor / Lancaster, PA 17602 Date: ~ ~/6~ (717) 291-9292 PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Ni captioned matter. Staley O' ixe^in the above- Date: ''6 ~ I11 ' ~~ NicZiole M. Stay O'Gc ID #79866 1719 North Front Street Harrisburg, PA 17102 (717)234-4178 t ~ ~' {°„~ ' ~~ ., ~~ ~ - ;^• ~., _ _,~ t Y, ...z ,; i f-,, .~-i Cf i ;,y r _~ Nichols M. Staley O'Gorman, Esquire ID #79866 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717 234-4178 nstaley(c~okh.com CHRISTINA R. REISSER, Plaintiff v. ERIK J. REISSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2007-4153 CIVIL ACTION -LAW IN DIVORCE AND CUSTODY MOTION TO SCHEDULE CUSTODY CONCILIATION CONFERENCE AND NOW, comes Movant, Erik J. Reiser, by and through his attorneys, Purcell, Krug and Haller, and files the following Motion: 1. Movant is Erik J. Reiser, Defendant in the above captioned action. 2. Respondent is Christina R. Reiser, Plaintiff in the above captioned action. 3. This action was commenced by the filing of a Divorce Complaint on December 15, 2006, which included a count for child custody. 4. The parties are the parents of three minor children: Adriana M. Reiser (DOB 4/19/96), Aidan A. Reiser (DOB 11/3/00) and Adlai P. Reiser (DOB 7/25/05). 5. The action was commenced in York County and transferred to Cumberland County by Order of Court dated June 18, 2007. 6. A Custody Conciliation Conference did not occur prior to the transfer of this case, and was not scheduled in Cumberland County upon transfer of the action. r -. 7. No Order has been entered in this case, and Movant desires the entry of an Order defining the custodial rights and responsibilities of the parties. WHEREFORE, Movant, Erik J. Reisser, respectfully requests this Honorable Court to schedule a Custody Conciliation Conference in this matter. LL, KRUG & HALLER gy w" ., Nich le M. Staley Orman Esquire I D # 9866 171 North Front Street Harrisburg, PA 17102 717 234-4178 Attorney for Movant, Erik J. Reisser Date: ~ r~ I -~~ r CERTIFICATE OF SERVICE I, CATHI LEIGH MCADAMS, an employee of the law firm of Purcell, Krug & Haller, counsel for Plaintiff, hereby certify that service of the foregoing Motion to Schedule Custody Conciliation Conference, is made upon the following by Regular Mail, Postage Prepaid on '~ to: Barbara Sumple Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070 Cathi Leigh Adams __.e ~' >' N r ~ ~-' ss , xY 4`; 3 ~ c ~±? '~ O CHRISTINA R. REISSER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ERIK J. REISSER DEFENDANT • 07-4153 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, September 14, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 16, 2007 at 1:00 PM for aPre-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 ail existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: 1sl ohn . M r. 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 inforrnation 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~!#~f1~h~c! ~~~~ ~~ L { ~~ ~d h ! d3S t4~Z ,ttiVl H10 3HL s~ ~<!~'Id Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINA R. REISSER, IN THE COURT OF COMMON PLEAS Plaintiff v. ERIK J. REISSER, Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4153 PACSES NO. 820108860 CIVIL ACTION -LAW DRS ATTACHMENT FOR APL PROCEEDINGS PET ITIONER NAME Christina R. Reisser ADDRESS 2 Old Coach Lane, Carlisle, PA BIRTH DATE March 1, 1973 SOCIAL SECURITY NUMBER 209-60-7904 HOME PHONE 717 422-5420 WORK PHONE 717 609-7045 EMPLOYER NAME Centu 21 Piscioneri EMPLOYER ADDRESS 3315 Market Street, Cam Hill, PA JOB TITLE/POSITION Realtor DATE EMPLOYMENT COMMENCED Aril, 2003 GROSS PAY Commission Onl -Various NET PAY Commission Onl -Various OTHER INCOME None ATTORNEY'S NAME Barbara Sum le-Sullivan, Es uire ATTORNEY'S ADDRESS 549 Brid e Street, New Cumberland, PA 17070 ATTORNEY'S PHONE NUMBER 717 774-1445 RESPONDENT NAME Erik J. Reisser ADDRESS Jacob Lane, Mechanicsbur , PA BIRTH DATE Ma 5, 1971 SOCIAL SECURITY NUMBER 207-52-0283 HOME PHONE 717 730-4060 WORK PHONE 717 235-9888 EMPLOYER NAME CR Consultin Self-Em to ed EMPLOYER ADDRESS Market Street, Cam Hill, PA JOB TITLE/POSITION Real Estate A raiser DATE EMPLOYMENT COMMENCED 2002 GROSS PAY $99,719.00-2006 Wages $185,080.00- 2006 CR Consultin Profit NET PAY Unknown OTHER INCOME None ATTORNEY'S NAME Nichole M. Stale O'Gorman, Es uire ATTORNEY' S ADDRESS 1719 North Front Street, Harrisbur , PA 171.02 ATTORNEY'S PHONE NUMBER 717 234-4178 MORTGAGE INFORMATION DATE OF MARRIAGE October 9, 1999 PLACE OF MARRIAGE New Cumberland, PA DATE OF SEPARATION November 23, 2006 ADDRESS OF LAST MARITAL HOME 220 East Lauer Lane, Camp Hill, PA Marital Home sold on Februa 28, 2007 DESCRIPTION OF DOCUMENT RAISING APL CLAIM Divorce Complaint and Petition for Alimony Pendente Lite DATE APL DOCUMENT FILED December 15, 2006 and December 22, 2006 C`? r'~ C~ c- ~, -,~ __., `- ~_ c%x om ~r b -'~ `n , _ .-,',` --~ =. ~w:A ~ , " 7 ~ i ~ .. ~ ~j ~! --G C;,;;, CHRISTINE R. REISSER, Plaintiff V. ERIC J. REISSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2007-CV 4153 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 15, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit 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: ~ ~ ~ ~~ ERIK J. REISSER, Defendant C) -J `..~ •~ i `~~ ~ i'~ l t~ C.3 r` :- f `? J`.. ~u -- Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 CHRISTINA R. REISSER, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 07-4153 ERIK J. REISSER, Defendant PACSES NO. 820108860 CIVIL ACTION -LAW PETITION REQUESTING HEARING ON ALIMONY PENDENTE LITE 1. Petitioner is Christina R. Reisser, an individual residing at 2 Old Coach Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondent is Erik J. Reisser, an individual residing at 504 Jacob Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. On December 20, 2006, Petitioner filed a Complaint for Support in the Court of Common Pleas of York County, Docket No. 2006-CV-2255-Y03. 4. On December 28, 2006, Petitioner also filed a Petition for Alimony Pendente Lite in the Court of Common Pleas of York County, Docket No. 03412 SA 2006. 5. The matters were scheduled for conference on March 13, 2007 and rescheduled on May 1, 2007. 6. Petitioner sought transfer of the York County actions to Cumberland County, the -1- county were Petitioner and Respondent both reside. 7. The actions were transferred to Cumberland County wherein a support conference was scheduled for September 13, 2007 and subsequently rescheduled for September 27, 2007.. 8. Petitioner requests a hearing be promptly scheduled on her Alimony Pendente Lite claim. 9. Petitioner requests retroactivity back to her original filing, attachment and referral to the Domestic Relations Office in the Court of Common Pleas of York County matter on December 28, 2006. 10. An updated Domestic Relations Section Attachment for APL Proceedings is attached hereto as Exhibit "A." WHEREFORE, Petitioner requests a hearing be scheduled on her Alimony Pendente Lite claim. /, Dated: October 2, 2007 (717) 774-1445 Supreme Court No. 32317 Attorney for Plaintiff -Z- Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Barbara Sample-Sullivan, Esquire Supreme Court r32 ~ 17 ,49 Bridge Street Ne~~ Cumberland, PA 17070 1717) 774-144 CHRISTINA R. REISSER, IN THE COURT OF COMMON PLEAS Plaintiff CUIVIBERLAI~TD COUNTY, PENNSYLV 4NLA ~. : NO. 07-4153 C N PACSES NO. 820108860 .Tt ~- c~ -' _ ERIK J. REISSER, CIV~II, ACTION -LAW -~ ~'=~- `~ r,~ ~ ~' _~ y Defendant -= - - - -~ ~= : c=.> _ ~ -~ -' ~ r~ DRS A.TTACffil~ENT I~ OR APL PROCEEDINGS n4` ' ~ ~ -.. r ~, --~ PE TiTIOI~TER ~ ~~ Christina R. Reisser ~4BJ~RES5 2 Old Coach Lane, Carlisle, PA BIRTH -ATE March 1, 1973 SOCIAL SECITRI'T~' 1'~TUNIBER 209-60-7904 HOME PHONE 717) 422_5420 V~itE?RK pHO~ -(717) 609-7045 E1~PLC?~'ER NAME Century 21 Piscioneri EI~IPL€3~i'ERDRESS 3315 Market Streef, ..Cam Hill; PA .. 3C1~B TIT•LE/POSITIE3N Realtor - -.. _ . BATE ENIPLO~'l~'>`ENT' COl~'Il~'>LJENCEB ~ ril, 2003 GROSS PA.I' Commission Only- Various ~,~~' PAI' Commission Only -Various OTHERIlV"COME None _ _ ATTORNEY'S NAME ~! Barbara Sum le-Sullivan, Es uire TT ~ RNE~"S ABaIZESS A O 549 Bridge Street, New Cumberland, PA 17070 ATTOR~!?E~"S PHONE NITI4IBER (717 774-1445 RESPONDENT NAME Erik J. Reisser ADDRESS Jacob Lane, Mechanicsbur , PA BIRTH DATE Ma 5, 1971 SOCIAL SECURITY NiTMBER 207-52-0283 HOiYlE PHONE 717.' 730=4060 .WORK PHONE 717 235-9888 EMPLOI'ER NAME CR Consultin {Self-Em to ed) EMPLOYER ADDRESS Market Street, Cam Hill, PA j FOB ~'FTLE/POSI'1:'ION Real Estate A praiser ~ 13A~'E E1F~PLOY1~'IEN'I' COIl~'IEI~CED 2002 i CROSS PAY $99,719.00-2006 Wages $18,080.00- 2006 CR Consulting Profit NET PAY Unknown OTHER P~TCOll~E None ATTORNEY'S NAll~E Nichole M. Stale O'Gorman, Es uire ATTORNEY'S ABIIRESS 1719 North Front Street, Harrisbur , PA I7I02 ATTORNEY'S PHOl!'E NUIF~ER ~ (71.7) 234-4178 MORTGAGE INFORIVF.4TION DATE OF NL~RRIAGE October 9, 1999 PLACE OF NI:~:RRIAGE New Cumberland, PA I}ATE OF SEP ORATION November 23, 2006 ADBRESS OF LAST MARiTAE HOME 220 East Lauer Lane, Camp Hi11, I'A Marital Home sold on February 28, 2007 ~3ESCRR'TION OF DOCITl~ENT RAISING ~4PL CLAIlK Divorce Complaint .and Petition for Alimony Pendente Lite D~4TE API. DOCI3MENT FILED December 1.6, 2006 and December 22, 2406 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (7171774-1445 CHRISTINA R. REISSER, Plaintiff vi. ERIK J. REISSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.07-4153 PACSES NO. 820108860 CIVIL ACTION -LAW CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the PETITION REQUESTING HEARING ON ALIMONY PENDENTE LITE, in the above-captioned matter upon the following individual, by United States first-class mail, postage prepaid, addressed as follows: Nichole M. Staley O'Gorman, Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102-2392 DATE: October 2, 2007 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff t ? ~` ~ ;~ ._., r-3 -_-~ -~-;-i ' 1 . r ~ i _. " (_:.) 1 f i ""' `J:7 ~ .{ Nichole M. Staley O'Gorman, Esquire ID #79866 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717 234-4178 nstaley~a_pkh.com CHRISTINA R. REISSER, Plaintiff v. ERIK J. REISSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2007-4153 C{VIL ACTION -LAW IN DIVORCE PETITION FOR ENFORCEMENT OF MARITAL SETTLEMENT AGREEMENT AND NOW, comes the Defendant, Erik J. Reisser, by his attorneys, Purcell, Krug & Haller, and Petitions This Honorable Court as follows: 1. Petitioner is Erik J. Reisser, Defendant in the above captioned divorce action (hereinafter "Husband") 2. Respondent is Christina R. Reisser, Plaintiff in the above captioned divorce action (hereinafter "Wife"). 3. The above captioned divorce action was initiated in York County on December 15, 2006 by Wife, through her first attorney, James F. Logue, Esquire. 4. By agreement of the parties, the matter was transferred to the jurisdiction of the Cumberland County Court of Common Pleas on or about June 18, 2007, as both parties have relocated to Cumberland County. 5. The parties were married on October 9, 1999. 6. There are three children of this marriage. 7. The parties separated on or about November 24, 2006 when Wife called Husband at his place of business to announce that she was leaving him. 8. Although blind-sided and emotionally devastated by the announcement, Husband agreed to cooperate with Wife to effectuate an amicable settlement as to divorce, support and child custody issues. 9. On December 5, 2006, the parties met at a local restaurant and reached a comprehensive settlement as to all matters between them, including child custody, divorce, division of property and financial support. 10. Following this meeting, Husband and Wife parted company. Husband placed in writing the terms of the parties' agreement and e-mailed the document to Wife. 11. Later the same day, the parties met again and signed the document prepared by Husband. A true and correct copy of same is attached hereto and made part hereof as Exhibit "A". 12. Thereafter, Husband learned that Wife had an ongoing extra-marital relationship with Dr. Jonathan Verrecchio, with whom she now resides. 13. At all times prior to the December 5th agreement, Wife specifically denied the existence of any extra-marital relationship. 14. Upon learning of the affair, Husband promptly advised Wife that he felt he had been misled and would not have agreed to pay alimony had he known the truth. 15. After discussion, the parties agreed that Husband would pay alimony in the amount of $3,000 per month through December 31, 2007 and not until the parties' 2 youngest son turned five as they had originally agreed. 16. At Wife's suggestion, the parties attended mediation on or about December 28, 2006 to discuss details surrounding implementation of their agreement. 17. Mediation was conducted by Rebecca N. Tortorici, Esquire, a mediator selected by Wife. 18. The parties attended one session, following which Ms. Tortorici prepared a Memorandum of Understanding describing the details agreed upon by the parties. A true and correct copy of same is attached hereto and made part hereof as Exhibit "6". 19. The majority of the mediation session was spent discussing an agreed expansion of Husband's periods of physical custody with the children. 20. The parties also agreed to distribute a greater share of retirement assets to Wife in lieu of the cash payment (of an approximately equal amount) described in the December 5th agreement. 21. But for the agreed modification of alimony and child custody provisions, the original understanding of the parties did not materially change. 22. Thereafter, Husband acted in reliance on the parties' agreement and each of them began to perform their respective obligations under the agreement, as follows: a. Husband paid, and Wife accepted, support in the amount of $6,000 per month; b. Husband has continued to pay the health insurance premiums for Wife and the parties' children at an out-of-pocket cost of approximately $900 per month; c. Wife elected to sell 220 East Lauer Lane, Husband cooperated as needed to effectuate the sale and the associated mortgage with Astoria Mortgage was satisfied; 3 d. From the time of the agreement until the time of sale, Wife paid the mortgage, all maintenance, real estate taxes, repairs and other expenses related to 220 East Lauer Lane; e. Husband elected to sell 3 Riverside Drive, Wife cooperated as needed to effectuate the sale and the associated mortgage with Wells Fargo was satisfied; Until the time of sale, Husband paid the mortgage, all maintenance, real estate taxes, repairs and other expenses related to 3 Riverside Drive; g. Husband received and retained an escrow refund in the amount of $2,100 from the Riverside Drive mortgagee; h. Wife removed and retained all personal property from 220 East Lauer Lane; Husband removed and retained all personal property from 3 Riverside Drive; Husband sold the Yamaha wave runner and used the proceeds, along with a portion of his separate funds, to satisfy the lien on the wave runner; k. The parties' joint checking and savings accounts were closed; Wife retained her M&T checking account; m. Husband retained his M&T checking account; n. Wife has made the monthly payments on the Chase credit card; o. Husband has made the monthly payments on the Circuit City credit card and on the Yamaha account until it was paid in full; p. Husband's counsel prepared a marital settlement agreement which includes the essential terms of the agreement reached by the parties; and q. Husband relocated his business from Shrewsbury to the Camp Hill area to facilitate the agreed child custody arrangements. 