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HomeMy WebLinkAbout07-4469 Anthony T. McBeth, Esquire 407 North Front Street Harrisburg, PA 17101 (717) 238-3686 Attorney for Plaintiffs RONALD D. REINFELD, JR., : IN THE COURT OF COMMON PLEAS OF JASON KOZLOWSKI and :CUMBERLAND COUNTY, PENNSYLVANIA ASHLEY KOZLOWSKI, Plaintiffs : NO. b 7- S~`/L9 ~ '~„Q,~,.._ v. CIVIL ACTION -LAW CORI J. WAGNER, :CUSTODY Defendant COMPLAINT FOR CUSTODY. PARTIAL CUSTODY OR VISITATION 1. Plaintiff Ronald D. Reinfeld, Jr., is the natural father, residing at 95 Mount Zion Manor, Tunkhannock, Pennsylvania, 18657. 2. Plaintiffs Jason Kozlowski and Ashley Kozlowsky are uncle and aunt, residing at 554 Highland Street, Enhaut, Dauphin County, Pennsylvania 17113.. 3. The Defendant is Cori J. Wagner, natural mother, residing at 135 Bosler Avenue, Second Floor, Lemoyne, Cumberland County, Pennsylvania 17043. 4. Plaintiffs seek custody of the following child: Name Present Residence Age Ethan David Reinfeld 554 Highland Street 9 years Enhaut, PA 17113 The child was born out of wedlock. The child is presently in the custody of Jason Kozlowski and Ashley Kozlowski, whose current address is 554 Highland Street, Enhaut, Pennsylvania, 17113. During the past five years, the child has resided with the following persons and at the following addresses: ` . Persons Addresses Dates Jason & Ashley Kozlowski 554 Highland Street 6/21/07 to Enhaut, PA 17113 Present Cori J. Wagner 135 Bosler Avenue, 2"~ Floor 6/03 to Lemoyne, PA 17043 6/07 Cori J. Wagner Colonial Glenn Apts. 6/02 to Harrisburg, PA 17109 6/03 The mother of the child is Cori J. Wagner, currently residing at 135 Bosler Avenue, Second Floor, Lemoyne, PA 17043. She is not married. The father of the child is Donald D. Reinfeld, currently residing at 95 Mount Zion Manor, Tunkhannock, PA 18657. He is :--~ onarried. 5. The relationship of Plaintiff Donald D. Reinfeld to the child is that of father. The Plaintiff Donald D. Reinfeld currently resides with the following persons: Name Relationship Erica Reinfeld Wife McKayla Reinfeld Daughter 6. The relationship of Plaintiff Jason Kozlowski to the child is that of uncle. The Plaintiff Jason Kozlowski currently resides with the following persons: Name Relationship Ashley Kozlowski Wife Abbigayle Elyse Kozlowski Daughter Ethan David Reinfeld Nephew 7. The relationship of Plaintiff Ashley Kozlowski to the child is that of aunt. The Plaintiff Ashley Kozlowski currently resides with the following persons: Name Relationship Jason Kozlowski Husband 3 Abbigayle Elyse Kozlowski Daughter Ethan David Reinfeld Nephew 8. The relationship of Defendant is that of mother. The Defendant currently resides with the following persons: Name Relationshia None 9. Plaintiffs have not participated as a parties or witnesses, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiffs have no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. Plaintiffs do not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 10. The best interests and permanent welfare of the child would be served by granting the relief requested herein because, Jason and Ashley Kozlowski can provide a stable, nurturing and loving environment for the child, whereas Defendant has taken many actions adverse to the child, including ingesting illegal narcotics in the child's presence, and enlisting the child's assistance with such activity on a regular basis. A petition for emergency relief, detailing some of these events, is being filed contemporaneously with this Complaint. 11. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim 4 None WHEREFORE, Plaintiffs request the Court to grant custody, and legal custody of the child as the Court deems appropriate. a~ a~ to Attorney for Ptai i 407 North Front t., first Floor Harrisburg, PA 10 (717) 238-3686 Supreme Court I.D. # 53729 5 VERIFICATION I, Ashley Kozlowski, Plaintiff in the foregoing action, verify that the facts set forth in the attached document are true and correct to the best of my knowledge, information and belief. I so state subject to the penalties of 18 Pa. C. S. §4904 (relating to unsworn falsification to authorities). 2 ~ . Date As ley Ko ws i N t~ ~- ~ ~ i. ~ ~ •, t "~~.. j....... l ~C ~, ~_ ~ .,,~ 6` cf~ Anthony T. McBeth, Esquire 407 North Front Street Harrisburg, PA 17101 (717) 238-3686 Attorney for Plaintiffs RONALD D. REINFELD, JR., JASON KOZLOWSKI and ASHLEY KOZLOWSKI, Plaintiffs v. CORI J. WAGNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT/Y,,~P-EN~NSYLVANIA ~? CIVIL ACTION -LAW