23. On or about January 22, 2007, Husband's former counsel, Gary Efstration, 4 Esquire, prepared and forwarded a marital settlement agreement containing the essential terms of the parties' agreement. 24. Wife subsequently retained new counsel, Barbara Sumple Sullivan, Esquire, who has advised that Wife will not sign the marital settlement agreement and seeks to substantially change the terms of the parties' agreement, even though she has accepted and continues to enjoy the benefits of Husband's performance under the existing agreement. 25. Husband respectfully requests that this Honorable Court enforce the agreement reached by the parties and enter an order incorporating the terms of the Memorandum of Understanding attached hereto as Exhibit "B". 26. By virtue of Wife's refusal to execute a marital settlement agreement which incorporates the terms of the parties' agreement, Husband has been and will continue to be caused to incur substantial counsel fees in the preparation, filing and resolution of this Petition. 27. Pursuant to 42 Pa.C.S.A. § 2503(7), Defendant is entitled to an award of counsel fees incurred as a result of Wife's dilatory, obdurate or vexatious conduct. 28. Further, pursuant to 23 Pa.C.S.A. §3502(e), Husband is entitled to an award of counsel fees to enforce the terms of the parties' agreement. WHEREFORE, Defendant, Erik J. Reisser respectfully requests this Honorable Court to enter an Order providing as follows: A. Resolving all divorce and economic claims filed to the above captioned term and number in accordance with the terms of the Memorandum of Understanding attached as Exhibit "B", which accurately reflects the agreement reached by the parties; B. Further ordering Plaintiff to execute an Affidavit of Consent and all other documents needed to finalize the divorce between the parties and to effectuate the terms of the parties' agreement; C. Ordering Plaintiff to pay Defendant's counsel fees incurred in connection with the preparation, filing and resolution of this Petition. PURCELL, KRUG & HALL N cho`f~'bt'"St Ids an, Esquire I #79866 1719 North F ont S reet Harrisburg, P 171 717 234-4178 Attorney for Plaintiff Date: /~ ,~, ~-~ 6 AGREED ON 12(05(06 I . TINA AGREES TO RELINQUISH ALL RIGHTS OF CR CONSULTING, LLC 2. TINA KEEPS 220 E LAUER, IT'S CONTENTS (MINUS PERSONALS BELONGING TO ERIK) & WILI. REMOVE ERIK FROM DEED & LOAN THROUGH PREFERABLY A REFINANCE 3. TINA KEEPS HER IRA & MILLENIUM PLAN SUPPORT (CHILD & SPOUSAL) IN THE AMOUNT OF $6000 PER MONTH UNTIL ADLAI IS 5 YEARS OLD AT WHICH TIME SPOUSAL SUPPORT WILL CEASE & C}1[LD SUPPORT WILL BE NEGOTIATED. SHOULD TINA RE-MARRY ALL SPOUSAL SUPPORT CEASES AND CHILD SUPPORT WILL BE NEGOTIATED FROM THERE FORWARD. ALL BILLS ASSOCIATED WITH 220 E LAUER ARE RELINQUISHED TO TINA EXCEPT NOTED WITHIN. TINA KEEPS HER PERSONAL BANK ACCOUNT (M&T) TINA PAYS HER CHASE CREDIT CARD ALL OTHER JOINT ACCOUNTS TO BE CLOSED (CURRENTLY NO BALANCE) ERIK WILL PAY TINA $25,000 AT THE FINALITY OF THE DIVORCE AT WHICH TIME L1:GAL FEES TO BE DEDUCTED AMICABLY. CUSTODY: JOINT LEGAL CUSTODY WITH AGREED VISITATION RIGHTS AT A MINIMUM OF 2 NIGHTS PER WEEK & EVERY OTHER WEEKEND WITH VACATIONS NEGOTIABLE. ALL LIFE INSURANCE FOR TINA & ERIK WILL BE PUT INTO TRUST FOR THE ALL 3 CHILDREN. TINA AGREES TO PAY HER OWN CAR INSURANCE ]. ERIK KEEPS 3 RNERSIDE DR AND WILL REMOVE TINA THROUGH REFINANCE FORTHCOMING. 2. ERIK KEEPS ALL PERSONAL INVESTMENTS (IRAs, ETC) 3. TAP 529 PLANS REMAIN IN ERIK'S NAME FOR CHILDREN'S USE 4. ERIK KEEPS 1979 MERCEDES 5. ERIK CONTINUES TO PAY TINA'S CAR (LAND ROVER) UNTIL FULLY PAID, A'T' WHICH TIME THE CAR BECOMES TINA'S. ALL REPAIR, ETC COSTS ARE TO BE PAID BY TINA. 6. ERIK WILL PAY CIRCUIT CITY & YAMAHA BILLS 7. ERIK KEEPS HIS PERSONAL BANK ACCOUNT (M&T) 8. ERIK CONTINUES TO PAY HEALTH INSURANCE FOR CHILDREN. 9. ERIK PAYS TINA'S HEALTH INSURANCE UNTIL ADLAI TURNS 5 OR SHE SHOULD RE-MARRY ]0. 1 ADDT'L PHONE LINE TO REMAIN IN THE HOUSE FOR BUSINESS USE TO BE', PAID BY ERIK UNTIL ADLAI TURNS 5 OR TINA SHOULD REMARRY 11. COMPUTER AT HOUSE CONTINUALLY TO BE PAID BY ERIK UNTIL IT iS DEEIvIED UNUSABLE OR ADLAI TURNS 5 OR TINA SHOULD RE-MARRY %Z-/U ~ld~ G~ I ~ ~.J~ ~~.r ~~~~ ~~~ ~~~~~ r ,,` fit ~ ~ (~~' ~--~- v1~4-~~--, MEMORANDUM Off' DERSTANDING The Parties, Erik Reiser ("Erik")and Christina Reissez ("Tina"), attended mediation lu address economic issues and child related issues. The parties reached tl~e following resolutions. 1. Distribution of Assets. A. Real Estate. 1. 220 East Lauer Lane Camp Hill. Pennsylvania. All equity and rights of ownership will be Tina's property together with all the contents of the property with the exception of the contents of the basement, Erik's personal effects and some other items. The parties will make a Iist of these items to be attached to the final formal agreement. Tina is solely responsible for payment of the maintenance, real estate taxes, repairs and all other expenses related to ownership including the mortgage in favor ofAstoria Mortgage. Tina will refinance the Astoria mortgage removing Erik from all liability witlun sixty days of the signing of the forn~al Marital Scttlctzlcnt Agreement. The Deed will be transferred at the time of the settlement on the mortgage refinance. Erik is solely responsible for addressing and. satisfying any and all presently pending claims of the Lauer Lane neighbor (Sanay). 'l. 3);tiverside Urive Etters. Pennsylvania. All equity and rights of ownerslup will be Erik's property together with all. the contents of the property. However, should Frik decide at any tirnc to sell the property, Tina shall have first right of rcfu nl to purch2~c the property at fair markcl value. Erik w711 give Tina written notice of his intention to sell and. Tina will notify Erik within ten (10) days of receipt of the ztotice to advise Erik whether she is interested in buying the property. If so, the property will be appraised by a mutually agreeable appraiser (if they do not agree on the fair market value). Tina will have thirty (30) days to notify Ertl: in, writing whether or not she will exercise her right to purchase at the appraised or agreed. value. Erik is solely responsible for payment of the maintenance, real estate taxes, repairs and all. other expenses related to ownership including the mortgage in favor of Wells Fargo. Frik will refinance the Wells Fargo mortgage removing Tina from all liability within sixty days of the signing of the formal Marital Settlement Agreement. The Deed will be transferred at the time of the settlement on the mortgage refinance. Erik is solely responsible for addressing a,nd satisfying any and all claims o£ Tina's family regarding the contents of the Riverside Drive property. B. Business. Erik will be have sole and exclusive ownership of all shares and the business kn.o~un. as CR Consulting, LLC, including all fivniture, equipment, accounts receivable, work in progress, deposits on account in banks, notes receivable and all and all other assets. Frill will indemnify and hold Tina harmless from all liability far any business related liabilities including accounts payable, notes payable, leases, cozttracts and any and all other liabilities. C. I~•lgtonized Vehicles. Erik ur CR Cuntiulting LLC will have sole ow~ershi.p of the l 979 Mercedes and the 2003 Lexus which is encumbered by a lien in favor of Citizen's Bank ($49,000). Tina will have sole ownership the 2003 Land Rover which is encumbered by a lien in favor of M&T Page 1 of 4 Bank ($11,000). Erik will have sole ownership of the Yahama Wave Runner and will pay the debt to Yamaha ($6,000) as noted in the Debts paragraph below. Frik or CR Consulting LLC will be solely responsible for full payment of the M&T lien on the Land Rover and the Citizen's lien on the Lexus and will make the monthly payments. I Iowever, should Tina so request at any time, Erik will pay the M&T lien in full within fiftcctt (15 j days. Each pa.t'ty is sulcly respunsiblr fur pa.ytatrttt of the insurance, repairs, maintenance, registration and other expenses associated with his/her vehicle(s). D. Accounts. All. joint accounts have zero or nominal balances on account and will be closed; each party will retain all funds withdrawn or utilized by him/her from the joint accounts before closure without any offseUcompensa±ion. Tina will have sole ownership of her M&T clteckitlg account. F.rik will have sole owncrslvp all the personal investments, his ITT&T account anal all. other accounts in his name only with the exception of the IR1~ rollover designated in paragraph IF. The TAP plans will remain in. Erik's name for the children's use as designated by the accounts. 1/. llebts. Tina will be solely responsible for full payment and satisfaction of the Chase credit card ($2,000). Erik will be solely responsible for full payment and satisfaction of the Circuit City ($6,000) and Yahama ($6,000) accounts and tltc Land Rover li.cn ($11,000). P. Retirement. Tina will be the sole owner of her IRA account and Millennium Plan with an approximate aggregate value ofSeventy-Five Thousand Dollars ($75,000). Erik will do the work necessary with the financial advisor to have the 1Vfillennium Plan. (employee benei:zt through CR Consulting LLC) converted to an asset transferred to Tina's individual. Retirement Account. Erik has two Individual Retirement Accounts with an approximate aggregate value of One Hundred Seventeen Dollars ($117,000). The parties will sigrtthe paperwork necessary (whether by Stipulated Order for IRA rollover or Qualified Domestic Relations Order. whichever the IRA custodian requires) to effectuate a custodian to custodian IRA rollover from one of Eri k's I.RAs to Tina's I.RA, a specific sum calculated as follows: fifty percent of the difference between the aggregate vat ue of bothpa.rties' retirement assets after subtracting boththe value ofTina's retirement assets and all costs fur thr divur~r, Millrittuuttt Phut cuuvrt~iott cltar~r~ arid. all legal fern of buth Tina anti Erik, Or stated another ~.vay : 0.50 x ([aggregate value of all retirement assets -value of Tina's retirement assets] -all costs for the ditforce., Millerini.um Plan coziversi.on charges and ail legal fees of both Tina and. Erik). G. Life insu ante. The Guardian/John Hancock policy(sj on the life of Erik will be Erik's sole and. exclusive property. As long as Erik maintains these policies, he wit l name a trust as the sole brrtcficiary of thr pulicy(sj clca.tli bcitcfits; rite trwt 5ha11 name the children as the sole beneficiaries in equal shares and shall allow for the trustee to make advance distributions to the child(renj before the age of twenty-five years for the welfare and benefit of the children. Frik's maintenance of the policy(s) is in his sole discretion and is not an obligation on his part. Mediator's 1~'ote Regarding the Trust Terrrrs : Tlie parties did nor decide tMe particulars, a suggested startirzg point for• the discussion could be : "When each child reaches the age of twenty-f ve years, that child will receive a distribution. calculated by dividing the initial trust balance by three and subtracting the advance distributions made for that child's sole bcrcCt and, if advance distributions were made to benef t all the children, the proportionate share o~f those distributions shall also be subtracted. When the youngest child reaches the age of twenty-five years and has received the final distrihuti~n, any and Paae 2 of =t all other earnings remaining the in the trust will be distributed equally between the three children (or the survivors if any should die before this date) and the trust terminated." II. Spousal Support, Aliimanti Erik will pay the sum of Three Thousand ($3,000) dollars monthly to Tina as spousal support or al imony for the period January 2007-December 2007; payment will be made directly to Tina by check on the first Friday of the month or the fifth day of the month., whichever is later. Alimony swill cease upon the death of either party or Tina's remarriage. In addition, Erik will maintain the presently existing health insurance coverage on Tina until the entry of the divorce decree or March 31, 2007, whichever is earlier. III. Legal Fees, Costs and Eapenscs. Erik will pay ail the casts and expenses to effectuate the divorce and. division of assets. Erik will also pay all of Tina's legal fees and his own legal fees invoiced through the completiozt of the retirement division stated in Paragraph IP. ~t~tediator's Note The parties did not specify a date but a date ofsonie kind should be inserted because the, fees are tied to the w»ount distributed in ~I~e IRA divr'sio~~ m7d without a date, there is an "endless loop ". The legal fees, costs and expenses will be factored into the division of the retirement as stated in paragraph IF of this Memorandum. Iv. Child Custod A. Leal Custody. The parties will share legal custody. The parties will each consult with the non-custodial parent before any medical treatment is administered or prescriptions given. to ar~y of the children. if the non-custodial parent disapproves, the treatment or prescription will not be a~luiillistrl~a or give».; the only exception is a life tlucatening clncrgcncy at a time when the child is in the care of a medical emergency team at the scene of the emergency of under the care of a physician (other than Tina's raramour) in the emergency roam of a hospital. The parties acknowledge that major decisions regarding the children's academic, medical/psychological/dental, extracurricular matters require the consent of both parties before any action cart be taken by either P~y• B. P11Y51Ca1 CUStod~ The partlt5 w1I1 SlZare phy51Gc11 GustOdy. Duelll~ t11C "tr8.1151t10I1 p11aSG" between the present and the purchase and establishment of Erik's new permanent residence (3 Riverside Drive is not Erik's pernaanent residence), the parties will arrange the periods of custody agreeably between them with a minimum of alternate ~r~~eekertds anal two nights per week to each parry. When Erik has established hi.s permanent residence, he will notify Tina and the parties will begin. alternating weeks of physical custody. 'Tlae parties will. be I].ex.ible with the joint physical custody arrangement and will work to accommodate requests for changes, and the vacation anal holiday plans of the other party for the benefit and welfare of the children. C. Telephone Communications with Children if the non-custodial party calls the children and leaves a message, the custodial parent «~ill insure a return call is placed to the non-custodial parent by 9:30 pm the day the message is left. When Tina is the custodial party, she will first return the call to Erik's cell phone and then to Erik's home phone. When Erik is the custodial parry, he will t~rst rettun the call to Tina's home phone and then to Tina's cell phone. The custodial party need Page 3 of ~ only return the call to these two numbers and leave a message if the non-custodial party does not answer either phone. D. Transportatiox~~ The party who will be assuming custody is responsible for transportation o1'the children. V. Child Support. Erik will pay the sum of Three Thousand. Dollars ($3,000) monthly ac child support for the three children : Adri anna Reisser born Apri119, l 996; Aidan Reisser born. November 3, 2000; and Adlai Reisser born July 25, 2005. Erik will maintain the health insurance for the children. V1. Axvorce. The ivlariial Settlement Agreement will state Thal bush parries acknuwlccl~,c: ltiat ~-v indi gnities under Pennsylvania law were committed by Erik dtuing the marriage but the parties agree the marriage is irretrievably broken ann will execute the neceteary Affidavits c,f C'onsent and Waivers of Notice upon the expiration of the ninety day waiting period (approximately March 26, 2007). VIi. Formalization of Agreement/Case Closing. Erik's attorney, Gary Efstration, Esquire, 232 East Orange Street, Lancaster, Pennsylvania, has been elected to draft the Marital Settlement Agreement and necessary documents to effectuate the IRA rollover for. review and approval by all parties and counsel. Tl~e parties realise That this Memorandum does not constitute a formal agreement or Court Order. Respectfully Submitted by the Mediator Date :December 28, 2006 REBECCA N. TORTORICI, ESQ. Supreme Court LD. 43527 ~ 11.0 East Marlcet Street York. PA 1.7402 Telephone: (717) 751-0443 Page 4 0£ 4 VERIFICATION Erik J. Reisser plaintiff in the within action, I, hereby verify that the facts contained in the foregoing Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. DATE : /L~ ~' ~-~ CERTIFICATE OF SERVICE I, Angela S. Shaffer, employee for the law firm of Purcell, Krug & Haller, counsel for Defendant, Erik J. Reisser, hereby certify that service of the foregoing Petition for Enforcement of Marital Settlement Agreement was made on the following via regular mail on October 10. 2007: Barbara Sumple Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Attorney for Plaintiff Angela S. Shaffe r-~ ~ ~ C? ~ ~ ... L~.'~ C"~ ~ : ~ ,r,~ ~ -*+ ~~ t ¢~ , ~ ,, S3 ~ +~ L.c,..~ ~ ~ t ~ ~~ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CHRISTINA K. REISSER ) Docket Number 07-4153 CIVIL Plaintiff ) vs. ) PACSES Case Number 851109526 ERIK J. REISSER ) Defendant )Other State ID Number ORDER OF COURT You, ERIK J. REISSER plaintiff/defendant of 504 JACOB LN, MECHANICSBURG, PA. 17050-7218-04 are Ordered t0 appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the DECEMBER 4, 2007 at 8 : 3 oAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21302 REISSER PACSES Case Number: 851109526 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: ~- S `(~~ ~ ~~ JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. v• REISSER CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717 > 2 4 0 - 6 2 2 5 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Rev. 1 Service Type M Worker ID 213 0 2 w ~') ~ ~ C'. ~ ~'~~ S't-1 C' ~- , ~ ~~ ~1 ._ ~r .. ~. .. ~+ ^r ~ ~ ~ F'Y ~ y ~ . i -~ ' --~ , ~ -_~; " .%' ( ~M (~ } ~ In the Court of Common Pleas of C~ERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CHRISTINA K. REISSER ) Docket Number 07-4153 CIVIL Plaintiff ) vs. ) PACSES Case Number 8 5110 9 5 2 6 ERIK J. REISSER ) Defendant ) Other State ID Number ORDER OF COURT YOU, CHRISTINA K. REISSER 2 OLD COACH LN, CARLISLE, PA. 17013-8794-02 are Ordered t0 appear at DOMESTIC RELATIONS HEARING RM plaintiff/defendant of DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the DECEMBER 4, 2007 at 8 : 3 oAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21302 REISSER PACSES Case Number: 851109526 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: , ~ ~1.C - p~ • ~ ~r~. JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. v• REISSER CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 24 0 - 6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Service Type M Page 2 of 2 Form CM-509 Rev. 1 Worker ID 21302 ~~ ~~ ~J ~-r V"t tN r ~ Nichole M. Staley O'Gorman, Esquire ID #79866 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717 234-4178 nstaley(a~pkh.com CHRISTINA R. REISSER, Plaintiff v. ERIK J. REISSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2007-4153 CIVIL ACTION -LAW IN DIVORCE ADDENDUM TO PETITION FOR ENFORCEMENT OF MARITAL SETTLEMENT AGREEMENT AND NOW, comes the Defendant, Erik J. Reisser, by his attorneys, Purcell, Krug & Haller, and avers as follows: 29. On October 4, 2007, The Honorable Judge Hess signed a support Order docketed to number 683 S 2007. This is the only prior judicial assignment with respect to the above referenced parties. 30. Counsel for the parties have discussed Defendant's Petition at length, and counsel for Plaintiff does not concur. WHEREFORE, Defendant, Erik J. Reisser respectfully requests this Honorable Court to enter an Order providing as follows: A. Resolving all divorce and economic claims filed to the above captioned term and number in accordance with the terms of the Memorandum of Understanding attached as Exhibit "B", which Y ~ • B. C accurately reflects the agreement reached by the parties; Further ordering Plaintiff to execute an Affidavit of Consent and all other documents needed to finalize the divorce between the parties and to effectuate the terms of the parties' agreement; Ordering Plaintiff to pay Defendant's counsel fees incurred in connection with the preparation, filing and resolution of this Petition. URCELL, KRUG & HALLER ~a~ ulnlo'1 ichole M. S ley O'G~ I D #79866 , , \ 1719 North F~I-ont Street Harrisburg, PA 17102 717 234-4178 Attorney for Plaintiff n, Esquire ~~~ _ „ CERTIFICATE OF SERVICE I, Cathi Leigh McAdams, employee for the law firm of Purcell, Krug & Haller, counsel for Plaintiff, Christina R. Reisser, hereby certifies that service of the foregoing Addendum to Petition for Enforcement of Marital Settlement Agreement ,was made on the following via first-class, postage prepaid regular mail on November 7, 2007 to: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 ~~ Cathi Leigh McAdams e OCT 29200~i11 CHRISTINA R. REISSER, Plaintiff v. ERIK J. REISSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2007-4153 CIVIL ACTION -LAW IN DIVORCE AND CUSTODY COURT OR~r/DER r~/~llL~ tJ AND NOW, this s~ day of , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. Leal Custody: The parties will share joint legal custody of Adriana M. Reisser, (DOB 4-19-96), Aidan A. Reisser (DOB 11-03-00) and Adlai P. Reisser (DOB 7-25-OS). The parties agree that major decisions concerning their children, including, but not necessarily limited to, their health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in best interest of the children. Each party agrees not to impair the other party's rights to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning their children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. Mutual agreement should be made, in advance, regarding the following matters: enrollment or termination in a particular school or school program, advancing or holding a child back in school, authorizing enrollment in college, authorizing a child's driver's license or purchase of an automobile, authorizing employment, authorizing a child's marriage or enlistment in the armed forces, approving a petition for C~ -rid jr ~~~+,n' r~t` ~~~~~ €~ ~„ r~~ ~~;i/~ s7 ,, Z ~~ ~ ~ emancipation, authorizing foreign travel, passport application or exchange student status. Each parent shall execute any and all legal authorizations so that the other parent may obtain information from schools, physicians, psychologists, or other individuals concerning the progress and welfare of the children. 2. Physical custody of the children shall occur as follows: a. Weekday/Weekend Schedule: Father shall have the children: i. Every Tuesday evening from 6:00 p.m. until the following morning when he will deliver Adriana to school and the boys to Mother's home by 8:00 a.m.; ii. On the Thursday prior to Mother's weekend, from 6:00 p.m. until Friday morning when he will deliver Adriana to school and the boys to Mother's home by 8:00 a.m.; iii. On the Thursday prior to Father's weekend, one of the children (on a rotating basis) from 6:00 p.m. until Friday morning when he will deliver Adriana to school or the boys to Mother's home by 8:00 a.m. iv. Every other weekend from Friday at 6:00 p.m. until Sunday at 6:00 p.m. Mother will then pick up the child Father had on Thursday and Father will keep the two remaining children until Monday morning when he will deliver Adriana to school or the boys to Mother's home by 8:00 a.m. Mother shall have custody for the remainder of the week not designated as a period of custody for Father. b. Holidays: i. The parties will alternate the Memorial Day, Fourth of July and Labor Day holidays. The holiday will include the weekend and school break associated with the holiday and will start at 6:00 p.m. on the evening prior to the holiday period and end the morning 3 after the holiday period. Father will have the Memorial Day holiday in 2008, and the schedule will alternate thereafter. ii. Thanksgiving: The Thanksgiving holiday shall be divided into two segments: (1) Part A -from the conclusion of school on Wednesday until 3:00 p.m. on Thanksgiving Day. (2) Part B -from 3:00 p.m. on Thanksgiving Day until 6:00 p.m. on Friday. The parties have made other arrangements for the 2007 Thanksgiving holiday. In 2008 and all subsequent even numbered years, Father shall have Part A, with Mother having Part B. The schedule will reverse in odd numbered yeazs. iii. Christmas: The Christmas holiday shall be divided into two segments: (1) Part A -from 8:00 p.m. on Christmas Eve until 3:00 p.m. on Christmas Day. (2) Part B -from 3:00 p.m. on Christmas Day until 6:00 p.m. on December 26`x. The parties have made other arrangements for the 2007 Christmas holiday. In 2008 and all subsequent even numbered years, Father shall have Part A, with Mother having Part B. The schedule will reverse in odd numbered years. iv. Easter: The Easter holiday shall be divided into two segments: (1) Part A -from the conclusion of school on the last day prior to the holiday unti13:00 p.m. on Easter. (2) Part B -from 3:00 p.m. on Easter until the morning following the last day of the school break. In 2008 and all subsequent even numbered yeazs, Mother shall have Part A, with Father having Part B. The schedule will reverse 4 in odd numbered years. v. Mother will have custody of the children on Mother's Day and Father will have custody of the children on Father's Day. vi. The holiday schedule shall take precedence over the regulaz custody schedule. c. Vacation: Each parent shall be entitled to two non-consecutive weeks of uninterrupted vacation custody. There shall be no school yeaz vacations requiring a party to remove the children from school for more than one day in a thirty day period unless otherwise agreed by the parties. Vacation custody shall supersede the regulaz weekend/weekday schedule, but not the holiday schedule. 3. The parents shall organize ways for their children to maintain their friendships, extracurriculaz activities, and other special interests, regazdless of which household they may be in. Each parent must confer with the other pazent before arranging regulazly occurring extracurricular activities for a child which might interfere with regular visitation. 4. The parents shall permit and support access to all family relationships. Special family events such as weddings, family reunions, family gatherings, funerals, graduations, etc. shall be accommodated by both parties with routine visitations resuming immediately thereafter. Each pazent shall have the option of proposing time or date variations to the other parent when special recreational options or other unexpected opportunities arise. 5. Each pazent shall exercise care in screening babysitting/child caze providers. 6. Each parent shall be entitled to reasonable telephone and a-mail contact with the children when in the custody of the other pazent. 7. Neither parent shall permanently relocate if the relocation would necessitate a change in the visitation schedule, or if the relocation would result in a change of school for the children, or exceed a fifty (50) mile radius without a minimum notice of sixty (60) days to the other pazent. The sixty (60) day notice is designed to afford the parents an opportunity to renegotiate the custodial arrangements or to have the matter listed for a Court hearing. 8. Each pazent agrees not to attempt to alienate the affections of the children from 5 the other and will make a special conscious effort not to do so. Both parents shall refrain from making derogatory comments about the other pazent in the presence of the children and, to the extent possible, shall not permit third pazties from making such comments in the presence of the children. 9. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Cc: Bazbaza Sumple Sullivan, Esquire Nichole M. Staley O'Gorman, Esquire John J. Mangan, Esquire p ~f.S' /»~~~ 1 ~i~~ f a ? 6 CHRISTINA R. REISSER, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2007-4153 ERIK J. REISSER, Defendant :CIVIL ACTION -LAW IN DIVORCE AND CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Adriana M. Reisser, (DOB 4-19-96) Aidan A. Reisser (DOB 11-03-00) and Adlai P. Reisser (DOB 7-25-OS) 2. The parties agreed to the entry of an Order in the form as attached. Date: ~ ~~~ Jo angan, Esquire C tod Conciliator OCT 112DO~,p~ CHRISTINA R. REISSER, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2007-4153 ERIK J. REISSER, Defendant :CIVIL ACTION -LAW IN DIVORCE RULE TO SHOW CAUSE AND NOW, this ~ day of ~,~ ~,D~/ , 2007, upon consideration of the Defendant's Petition for Enforcement of Marital Settlement Agreement filed herein, A RULE IS HEREBY ISSUE upon Plaintiff, Christina R. Reisser, to show cause, if any she has, why the relief requested should not be granted. RULE RETURNABLE at a hearing to be held at /.~ 3D o'clock~J. m. on the /~v~ day of , 20 in Courtroom ~, Cumberland County Courthouse, One C rthouse quare, Carlisle, Pennsylvania. BY THE COURT: Distribution: For the Defendant: Nichole M. Staley O'Gorman, Esquire Purcell, Krug and Haller 1719 North Front Street Harrisburg, PA 17102 717 234-4178 For the Plaintiff: Barbara Sumple Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 717 774-1445 ~a~ ~'~ m ~~ L~c~ ~~ ~~o~ ~' I ~~~~~ S £ ~~ Wd ~- AQH 10€ ~~~~~~d Nichole M. Staley O'Gorman, Esquire ID #79866 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717 234-4178 nstaley~pkh.com CHRISTINA R. REISSER, Plaintiff v. ERIK J. REISSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2007-4153 CIVIL ACTION -LAW IN DIVORCE MOTION FOR CONTINUANCE AND NOW, comes the Defendant, Erik J. Reisser, by his attorneys, Purcell, Krug & Haller, and files the following Motion for Continuance: 1. Movant is Erik J. Reisser, Defendant in the above captioned action. 2. Respondent is Christina R. Reisser, Plaintiff in the above captioned action. 3. On or about October 10, 2007, Movant filed a Petition for Enforcement of Marital Settlement Agreement. 4. A hearing has been scheduled to occur before The Honorable Judge Hess on January 16, 2008 at 1:30 p.m.. 5. The undersigned counsel for Movant is scheduled to appear in the Perry County Court of Common Pleas for a full day custody trial on the same date. 6. Counsel for Respondent has been consulted and does not object to a continuance. 7. The Honorable Judge Hess has been assigned to this case. WHEREFORE, Movant respectfully requests this Honorable Court to continue the hearing in this matter to the next available date. PURCELL, KRUG & HALLER ole M. Staley :O' rman, Esquire ID #79866 1719 North Front Street Harrisburg, PA 17102 71 7 234-41 78 Attorney for Plaintiff Date: ~ I - ~ (/( ~ (~ 2 CERTIFICATE OF SERVICE I, Cathi Leigh McAdams, employee for the law firm of Purcell, Krug & Haller, counsel for Defendant, Erik J. Reisser, hereby certify that service of the foregoing Motion for Continuance ,was made on the following via first-class, postage prepaid regular mail on November 21, 2007 to: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 I // ~lle ` Cathi Leig cAda s C ~v v ° O ~ ~ ~ t ~'T`ffir ~ ~ .. j ~ ~ ~~ t +_^~},~ ~' - ~~ ,f ~ ~ ti ~ y ~--~ C::7 :~7 ~ '"'~~ ~e,~,,,,~ V) NOV $Y 1DD1,Nf~ CHRISTINA R. REISSER, Plaintiff v. ERIK J. REISSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2007-4153 CIVIL ACTION -LAW IN DIVORCE ORDER AND NOW, this o77~ day of , 2007, upon consideration of Defendant's Motion for Continuance, it is hereby ordered that the hearing scheduled for January 16, 2008 at 1:30 p.m. on Defendant's Petition for Enforcement of Marital Settlement Agreement shall be continued to the ,~ ~~ day of ~-~ , 2008 at l ; 3 ~ o'clock ~.m. in Courtroom 4, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. BY THE COURT: Distributi n: hole M. Staley O'Gorman, Esqui 1719 North Front Street Harrisburg, PA 17102 ~arbara Sumple Sullivan, Esquire .J 549 Bridge Street New Cumberland, PA 17070 J. f~~.~ ~J~~ ~` , ~ ` ' "~"' ~GTY..LC.t`~; r N, -~ ~ , _ ~~ ,~~~.~ .~t~ ~?~.,~._ .r, ;tom CHRISTINA R. REISSER, Plaintiff vs. ERIK J. REISSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.07-4153 CIVIL IN RE: DEFENDANT'S PETITION TO ENFORCE MARITAL SETTLEMENT AGREEMENT ORDER AND NOW, this Zo- day of February, 2008, it appearing that the parties have reached an agreement, the hearing on the defendant's petition to enforce marital settlement agreement is continued generally in order to allow time to complete a formal settlement agreement. BY THE COURT, Barbara Sum le-Sullivan Es uire p ~ q For the Plaintiff Nichole M. Staley O'Gorman, Esquire For the Defendant :rlm C'~P,~ ma, f~L a/a%s x ~" i ~.f ~5, ~ - '~y~J Barbara Sumpue-Sullivan, Esquire Supreme Cour~ #32317 549 Bridge Street New Cumberlapd, PA 17070 X717)774-144$ CHRISTINA R. REISSER, Plaintiff, v. ERIK J. REI~SER, ,Defendant, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-4153 CNIL ACTION-LAW DNORCE AFFIDAVIT OF CONSENT 1. ' A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 1512006. 2. 'The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed ~ince the filing and service of the Complaint. 3. '~ I consent to the entry of a final decree of divorce after service of notice of intention to rekluest entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees o~ expenses if I do not claim them before a divorce is granted. 5. ';I verify that the statements made in this affidavit are true and correct. I understand tha~ false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to uns~vorn falsification to authorities. DATE: I aZ , 2008 ~hA~(1~1/YLA. ~ ~--e~~I/ CHRISTINA R. REISSER o ~ c:a '~ ~ rx~ ~ ~ ~:. ..;c ~, p, ~7F ~~, ,~ ~ o "".~ Barbara Sump e-Sullivan, Esquire Supreme Co #32317 549 Bridge Street New Cumberlajnd, PA 17070 (717)774-144 CHRISTINA R. REISSER, Plaintiff, v. ERIK J. REIISSER, Defendant, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-4153 CNIL ACTION-LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301{c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees pr expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statement herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. n DATE: ~ 02 , 2008 l.~ ~UlA.4~"1/~'~v ~- ~--Q L~~ CHRISTINA R. REISSER r-~ c ~ ~ ~ ~'c -o~` z~Q 'r ~ ~tJ ~µ~ ~~. ~~ ~ -:; L~ ~ ~s~ Nichols M. Staley O'Gorman, Esquire ID #79866 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717 234-4178 nsta{eyCa~pkh.com CHRISTINA R. REISSER, Plaintiff v. ERIK,!. REISSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2007-4153 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit 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: ~ %~ g ~ Erik Reisser, Defendant ~ ~ ~~ r+ ..t e U~ ~' ~_ ;~, .-c- ~ -~; ~. ~ *~~ ~ ~ ..- .a Nichole M. Staley O'Gorman, Esquire ID #79866 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717 234-4178 nstaley~pkh.com CHRISTINA R. REISSER, Plaintiff v. ERIK J. REISSER, Defendant IN THE COURT OF COMA CUMBERLAND COUNTY, NO. 2007-4153 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under Code. 2. Date and manner of service of the Complaint: Comp certified mail on 12/22/06. 3. Complete either paragraphs (a) or (b). SON PLEAS PENNSYLVANIA e Court for entry of the Divorce was served by (a) Date of execution of the Affidavit of Consent requ red by §3301(c) of the Divorce Code: By Plaintiff: 5/2/08 and By D fendant: 9/27/07. -t (b) (1) Date. of execution of the Affidavit required by Divorce Code: ; (2) Date of filing and service of the Plaintiff's Affi Respondent: 4. Related claims pending: None. 5. Complete either (a) or (b). (a) Date and manner of service of the notice of inter Praecipe to Transmit Record, a copy of which is (b) Date Plaintiff s Waiver of Notice in §3301(c) Divoi the Prothonotary: 5/6/08: Date Defendant's Waiver of Notice in §3301(c) Divorce Prothonotary: 5/6/08. Respectfully submitted, PU~tCELL, KRUC~ HALLE DATE: r^, ~ _~~ ivicnoie . siaiey I D #789 6 1719 N h Front Stre Harrisburg, PA 17102 (717) 234-4178 Attorney for Defendan 1(d) of the upon the to file a was filed with s filed with the n, Esquire CERTIFICATE OF SERVICE I, Kimberly S. DeFalco, Legal Assistant to Nichole M. Staley O'Gorman, hereby certify that a true and correct copy of the foregoing document was se Plaintiff, by sending a copy of the same via first class U.S. Mail to: Barbara Sumple Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Kimberly S. DeP~CI o, Legal Assista t to Nichole M. Staley O'Gorman, Esqu re PURCELL, KRUG & HALLER i I.D. No. 78966 upon the DATE: 5 ~ ~ l d~ ~ "`~ ~ ~ c ~ ~ ~ =~ ~ t- I* : -~c " r= ~= = ~ ~ ~ ~L' ~ ~~ ~ O ~ i\.i ^~C I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF " ~ PENNA. CHRISTINA R. REISSER ~~,:, Plaintiff VERSUS ERIK J. REISSER Defendant N O. 2007-4153 DECREE IN DIVORCE AND NOW, ~'? 2OOH IT IS ORDERED AND DECREED THAT CHRISTINA R. REISSER PLAINTIFF, AND ERIK .7 REISSER DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; BY THE COURT: ATTES _ ~ J. PROTHONOTARY ~~ CHRISTINA R. REISSER, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :DOMESTIC RELATIONS SECTION ERIK J. REISSER, :PACSES NO. 820108860 Defendant :DOCKET NO. 683 SUPPORT 2007 CHRISTINA R. REISSER, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner :CUMBERLAND COUNTY, PENNSYLVANIA V. DOMESTIC RELATIONS SECTION ERIK J. REISSER, :PACSES NO. 851109526 Defendant/Respondent: :DOCKET NO. 07-4153 CIVIL ORDER OF COURT AND NOW, this 20th day of May, 2008, this matter having been scheduled for a hearing de novo before the Support Master on the Plaintiff's complaint for support and petition for alimony pendente lite, and the parties having reached an agreement on all outstanding issues, upon recommendation of the Master it is ordered and decreed as follows: 1. In the case docketed to 683 Support 2007 the interim order of October 4, 2007 is affirmed as a final order. 2. All arrearages owing on said case effective February 29, 2008 are remitted. 3. The Defendant's obligation to pay spousal support is suspended effective February 29, 2008. 4. Effective March 1, 2008 the Defendant shall pay to the Pennsylvania State Collection and Disbursement Unit as support for his children, Adriana M. Riedel, born April 19, 1996, Aidan A. Reisser, born November 3, 2000, and Adali P. Reisser, born July 25, 2005, the sum of $2,525.00 per month. 5. The provisions for health insurance coverage and payment of unreimbursed medical expenses incurred for said children as set forth in the order of October 4, 2007 shall remain in full force and effect. 6. The Plaintiff's claim for alimony pendente lite in the case docketed to 07-4153 Civil is withdrawn. Cc: Christina R. Reisser Erik J. Reisser By t Court, `9~.~ /'~ Kevin A. Hess, J. Barbara Sumple-Sullivan, Esquire For the Plaintiff Nichole M. Staley O'Gorman, Esquire For the Defendant DRO t ACT 13 2008 Nichole M. Staley O'Gorman, Esquire ID #79866 Purcell, Krug 8~ Haller 1719 North Front Street Harrisburg, PA 17102 717 234-4178 nstalevCc~akh.cam CHRISTINA R. REISSER, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND GOUNTY, PENNSYLVANIA v. : NO. 2007-4153 ERIK J. REISSER, : Defendant C1VlL ACTION -LAW IN DIVORCE ORDER AND NOW, this <G `day of Q1a 6-a- , 2048, the parties having stipulated to the terms set forth below, it is so ordered as fiollows: 1. Effect on Participant's individual Retirement Account (iRA): This QDRO applies to the SRA that Erik J. Reiser, the Participant, owns through 1717 Capital Management. Pursuant to the #erms of the Decree of Divorce, Christina A. Reiser, now known as Christina R. Verrecch'so, the Altemate Payee, is entitled to a portion of Erik J. Reisser's IRA account balance as set forth in Section 6 below. The Participant shall take ail steps necessary in order to effectuate the transfer of the called- for portion to Alternate Payee and snail nofi take any actions, affirmative or otherwise, that wil! circumvent the Alternate Payee's Interest in the iRA as set forth herein. 2, Participant Information: The name, last known address, Social Security number, and date of birth of the Participan# are: Erik J. Reisser 504 Jacob Lane Mechanicsburg, PA 17050 SSN: 207-52-0283 DOB: May 5, 1971 S. Former Spouse Information: The name, last known address, Social Security number, and date of birth ofi the Alternate Payee are: Christina R. Verrecchio (formerly known as Christina R. Reisser) 2 Old Coach Lane Carlisle, PA 17013 SSN: 209-60-7904 DOB: March 1, 1973 The Alternate Payee shall have the duty to notify the Pian Administrator in writing of any changes in her mailing address subsequent to entry of this Order. 4. Name of IRA.: The name of the IRA to which this Order applies is 1717 Capital Management IRA, formerly known as New England Securities IRA, held in the name of the Participant, Account No. 783-566672 (her®inafter referred to as IRA}. 5. For Provision of Marital Property Rights: This Order relates to the provision of marital property rights for the Alternate Payee as a result of the Order of Divorce between Participant and Alternate Payee. 6. Amount of Alternate Payee's Benefit: This Order assigns to Altemate Payee an amount equal to one hundred percent (100%) of the Participant's total account balance under the IRA, effective as of the date this Order is approved by the Plan (or the coses# possible valuation date thereto), plus any interest and investment earnings or losses attributable thereon for periods subsequent to that date until the date 2 of total distribution. The 1RA Administrator is hereby directed to transfer one hundred (1 QO%} percent of the total account balance to Altemate Payee's account number 783- 585647 as soon as administratively feasible fot[owing the date this Order is approved as a QDRO by the Plan Administrator. 7. Restriction on Subsequent Withdrawais: Until such time as the Alternate payee receives her distribution, the Participant shah not be permitted to receive any withdrawals and/or distributions under his IRA. 8. Death of Alternate Payee: In the event of Alternate Payee's death prior to the transfer of such funds, such Alternate Payee's beneficiary(ies), as designated on the appropriate form provided by the iRA Administrator (or in the absence of a beneficiary designation, her estate), shall receive her share of the account balance as set forth under the terms of this Order. 9. Death of Participant In the event that the Participant dies prior to the transfer of the funds in accordance with the terms of this Order, the Alternate Payee shall be treated as the Participant's beneficiary to the extent of her assigned interest as set forth herein. Should the Participate predecease the Alternate Payee after the transfer of the funds is made to the Alternate Payee, his death shalt not affect fine Alternate Payee's rights and entitlements as set forth herein. 10. Inadvertent Payments} to Pian Participant: In the event that the Plan Trustee inadvertently pays to the Participant any benefits that are assigned to the Alternate Payee pursuant to the terms of this Order, the Participant snail immediately return such payments to the Plan Administrator. ~, '. 11. Gon#inued Jurisdiction. The Court shall r®tain jurisdiction with respect to this Order to the extent required to maintain its qualified status by the 1RA fund administrator and the original intent of the parties and the Court as stipulated herein. 12. Actions by Participant: The Participant shall not take any actions, affirmative or otherwise, tha# could circumvent the terms and provisions of this Order, or that could diminish or extinguish the rights and entitlements of the Alternate Payee as set forth herein. Should the Participant take any action or inaction to the detriment of the Alternate Payee, he shall be required to make sufficient payments direcflyto the Alternate Payee, to the extent necessary to neutralize the effects of his actions or inactions and to the extent of her full entitlements hereunder. Barbar~5umple Sullivan, Esquire Nichole 1Wf. Staley O'Gorman, Esquire ~~ _ _ 1 /~ ~ ~ ~ I ristina R. Verrecchfo formerly know as Christina R. Reisser Erik J. Reisser 8Y THE COURT: ~ -~' ~"'' •' ~ ~`. r-- i ~~, ~ :;. ~`~- sac ~ ;--= '~ +~; _. ~~ ,,D > . G. .-,. c~- © 'MY' c-~ ry i r^ Barbara Sumple-Sullivan,Esquire �!; ! k 't{CJ 6 , r; Supreme Court#32317 549 Bridge Street L �' ; — ; New Cumberland,PA 17070 (717)774-1445 CUMBER!AND cotjwy NNSYLVANIA CHRISTINA R. REISSER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION- CUSTODY ERIK J. REISSER, Defendant NO. 2007-4153 PETITION FOR CONTEMPT OF A CUSTODY ORDER AND NOW this 6th Day of February, 2014, comes Barbara Sumple-Sullivan, Esquire, on behalf of Plaintiff, and files this Petition for Contempt. 1. Petitioner is Plaintiff, Christina R. Verrechio (formerly Reisser), an individual residing at 403 West Main Street, Mechanicsburg, Cumberland County, Pennsylvania (hereinafter referred to as "Mother"). 2. Respondent is Defendant, Erik J. Reisser, an individual residing at 659 William Way Mechanicsburg, PA 17055 (hereinafter referred to as"Father"). , 3. Petitioner and Respondent are the natural parents of three minor children. NAME PRESENT RESIDENCE DATE OF BIRTH Adriana M. Reisser 403 W. Main Street, Mechanicsburg, PA 04/19/1996 Aidan A. Reisser 403 W. Main Street, Mechanicsburg, PA 11/03/2000 Adlai P Reisser 403 W. Main Street, Mechanicsburg, PA 07/2/2005 S3, no P� 1 e60,0Z9 � 3a136� 4. A Court Order regarding custody of these children was entered on November 5, 2007, a copy of which is attached as Exhibit A. 5. The Order grants Mother primary physical custody of the children. Father has partial physical custody. 6. The Order specifically states that on Father's overnights, with the exceptions of weekends, his custody ends at 8:00 a.m. the day following the overnight and the children are either to attend school, or be returned to Mother. 7. By mutual agreement, the parties have been following a modified schedule which was confirmed in a letter from Counsel for Mother to Counsel to Father on January 17, 2014, a copy of which is attached as Exhibit B. 8. Under the modified schedule,the days on which Father has custody were changed by mutual consent. 9. The parties did not agree to change the time of day during which Father can exercise custody. Therefore under the modified schedule, as under the Order, on Father's overnights he has custody from 5:00 p.m. the day of the overnight until school begins the following morning, or when school is not in session, 8:00 a.m. the following morning. 10. Under both the Order and the modified schedule, Father does not retain custody of the children during the day, when school is not in session. 11. Over the last month Father has consistently and willfully failed to return the children to Mother during the day when they do not have school, despite Mother's request that he do so pursuant to the Order and the modified schedule confirmed by her Counsel. 12. Mother has consistently reminded Father that she does not agree with this modification of the Order. 2 13. The most recent incident occurred on February 5, 2014, after Aidan and Adlai spent the night of Tuesday February 4, 2014 at Father's. 14. Father refused to return Aidan and Adlai to Mother during the day on February 5, 2014, although Aidan and Adlai did not have school due to a winter storm. 15. Mother offered to provide all transportation for the children in order to ensure that they were returned to Father's house for the beginning of his next custodial period. 16. Father refused Mother's offer of transportation and insisted that he did not need to return the children pursuant to the Order. 17. Father alleged that he wished to spend time with the children during the day on February 5, 2014. Father worked during the day on February 5, 2014. 18. The Order requires both parents refrain from making derogatory comments about the other parent in the presence of the children. 19. In speaking about Mother, Father has repeatedly failed to abide by the provision of the Order requiring that he not make derogatory comments about Mother in the presence of the children. The prior Judge in this matter was the Honorable Judge Hess. WHEREFORE,Petitioner requests that this Honorable Court 1. Hold Father in contempt of the Order dated November 5, 2007 due to his refusal to return the children to Mother when they do not have school. 2. Grant Mother make-up time for the periods of custody which she was denied by Father. 3 3. Provide any other remedy the Court deems equitable Res,ec�l ed, DATE: February 6, 2014 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Petitioner 4 OCT 2 9 20OU? CHRISTINA R.REISSER : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. ; No. 2007-4153 ERIK J.REISSER, Defendant CIVIL ACTION-LAW : IN DIVORCE AND CUSTODY COURT ORDER AND NOW,this S' day of - ,2007,upon consideration of the attached Custody Conciliation Report,it is ordered and directed that: 1. Legal Custody: The parties will share joint legal custody of Adriana M.Reisser, (DOB 4-19-96),Aidan A.Reisser(DOB 11-03-00)and Adlai P.Reisser(DOB 7-25-05). The parties agree that major decisions concerning their children,including,but not necessarily limited to,their health,welfare,education,religious training and upbringing shall be made by them jointly,after discussion and consultation with each other,with a view toward obtaining and following a harmonious policy in best interest of the children. Each party agrees not to impair the other party's rights to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning their children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made,the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However,that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309,each party shall be entitled to complete and full information from any doctor,dentist, teacher,professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. Mutual agreement should be made,in advance, regarding the following matters; enrollment or termination in a particular school or school program,advancing or holding a child back in school,authorizing enrollment in college, authorizing a child's driver's license or purchase of an automobile,authorizing employment, authorizing a child's marriage or enlistment in the armed forces,approving a petition for EXHIBIT a A emancipation,authorizing foreign travel,passport application or exchange student status. Each parent shall execute any and all legal authorizations so that the other parent may obtain information from schools,physicians,psychologists,or other individuals concerning the progress and welfare of the children. 2. Physical custody of the children shall occur as follows: a. WeekdU Weekend Schedule: Father shall have the children: i, Every Tuesday evening from 6:00 p.m.until the following morning when he will deliver Adriana to school and the boys to Mother's home by 8:00 a.m.; I On the Thursday prior to Mother's weekend,from 6:00 p.m,until Friday morning when he will deliver Adriana to school and the boys to Mother's home by 8:00 a.m.; iii, On the Thursday prior to Father's weekend,one of the children(on a rotating basis)from 6:00 p.m.until Friday morning when he will deliver Adriana to school or the boys to Mother's home by 8:00 a.m. iv. Every other weekend from Friday at 6:00 p.m.until Sunday at 6:00 p.m. Mother will then pick up the child Father had on Thursday and Father will keep the two remaining children until Monday morning when he will deliver Adriana to school or the boys to Mother's home by 8:00 a.m, Mother shall have custody for the remainder of the week not designated as a period of custody for Father. b. Holidays: i. The parties will alternate the Memorial Day,Fourth of July and Labor Day holidays. The holiday will include the weekend and school break associated with the holiday and will start at 6:00 p.m. on the evening prior to the holiday period and end the morning 3 after the holiday period. Father will have the Memorial Day holiday in 2008,and the schedule will alternate thereafter. ii. Thanksgiving: The Thanksgiving holiday shall be divided into two segments: (1) Part A-from the conclusion of school on Wednesday until 3:00 p.m.on Thanksgiving Day. - (2) Part B-from 3:00 p.m.on Thanksgiving Day until 6:00 p.m.on Friday. The parties have made other arrangements for the 2007 Thanksgiving holiday, In 2008 and all subsequent even numbered years,Father shall have Part A,with Mother having Part B. The schedule will reverse in odd numbered years. iii. Christmas: The Christmas holiday shall be divided into two segments: (1) Part A-from 8:00 p.m.on Christmas Eve until 3:00 p.m. on Christmas Day. (2) Part B-from 3:00 p.m.on Christmas Day until 6:00 p.m. on December 26`h. The parties have made other arrangements for the 2007 Christmas holiday. In 2008 and all subsequent even numbered years,Father shall have Part A,with Mother having Part B. The schedule will reverse in odd numbered years. iv. Easter:The Easter holiday shall be divided into two segments: (1) Part A-from the conclusion of school on the last day prior to the holiday until 3:00 p.m,on Easter, (2) Part B-from 3:00 p.m.on Easter until the morning following the last day of the school break. In 2008 and all subsequent even numbered years,Mother shall have Part A,with Father having Part B. The schedule will reverse 4 in odd numbered years. V. Mother will have custody of the children on Mother's Day and Father will have custody of the children on Father's Day. A. The holiday schedule shall take precedence over the regular custody schedule. C. Vacation: Each parent shall be entitled to two non-consecutive weeks of uninterrupted vacation custody. There shall be no school year vacations requiring a party to remove the children from school for more than one day in a thirty day period unless otherwise agreed by the parties. Vacation custody shall supercede the regular weekend/weekday schedule,but not the holiday schedule. 3. The parents shall organize ways for their children to maintain their friendships, extracurricular activities,and other special interests,regardless of which household they may be in. Each parent must confer with the other parent before arranging regularly occurring extracurricular activities for a child which might interfere with regular visitation. 4. The parents shall permit and support access to all family relationships. Special family events such as weddings,family reunions,family gatherings,funerals,graduations,etc. shall be accommodated by both parties with routine visitations resuming immediately thereafter. ' Each parent shall have the option of proposing time or date variations to the other parent when special recreational options or other unexpected opportunities arise. 5. Each parent shall exercise care in screening babysitting/child care providers. 6. leach parent shall be entitled to reasonable telephone and e-mail contact with the children when in the custody of the other parent. 7, Neither parent shall permanently relocate if the relocation would necessitate a change in the visitation schedule,or if the relocation would result in a change of school for the children,or exceed a fifty(50)mile radius without a minimum notice of sixty(60)days to the other parent. The sixty(60)day notice is designed to afford the parents an opportunity to renegotiate the custodial arrangements or to have the matter listed for a Court hearing, 8. Each parent agrees not to attempt to alienate the affections of the children from 5 the other and will make a special conscious effort not to do so. Both parents shall refrain from making derogatory comments about the other parent in the presence of the children and,to the extent possible,shall not permit third parties from making such comments in the presence of the children. 9. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY CWA,I J. Cc; Barbara Sumple Sullivan,Esquire Nichole M.Staley O'Gorman,Esquire 04,0F /YS i John J.Mangan,Esquire 1 6 CHRISTINA R.REISSER, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. : No. 20074153 ERIK J.REISSER, Defendant : CIVIL ACTION-LAW : IN DIVORCE AND CUSTODY CONCILIATION CONFERENCE SUhIMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B),the undersigned Custody Conciliator submits the following report: I. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Adriana M.Reisser,(DOB 4-19-96) Aldan A.Reisser(DOB 11-03-00)and Adlai P.Reisser(DOB 7-25-05) 2. The parties agreed to the entry of an Order in the form as attached. Date: Jo 4gan,Esquire Cubtodf Conciliator I i LAW OFT,ICES BARBARA SUMPLE-SULLIVAN 549 BRIDGE STREET NEW CUMBERLAND,PENNSYLVANIA 17070-1931 PHONE: (717)774-1445 FAX: (717)774-7059 January 17,2014 Quintina M. Laudermilch,Esquire Daley Zucker Meilton & Miner 635 N. 12th St., Suite 101 Lemoyne, PA 17043 Via Facsimile to (717) 724-9826 Re: Verrecchio/Reisser Dear Tina: Per my advice and your agreement,Adriana will not be going to Erik's this evening. It is my further understanding that Erik will not attempt in any way, including through verbal intimidation, to force Adriana to come to his house. As you know, Adriana is opposed to spending any overnights with Erik. As a 17 year old, Erik will only further harm his relationship with her. We also confirm that neither parent will discuss with the boys during his or her custody periods, or allow any third party to discuss with them, any issues related to the police investigations. Both parties will act to shield the children from involvement. In addition to the above,please also accept this letter as confirmation of the parties' mutually agreed upon custody modification. Erik's physical custody of the boys is every Tuesday and Wednesday night,from 5:00 p.m. until school begins the following morning or,when school is not in session, 8:00 a.m. the following morning. Erik also has every other weekend from Friday at 5:00 p.m. until Sunday at 5:00 p.m. On Christmas Eve, Erik has the children from 5:00 p.m. until the following morning at Noon. On December 26, the normal custody schedule resumes. Other than Christmas, the holiday schedule in the prior custody order, dated November 5,2007 applies, and takes precedence over normal custody schedules and vacations unless otherwise agreed by the parties. I would like to reiterate that it is inappropriate for Christine Gelnett to be contacting Jon Verrecchio about the parties' custody issues. In light of the other recent events, I believe it is inappropriate for there to be any contact between the parties or their significant others. I am sending both Erik and Christine Gelnett a no-trespass letter and I EXHIBIT s Quintma M.Laudermilch,P.squire January 17,2014 Page 2 of 2 have enclosed copies of those letters. During the custody exchange this evening, and during every custody exchange, Erik should remain in his vehicle in the public alley behind Christina's home (W. Locust St.). Christina will walk the children to the vehicle. Erik should arrive promptly at 5:00 p.m. so that there is no need for him to contact Christina,or approach her property. I suggest that except for emergency situations, the parties communicate one time per week, by text,solely as relates to a change in the above referenced schedule. Thank you for your cooperation. Sincerely "o rs,. i Barbara Sumple-Sullivan BSS/als Enclosures cc: Ms. Christina Verrecchio (via email) ) f , Barbara Sumple-Sullivan,Esquire Supreme Court#32317 549 Bridge Street New Cumberland,PA 17070 (717)774-1445 CHRISTINA R. REISSER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION- CUSTODY ERIK J. REISSER, Defendant NO. 2007-4153 VERIFICATION 1, Christina Verrechio, hereby certify that the facts set forth in the foregoing Petition for Special Relief are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Dated: IN Christina Verrechio Barbara Sumple-Sullivan,Esquire Supreme Court#32317 549 Bridge Street New Cumberland,PA 17070 (717)774-1445 CHRISTINA R. REISSER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION- CUSTODY ERIK J. REISSER, Defendant NO. 2007-4153 CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on this date, I served a true and correct copy of the Motion for Emergency Relief, in the above-captioned matter upon the following individual(s), by facsimile and regular mail: Quintina M. Laudermilch,Esquire Daley Zucker Meilton& Miner 635 N. 12th St., Suite 101 Lemoyne, PA 17043 DATE: 91�IV arbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Petitioner reo. I LV14 L:jZrivi NO. )JOO r. j Barbara Sumple-Sullivan,Esquire ) " j ; P R 0 T H 011 0 1 A R'Y Supreme Court#32317 549 Bridge Street 2014 FEB —7 PM 2: 37 New Cumberland,PA 17070 (717)774-1445 ^I JMRF I -AI• ] COUNTY PENNSYLVANIA CHRISTINA R.REISSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. CIVIL ACTION-CUSTODY ERIK J. REISSER, Defendant : N0. 2007-4153 CRIMINAL RECORD/ABUSE HISTORY VERIFICATION I, Christina R.Reisser n/k/a Christina R. Verrecchio, hereby swear or affirm, subject to penalties of law including 18 Pa.C.S. §4904 relating to unsworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act, 42 Pa.C.S. §6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges; Check all Crime Self Other Date of Sentence that apply household conviction member guilty plea, no contest plea or ep nding char es ❑ 18 Pa.C.S. Ch, 25 ❑ O (relating to criminal homicide) reo t. LU14 L Lrivi NO 7JUU r, 4 ❑ 18 Pa.C.S. §2702 ❑ Q (relating to aggravated assault) ❑ 18 Pa.C.S. §2706 ❑ ❑ (relating to terroristic threats) ❑ 18 Pa.C.S. §2709.1 ❑ ❑ (relating to stalking) ❑ 18 Pa.C.S. §2901 ❑ ❑ (relating to kidnapping) ❑ 18 Pa.C.S. §2902 ❑ ❑ (relating to unlawful restraint) O 18 Pa.C.S. §2903 ❑ ❑ (relating to false imprisonment) O 18 Pa.C.S. §2910 ❑ ❑ (relating to luring a child into a motor vehicle or structure) ❑ 18 Pa.C.S. §3121 ❑ ❑ (relating to rape) ❑ 18 P&C.S.§31221 ❑ ❑ (relating to statutory sexual assault) O 18 Pa.C.S. §3123 ❑ ❑ (relating to involuntary deviate sexual intercourse) ❑ 18 Pa,C.S. §3124.1 ❑ ❑ (relating to sexual assault) ❑ 18 Pa.C.S. §3125 ❑ ❑ (relating to aggravated indecent assault) reo l LU14 z: �z r ivi NO. )Job r. 7 O 18 Pa.C.S. §3126 ❑ O (relating to indecent assault) ❑ 18 Pa.C.S. §3127 ❑ ❑ (relating to indecent exposure) O 18 Pa.C.S. §3129 O Q (relating to sexual intercourse with animal) ❑ 18 Pa.C.S. §3130 ❑ ❑ (relating to conduct relating to sex offenders) Q 18 Pa.C.S. §3301 a ❑ (relating to arson and related offenses) ❑ 18 Pa.C.S. §4302 ❑ ❑ (relating to incest) ❑ 18 Pa.C.S. §4303 ❑ ❑ (relating to concealing death of child) ❑ 18 Pa.C.S, §4304 O ❑ (relating to endangering welfare of children) ❑ 18 Pa.C.S. §4305 ❑ O (relating to dealing in infant children) ❑ 18 Pa,C,S, §5902(b) ❑ ❑ (relating to prostitution and related offenses) D 18 Pa.C.S. §5903(c)or(d) O ❑ (relating to obscene and other sexual materials and performances) reb 1. LU14 2: j 2 rivi No. SJdd r, b O 18 Pa.C.S. §6301 ❑ Q (relating to corruption of minors) O 18 Pa.C.S. §6312 O ❑ (relating to sexual abuse of children) O 18 Pa.C.S. §6318 ❑ O (relating to unlawful contact with minor) ❑ 18 Pa.C.S. §6320 O O (relating to sexual exploitation of children) ❑ 23 Pa.C.S. § 6114 O ❑ (relating to contempt for violation of protection order or agreement) ❑ Driving under the influence of O ❑ drugs or alcohol O Manufacture, sale, ❑ ❑ delivery,holding, offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below,neither T nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other Date all that household analy member ❑ A finding of abuse by a Children&Youth ❑ ❑ Agency or similar agency in Pennsylvania or similar statute in another jurisdiction ❑ Abusive conduct as defined under the ❑ ❑ Protection from Abuse Act in reb. 1. 1U 14 1:jZrM No 53UU r. / PonosylVaoia or.similar statute In soother jurlsdiclloq Q Other. . O ❑ 3.. Please list aqy eV0luat1op,counseling or other treatment received following conviction or flading of abuse; ' I 4: If-any conviction ahovo applies to a household member,pot a patty slale that ' Person's game,date of birth and relallorttthip to the child. I 5, If.you are aware that.(he other party or members of.1110 other party's household has , or have a cf1 minalMuge history,please explain; Y verity that she lototmeliorl above.is true.at,d aorrecl to the best of my knowledge., inforrae11ot1 or:bellef, I upderstand that(also statemcals hetelo are rode subject to the penalties of.lS:Pa,C.SA4904 relating to unsworn falsification to nufhorhles, (40 s►gnat�re Frilled Name CHRISTINA R. REISSER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-4153 CIVIL ACTION LAW ERIK J. REISSER IN CUSTODY DEFENDANT •• ORDER OF COURT AND NOW, Monday, February 10,2014 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan,Jr., Esq. , the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Friday, March 14,2014 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. 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court (including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT, By: Is/ John J. Mangan,Jr., Esq, ,t Conciliator 1;, J 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. t4 Ir:‘,L Cumberland County Bar Association 1 S � 32 South Bedford Street �° .z- rn CO --n Carlisle, Pennsylvania 17013 rn hn �i . t� ter-- r. P4y �� � ���1 ,� �� Telephone (717) 249-3166 �� ,�., �,;��- LCD 1a �G�.(J -c 1I '1 94-1-..( J.in 3 `�' = = , 0..//vAy —, no . __./19 Quintina M. Laudermilch,Esquire et •DALEY ZUCKER A° �. a L.i MEILTON& MINER, LLC ic�; t: ��. 635 North 12th Street, Suite 101 ,1 �,c� • Z. Lemoyne,PA 17043 , t ait `' �; T t (717)724-9821 r t S t'^ 6,1 taudermilch@,dzmmlaw.com CHRISTINA R. REISSER, : IN THE COURT OF COMMON PLEAS OF n/k/a CHRISTINA R. VERRECCHIO : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : No. 2007-4153 v. : CIVIL ACTION - LAW ERIK J. REISSER, : (In Custody) Defendant ANSWER TO PLAINTIFF'S PETITION FOR CONTEMPT OF CUSTODY ORDER AND COUNTERCLAIM FOR CONTEMPT, COUNSEL FEES, AND MODIFICATION 1. Admitted. 2. Admitted. 3. Admitted. By way of further answer, Father has periods of substantial physical custody during which time the children reside at 659 William Way, Mechanicsburg, Cumberland County, Pennsylvania 17055. 4. Admitted. 5. Admitted. By way of further answer, Father exercises periods of substantial physical custody of the children. 6. Admitted in part, denies in part. It is admitted that the order states that Father's mid-week overnights end at 8:00 a.m. when Father either returns the children to school or to Mother's care. By way of further answer, the custody order was entered six (6) years ago when Mother was providing child care for the youngest children because they were not yet in school. Further, for several years, the parties have not followed the schedule as outlined in the order, and u the children would not be returned to Mother when they did not have school, specifically during the summer. 7. Admitted in part, denied in part. It is admitted that by mutual agreement the parties have been following a modified schedule and that Counsel for Mother forwarded a letter to Counsel for Father dated January 17, 2014. It is denied that the January 17, 2014 accurately reflects the parties modified arrangement. By way of further answer, by agreement of the parties, the children routinely would not be returned to Mother on Wednesday or Thursday mornings when they did not have school, specifically during the summer, and would remain in Father's physical custody from Tuesday through Thursday. 8. Admitted. 9. Denied. As previously answered, by agreement of the parties, the children routinely would not be returned to Mother on Wednesday or Thursday mornings when they did not have school, specifically during the summer, and would remain in Father's physical custody from Tuesday through Thursday. 10. Admitted in part, denied in part. It is admitted that pursuant to the Order, the children are returned to school or Mother the morning following Father's mid-week overnight. It is denied that the modified schedule also required the children to be returned to Mother the mornings following Father's mid-week overnights when the children did not have school. By mutual agreement of the parties, the children routinely would not be returned to Mother on Wednesday or Thursday mornings when they did not have school, specifically during the summer, and would remain in Father's physical custody from Tuesday through Thursday. 11. Admitted in part, denied in part. It is admitted that on two occasions over the last month the children have remained with Father from Tuesday through Thursday, despite Mother's request that the children return to her home on Wednesday morning. It is denied that Father consistently and willfully failed to return the children to Mother during the day when they did not have school. On the two occasions the children did not have school due to severe winter weather and Father did not feel it was safe to drive the children to Mother's for them to simply return to him a few hours later. Father advised Mother of his concerns because for the weather; however, Mother instead wanted to risk the safety of the children and insist that Father return the children. 12. Denied. Father is without information sufficient to form a belief as to the truth of the matter asserted and strict proof thereof is demanded at the time of trial. 13. Admitted. 14. Admitted. By way of further answer, as previously answered, there was a severe ice storm the morning of February 5, 2014 and the children did not have school. Mother requested that she pick up the children between 11:00 a.m.-12:00 p.m.; however, Father did not feel it was safe to travel with the children to take them to Mother's when the children would be returning to his home 6-7 hours later. Father advised Mother of his concerns for the weather; however, Mother instead wanted to risk the safety of the children and insist that Father return the children. 15. Denied. Father is without information sufficient to form a belief as to the truth of the matter asserted and proof thereof is demanded at the time of trial. 16. Admitted in part, denied in part. Father admits that the children did not go back to Mother's home on February 5, 2014. By way of further answer, as previously answered, there was a severe ice storm the morning of February 5, 2014 and the children did not have school. Mother requested that she pick up the children between 11:00 a.m.-12:00 p.m.; however, Father did not feel it was safe to travel with the children to take them to Mother's when the children would be returning to his home 6-7 hours later. Father advised Mother of his concerns for the weather; however, Mother instead wanted to risk the safety of the children and insist that Father return the children. Further, pursuant to the parties' agreement, Father was supposed to have physical custody of the children Wednesday, February 12, 2014 overnight until Thursday, February 13, 2014; however, due to the severe winter weather, the children remained with Mother overnight because Father did not want to risk anyone's safety traveling during the severe storm. To the extent Mother is requesting make-up time for the other two snow days where the children remained with Father, the make-up time has already been provided when the children remained with Mother overnight February 12-13, 2014, which was otherwise Father's custodial period. In the alternative, Father is requesting make-up time for the overnight period the children remained with Mother. 17. Denied. Mother requested that she pick up the children between 11:00 a.m. — 12:00 p.m; however, Father advised Mother that he was concerned as a result of the hazardous driving conditions and that it did not make sense to risk traveling when the children did not have school, Father was home most of the day and the children would be returning to his home 6-7 hours later. However, Mother instead wanted to risk the safety of the children and insist that Father return the children. 18. Admitted. 19. Denied. Father is without information sufficient to form a belief as to the truth of the matter asserted and proof thereof is demanded at the time of trial. WHEREFORE, Defendant respectfully requests this Honorable Court deny Plaintiff's Petition for Contempt. COUNTERCLAIM FOR CONTEMPT 20. Paragraphs 1-19 are incorporated herein by reference. 21. The parties' November 5, 2007 Custody Order pertains to the parties' three (3) minor children; however, Father has not exercised physical custody of the parties' oldest daughter, Adriana, in almost two years. 22. Although Father has not wanted to cause more problems by pushing Adriana to visit, Father believes and therefore avers that Mother fails to encourage or foster Father's relationship with Adriana by supporting and encouraging Adriana's decision not to visit with Father. 23. Father repeatedly tried to maintain a relationship with Adriana, but Mother does encourage the relationship and has advised Father not to contact Adriana about visiting. 24. After Father advised Mother that he wanted to make sure Adriana was included in the visits, Mother advised Father, though a letter from her counsel dated January 17, 2014, that Adriana is opposed to visiting and will not be visiting Father. 25. Mother has failed to abide by the terms of the order when by not having Adriana spend time with her Father during his custodial periods. 26. The paragraph 1 of the parties' Custody Order states that the parties share legal custody of the children. Specifically, all major decision concerning their children, including educational decisions, are to be made by the parties jointly. 27. Mother made the unilateral decision that Adriana would attend at Dickinson College following her high school graduation. Father was not involved in any discussions about what school she would attend and he was not involved in the decision making process. 28. Mother routinely attempts to interfere in Father's custodial periods and uses the children to communicate with Father by making plans during Father's weekends and then using the children to ask Father whether they can participate in Mother's plan, thereby putting the children in the middle and putting Father in a position of having to discuss the matter with the children. 29. Pursuant to the parties' agreement, Father was supposed to have physical custody of the children Wednesday, February 12, 2014 overnight until Thursday, February 13, 2014; however, due to the severe winter weather, the children remained with Mother overnight because Father did not want to risk anyone's safety traveling during the severe storm. To the extent Mother is requesting make-up time for the other two snow days where the children remained with Father, Father believes the make-up time has already been provided when the children remained with Mother overnight February 12-13, 2014. In the alternative, Father is requesting make-up time for the overnight period he missed as well. COUNTERCLAIM FOR COUNSEL FEES 30. Paragraphs 1-29 are incorporated herein by reference. 31. Father has incurred legal fees in responding to Mother's petition and requesting make up time for a total period of 20 hours. 32. Father has incurred additional legal fees as a result of Mother's failure to comply with the parties' November 5, 2007 custody Order. 33. Father has incurred legal fees and expenses of approximately $1,200 to date and will continue to incur fees if the matter cannot be resolved. COUNTERCLAIM FOR MODIFICATION 34. Paragraphs 1-32 are incorporated herein by reference. • 35. Since the entry of the November 5, 2007 Custody Order, the circumstances of the parties and the children have changed such that Father believes and therefore avers it is necessary to modify the terms of the existing schedule to reflect the current circumstances and ages of the children. 36. In addition, Father is getting married and, in lieu of a honeymoon, Father and his fiancée would like to their all of the children to Disney World over the Thanksgiving holiday. This time period was selected after taking into consideration the parties' custodial schedule and Father's fiancée's custodial schedule with her children. Further, the week during the Thanksgiving Holiday minimizes the time the children will miss school. 37. Father is requesting that the parties switch the Thanksgiving and Christmas Holiday periods for 2014 so that Father can enjoy this vacation with the children. WHEREFORE, Defendant respectfully requests this Honorable Court to grant Defendant's Counterclaim for Contempt, Counsel Fees and Modification and enter an Order consistent with the best interest of the children. Respectfully submitted, DALEY ZUCKER MEILTON & MINER, LLC Date: aht-i iti By: J i , I/ • • . 'tina M. Laudermilch, Esquire Attorney ID # 94664 635 N. 12th Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 Attorneys for Defendant VERIFICATION I, Erik J. Reisser, verify that the statements made in this pleading 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. -311■ 411 4 7 Date Erik J. Reisser CERTIFICATE OF SERVICE I, Ashley A. Nelms, Paralegal, hereby certify that on this I I �A- day of February, 2014, a true and correct copy of the foregoing Answer and Counterclaim was served on Plaintiff by mailing same addressed as follows: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Ash ey A. Nel 1:, Paralegal • CHRISTINA R. REISSER, : IN THE COURT OF COMMON PLEAS OF n/k/a CHRISTINA R. VERRECCHIO : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff :No. 2007-4153 v. _- : CIVIL ACTION-LAW ERIK J. REISSER, : (In Custody) r-' Y) r cr)Defendant w o' ' L..,.+ CRIMINAL RECORD/ABUSE HISTORY VERIFICATION G t I, Erik J. Reisser, hereby swear or affirm, subject to penalties of law including 18 Pa. C.S. § 4904 relating to unworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below,neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act, 42 Pa.C.S. § 6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime Self Other Date of Sentence all that household conviction, apply member guilty plea, no contest plea or pending charges 18 Pa.C.S. Ch. 25 El (relating to criminal ❑ ❑ homicide) 18 Pa.C.S. §2702 El (relating to aggravated ❑ ❑ assault) 18 Pa.C.S. §2706 ❑ (relating to terroristic ❑ ❑ threats) 18 Pa.C.S.§2709.1 El (relating to stalking) El El 18 Pa.C.S. §2901 El (relating to kidnapping) ❑ ❑ 18 Pa.C.S.§2902 ❑ (relating to unlawful ❑ ❑ - 1 i h restraint) 18 Pa.C.S. &2903 ❑ ❑ (relating to false ❑ imprisonment) 18 Pa.C.S. §2910 ❑ (relating to luring a child ❑ ❑ into a motor vehicle or structure) 18 Pa.C.S. §3121 ❑ (relating to rape) ❑ ❑ 18 Pa.C.S. §3122.1 ❑ ❑ (relating to statutory El sexual assault) 18 Pa.C.S. §3123 ❑ (relating to involuntary ❑ ❑ deviate sexual intercourse) 18 Pa.C.S. §3124.1 ❑ (relating to sexual ❑ ❑ assault) 18 Pa.C.S. §3125 ❑ (relating to aggravated ❑ ❑ indecent assault) 18 Pa.C.S. §3126 ❑ (relating to indecent ❑ ❑ assault) 18 Pa.C.S. &3127 ❑ (relating to indecent ❑ ❑ exposure) 2 18 Pa.C.S. §3129 ❑ (relating to sexual ❑ ❑ intercourse with animal) 18 Pa.C.S. 3130 ❑ (relating to conduct ❑ ❑ relating to sex offenders) 18 Pa.C.S. §3301 ❑ (relating to arson and ❑ ❑ related offenses) 18 Pa.C.S. §4302 ❑ (relating to incest) ❑ ❑ 18 Pa.C.S. §4303 ❑ (relating to concealing ❑ ❑ death of child) 18 Pa.C.S. §4304 ❑ (relating to endangering ❑ El welfare of children) 18 Pa.C.S. §4305 ❑ ❑ ❑ (relating to dealing in infant children) 18 Pa.C.S. §5902(b) ❑ ❑ ❑ (relating to prostitution and related offenses) 18 Pa.C.S. §5903(c) or ❑ c ❑ ❑ (relating to obscene and other sexual materials and performances) 18 Pa.C.S. §6301 ❑ (relating to corruption of ❑ ❑ minors) 3 18 Pa.C.S. §6312 ❑ ❑ ❑ (relating to sexual abuse of children) 18 Pa.C.S. §6318 ❑ (relating to unlawful ❑ ❑ contact with minor) 18 Pa.C.S. §6320 ❑ (relating to sexual ❑ ❑ exploitation of children) 23 Pa.C.S. §6114 ❑ (relating to contempt for ❑ ❑ violation of protection order or agreement) Driving under the ❑ influence of drugs or ❑ ❑ alcohol Manufacture, sale, ❑ delivery,holding, ❑ ❑ offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other Date all that household apply member A finding of abuse by a Children& Youth ❑ Agency or similar agency in Pennsylvania ❑ ❑ or similar statute in another jurisdiction 4 Abusive conduct as defined under the ❑ Protection from Abuse Act in Pennsylvania ❑ ❑ or similar statute in another jurisdiction. Other: ❑ ❑ ❑ 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child. 5. If you are aware that the other party or members of the other party's household has or have a criminal/abuse history,please explain: I verify that the information above is true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Signature ? - Printed Name 5 CHRISTINA R. REISSER, N/K/A CHRISTINA R. VERRECHIO Plaintiff v. : No. 2007 -4153 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ERIK J. REISSER, Defendant : CIVIL ACTION - LAW : IN CUSTODY Prior Judge: Kevin A. Hess, P.J. COURT ORDER AND NOW, this 7."" day of April 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. Legal Custody: The parties will share joint legal custody of Adriana M. Reisser, (DOB 4- 19 -96), Aidan A. Reisser (DOB 11- 03 -00) and Adlai P. Reisser (DOB 7- 25 -05). The parties agree that major decisions concerning their children, including, but not necessarily limited to, their health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in best interest of the children. Each party agrees not to impair the other party's rights to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning their children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. Mutual agreement should be made, in advance, regarding the following matters: enrollment or termination in a particular school or school program, advancing or holding a child back in school, authorizing enrollment in college, authorizing a child's driver's license or purchase of an automobile, authorizing employment, authorizing a child's marriage or enlistment in the armed forces, approving a petition for emancipation, authorizing foreign travel, passport application or exchange student status. Each parent shall execute any and all legal authorizations so that the other parent may obtain information from schools, physicians, psychologists, or other individuals concerning the progress and welfare of the children. 2. Physical custody of the children shall occur as follows: a. Weekday /Weekend Schedule: Father shall have physical custody of Adriana by agreement of the parties; Father's physical custody of Aidan and Adlai shall be as follows: i. Every Tuesday evening from 5:00 p.m. until Thursday morning taking the Children to school; ii. Alternating weekends from Friday 5:00 pm until Sunday 5:00 pm iii. During the school year, on Wednesday, the boys will come to Mother's residence after school and Father shall pick them up when he is off of work. If there is no school on Wednesday for whatever reason and Father is working, Mother shall be given the first opportunity to watch the boys until Father is off of work; if there is no school and Father does not have to work, the boys shall remain with Father. iv. Mother shall have custody for the remainder of the week not designated as a period of custody for Father. Regular Physical Custody Schedule (M=mom D =dad Monday Tuesday Wednesday Thursday Friday Saturday Sunday M M D D D M M D D D M M M D D D M M M M b. Holidays: i. The parties will alternate the Memorial Day, Fourth of July and Labor Day holidays. The holiday will include the weekend and school break associated with the holiday and will start at 6:00 p.m. on the evening prior to the holiday period and end the morning after the holiday period. Father will have the Memorial Day holiday in 2008, and the schedule will alternate thereafter. ii. Thanksgiving: The Thanksgiving holiday shall be divided into two segments: (1) Part A - from the conclusion of school on Wednesday until 3:00 p.m. on Thanksgiving Day. (2) Part B - from 3:00 p.m. on Thanksgiving Day until 6:00 p.m. on Friday. For only Thanksgiving 2014, Father shall have the boys for the Thanksgiving break to take them to FL. In all other subsequent even numbered years, Father shall have Part A, with Mother having Part B. The schedule will reverse in odd numbered years. iii. Christmas: Father has the Children 12/24 8:00 pm until 12/25 until 12:00 pm. Mother has all of the Christmas holiday in 2014 only. iv. Easter: The Easter holiday shall be divided into two segments: (1) Part A - from the conclusion of school on the last day prior to the holiday until 3:00 p.m. on Easter. (2) Part B - from 3:00 p.m. on Easter until the morning following the last day of the school break. 3 In 2008 and all subsequent even numbered years, Mother shall have Part A, with Father having Part B. The schedule will reverse in odd numbered years. v. Mother will have custody of the children on Mother's Day and Father will have custody of the children on Father's Day. vi. The holiday schedule shall take precedence over the regular custody schedule. c. Vacation: Each parent shall be entitled to two non - consecutive weeks of uninterrupted vacation custody. There shall be no school year vacations requiring a party to remove the children from school for more than one day in a thirty day period unless otherwise agreed by the parties. Vacation custody shall supersede the regular weekend /weekday schedule, but not the holiday schedule. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. It has been agreed upon by the parties that Mother is going to be using a total of 16 vacation days in 2014; Mother has agreed to have her son attend his baseball all star games during her vacation as long as Father provides the transportation to and from the games back to her place of vacation. 3. The parents shall organize ways for their children to maintain their friendships, extracurricular activities, and other special interests, regardless of which household they may be in. Each parent must confer with the other parent before arranging regularly occurring extracurricular activities for a child which might interfere with regular visitation. 4. Counseling: The parents have agreed to, and are strongly encouraged to, engage in therapeutic family counseling by a mutually agreed upon professional counselor. The cost of the counseling, after appropriate payment through insurance, shall be split equally between the parties. The parents shall select and set up an appointment with a counselor within ten days of the instant Order. 5. In the event the custodial parent should take the Children out of state, the custodial parent shall notify the non - custodial parent within twenty -four hours of departure of the intended destination and a telephone number at which they can be reached. 6. The parents shall permit and support access to all family relationships. Special family events such as weddings, family reunions, family gatherings, funerals, graduations, etc. shall be accommodated by both parties with routine visitations resuming immediately thereafter. Each parent shall have the option of proposing time or date variations to the other parent when special recreational options or other unexpected opportunities arise. 7. Each parent shall exercise care in screening babysitting/child care providers. 8. Each parent shall be entitled to reasonable telephone and e -mail contact with the children 4 when in the custody of the other parent. 9. Relocation. The parties are advised that neither party shall hereafter relocate the child or children if such relocation will significantly impair the ability of a non - relocating party to exercise his or her custodial rights unless (a) every person who has custodial rights to the child /children consents to the proposed relocation or (b) the court approves the proposed relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337. 10. Each parent agrees not to attempt to alienate the affections of the children from the other and will make a special conscious effort not to do so. Both parents shall refrain from making derogatory comments about the other parent in the presence of the children and, to the extent possible, shall not permit third parties from making such comments in the presence of the children. 11. A status conference with the assigned conciliator is hereby scheduled for Tuesday June 10, 2014 at 9:00 am; in the event the conference is not necessary, counsel shall notify the conciliator. 12. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Cc: `' ara Sumple Sullivan, Esquire uitina Laudermilch, Esquire ohn J. Mangan, Esquire .93/19 flr) 5 BY THE COURT, CHRISTINA R. REISSER, N /K/A CHRISTINA R. VERRECHIO Plaintiff v. : No. 2007 -4153 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ERIK J. REISSER, Defendant : CIVIL ACTION - LAW : IN CUSTODY Prior Judge: Kevin A. Hess, P.J. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3 -8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Adriana M. Reisser, (DOB 4- 19 -96) Aidan A. Reisser (DOB 11- 03 -00) and Adlai P. Reisser (DOB 7- 25 -05) 2. The parties came to an agreement and an Order issued November 05, 2007, the parties have mutually agreed upon a modified schedule, Mother filed a petition for contempt, Father filed a counterclaim for contempt and a conciliation conference was held March 19, 2014 with the following individuals in attendance: The Mother, Christina Verrechio, with her counsel Barbara Sumple- Sullivan, Esq. The Father, Erik Reisser, with his counsel Quintina Laudermilch, Esq. 3. The parties agreed to, and the undersigned recommends, an Order in the form as attached. Date: 772- 7 le-- G Joh J. angan, Esquire Cus ' d Conciliator Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINA R. REISSER, N/K/A CHRISTINA R. VERRECCHIO Plaintiff vi. ERIK J. REISSER, Defendant 2314 1 1 p,'; 2: PENNSCUMBERLAND COUNT LVANiA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2007-4153 : CIVIL ACTION - LAW : IN CUSTODY STIPULATON REGARDING CUSTODY This Agreement is made this e day ofJMX. , 2014, by and between Christina R. Reisser (now known as Christina R. Verrecchio) (hereinafter referred to as "Mother„) and Erik J. Reisser (hereinafter referred to as "Father„). WITNESSETH: WHEREAS, the parties are the parents of two (2) minor children, being: Aidan A. Reisser (DOB 11/3/00) and Adlai P. Reisser (DOB 7/25/05). WHEREAS, a Custody Order was entered in this matter on April 2, 2014, a copy of which is attached as Exhibit A. WHEREAS, the parties have mutually come to an agreement regarding custody of the children and desire to amend the April 2, 2014 Custody Order as follows: 1. The terms of the April 2, 2014 Order are hereby ratified and confirmed except as amended below. 2. Paragraph 2a. regarding physical custody shall be replaced with the following language: 2) Mother shall have primary physical custody of the children. Physical custody of the children shall occur as follows: i. Father shall have physical custody of the children as follows: 1. School Year Custody: a. Every Tuesday evening from 5:00 p.m. until school begins on Wednesday, or if no school, until 10:00 a.m. b. Alternating weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m. c. Every other Wednesday at 5:00 p.m. until school begins on Thursday, or if not school, until 10:00 a.m. This alternating Wednesday overnight shall occur in the week following Father's weekend. In the event the children do not have school on Wednesday, Father shall have the option to keep the children during the day on Wednesday (continuing from hi custodial period each Tuesday overnight), provided that he is not working during that time. 2. Summer Break Custody: a. Every Tuesday evening from 5:00 p.m. until Wednesday at 10:00 a.m. b. Alternating weekends from Friday at 5:00 p.m. until Monday at 10:00 a.m. c. Every other Wednesday at 5:00 p.m. until Thursday at 10:00 a.m. This alternating Wednesday overnight shall occur in the week following Father's weekend. Father shall have the option to keep the children during the day on Wednesday (continuing from his custodial period each Tuesday overnight) during the summer only, provided that he is not working during that time. 3. Other periods of time on which the parties may mutually agree. 3. In the event either party will be unavailable overnight during his or her period of physical custody on a weekend, that party must provide the other with the right of first refusal of the children to care for the children. 4. The cgn iliation scheduled for June 10, 2014 shall be cancelled. Witness 3 OknaivAck Usmku-W, Christina R. Verrecchio Erik J. Reisser ___ Exhibit A CHRISTINA R. REISSER, N/K/A CHRISTINA R. VERRECHIO Plaintiff v. : No. 2007-4153 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ERIK J. REISSER, Defendant : CIVIL ACTION - LAW : IN CUSTODY Prior Judge: Kevin A. Hess, P.J. COURT ORDER AND NOW, this _ZA3c ay of April 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: Legal Custody: The parties will share joint legal custody of Adriana M. Reisser, (DOB 4-19-96), Aidan A. Reisser (DOB 11-03-00) and Adlai P. Reisser (DOB 7-25-05). The parties agree that major decisions concerning their children, including, but not necessarily limited to, their health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in best interest of the children. Each party agrees not to impair the other party's rights to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning their children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. Mutual agreement should be made, in advance, regarding the following matters: enrollment or termination in a particular school or school program, advancing or holding a child back in school, authorizing enrollment in college, authorizing a child's driver's license or purchase of an automobile, authorizing employment, authorizing a child's marriage or enlistment in the armed forces, approving a petition for emancipation, authorizing foreign travel, passport application or exchange student status. Each parent shall execute any and all legal authorizations so that the other parent may obtain information from schools, physicians, psychologists, or other individuals concerning the progress and welfare of the children. 2. Physical custody of the children shall occur as follows: a. Weekday/Weekend Schedule: Father shall have physical custody of Adriana by agreement of the parties; Father's physical custody of Aidan and Adlai shall be as follows: i. Every Tuesday evening from 5:00 p.m. until Thursday morning taking the Children to school; ii. Alternating weekends from Friday 5:00 pm until Sunday 5:00 pm iii. During the school year, on Wednesday, the boys will come to Mother's residence after school and Father shall pick them up when he is off of work. If there is no school on Wednesday for whatever reason and Father is working, Mother shall be given the first opportunity to watch the boys until Father is off of work; if there is no school and Father does not have to work, the boys shall remain with Father. iv. Mother shall have custody for the remainder of the week not designated as a period of custody for Father. Re lar Physical Custody Schedule M=rnom D ---dad) Monday Tuesday Wednesday Thursday Friday Saturday Sunday M D D D M MDD D M DDM DMM M M b. Holidays: i. The parties will alternate the Memorial Day, Fourth of July and Labor Day holidays. The holiday will include the weekend and school break associated with the holiday and will start at 6:00 p.m. on the evening prior to the holiday period and end the morning after the holiday period. Father will have the Memorial Day holiday in 2008, and the schedule will alternate thereafter. ii. Thanksgiving: The Thanksgiving holiday shall be divided into two segments: (1) Part A - from the conclusion of school on Wednesday until 3:00 p.m. on Thanksgiving Day. (2) Part B - from 3:00 p.m. on Thanksgiving Day until 6:00 p.m. on Friday. For only Thanksgiving 2014, Father shall have the boys for the Thanksgiving break to take them to FL. In all other subsequent even numbered years, Father shall have Part A, with Mother having Part B. The schedule will reverse in odd numbered years. iii. Christmas: Father has the Children 12/24 8:00 pm until 12/25 until 12:00 pm. Mother has all of the Christmas holiday in 2014 only. iv. Easter: The Easter holiday shall be divided into two segments: (1) Part A - from the conclusion of school on the last day prior to the holiday until 3:00 p.m. on Easter. (2) Part B - from 3:00 p.m. on Easter until the morning following the last day of the school break. In 2008 and all subsequent even numbered years, Mother shall have Part A, with Father having Part B. The schedule will reverse in odd numbered years. v. Mother will have custody of the children on Mother's Day and Father will have custody of the children on Father's Day. vi. The holiday schedule shall take precedence over the regular custody schedule. c. Vacation: Each parent shall be entitled to two non-consecutive weeks of uninterrupted vacation custody. There shall be no school year vacations requiring a party to remove the children from school for more than one day in a thirty day period unless otherwise agreed by the parties. Vacation custody shall supersede the regular weekend/weekday schedule, but not the holiday schedule. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. It has been agreed upon by the parties that Mother is going to be using a total of 16 vacation days in 2014; Mother has agreed to have her son attend his baseball all star games during her vacation as long as Father provides the transportation to and from the games back to her place of vacation. 3. The parents shall organize ways for their children to maintain their friendships, extracurricular activities, and other special interests, regardless of which household they may be in. Each parent must confer with the other parent before arranging regularly occurring extracurricular activities for a child which might interfere with regular visitation. 4. Counseling: The parents have agreed to, and are strongly encouraged to, engage in therapeutic family counseling by a mutually agreed upon professional counselor. The cost of the counseling, after appropriate payment through insurance, shall be split equally between the parties. The parents shall select and set up an appointment with a counselor within ten days of the instant Order. 5. In the event the custodial parent should take the Children out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 6. The parents shall permit and support access to all family relationships. Special family events such as weddings, family reunions, family gatherings, funerals, graduations, etc. shall be accommodated by both parties with routine visitations resuming immediately thereafter. Each parent shall have the option of proposing time or date variations to the other parent when special recreational options or other unexpected opportunities arise. 7. Each parent shall exercise care in screening babysitting/child care providers. 8. Each parent shall be entitled to reasonable telephone and e-mail contact with the children 4 when in the custody of the other parent. 9. Relocation. The parties are advised that neither party shall hereafter relocate the child or children if such relocation will significantly impair the ability of a non -relocating party to exercise his or her custodial rights unless (a) every person who has custodial rights to the child/children consents to the proposed relocation or (b) the court approves the proposed relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337. 10. Each parent agrees not to attempt to alienate the affections of the children from the other and will make a special conscious effort not to do so. Both parents shall refrain from making derogatory comments about the other parent in the presence of the children and, to the extent possible, shall not permit third parties from making such comments in the presence of the children. 11. A status conference with the assigned conciliator is hereby scheduled for Tuesday June 10, 2014 at 9:00 am; in the event the conference is not necessary, counsel shall notify the conciliator. 12. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Cc: Barbara Sumple Sullivan, Esquire Quintina Laudermilch, Esquire John J. Mangan, Esquire 5 BY THE COURT, TRUE COPY FROM RECORD •In Testimony whereof, I here unto set my hand and the sea of said C rt at Pa. This ay of , 90 Protho iota CHRISTINA R. REISSER, N/K/A CHRISTINA R. VERRECHIO Plaintiff v. ERIK J. REISSER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2007-4153 Defendant : CIVIL ACTION - LAW : IN CUSTODY Prior Judge: Kevin A. Hess, P.J. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Adriana M. Reisser, (DOB 4-19-96) Aidan A. Reisser (DOB 11-03-00) and Adlai P. Reisser (DOB 7-25-05) 2. The parties came to an agreement and an Order issued November 05, 2007, the parties have mutually agreed upon a modified schedule, Mother filed a petition for contempt, Father filed a counterclaim for contempt and a conciliation conference was held March 19, 2014 with the following individuals in attendance: The Mother, Christina Verrechio, with her counsel Barbara Sumple-Sullivan, Esq. The Father, Erik Reisser, with his counsel Quintina Laudermilch, Esq. 3. The parties agreed to, and the undersigned recommends, an Order in the form as attached. Date: JoI( langan, Esquire Cus d Conciliator 11 Barbara Sumple-Sullivan,Esquire ti jt111 13 f,:r`i 3 Supreme Court#32317 549 Bridge Street `-ilME)ttiiLA ND New Cumberland PA 17070 PEHNSYLVANIA (717)774-1445 CHRISTINA R. REISSER,N/KJA : IN THE COURT OF COMMON PLEAS CHRISTINA R. VERRECCHIO : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : No. 2007-4153 V. : CIVIL ACTION- LAW ERIK J. REISSER, : IN CUSTODY Defendant ORDER ADOPTING STIPULATION OF PARTIES AND NOW, to wit, this /3day of C)Lhl. , 2014, upon consideration of the attached Stipulation for Custody and on motion of Barbara Sumple-Sullivan, Esquire, counsel for Plaintiff, Christina R. Reisser, n/k/a Christina R. Verrecchio and Quintina M. Laudermilch, Esquire, counsel for Defendant, Erik J. Reisser, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the attached Stipulation for Custody are adopted as an Order of Court. BY THE COURT, J. Distribution: ,iftarbara Sumple-Sullivan,Esquire,549 Bridge Street,New Cumberland,PA 17070 Auintina M.Laudermilch,Esquire,635 N. 12th Street,Suite 101,Lemoyne,PA 17043 p,\S.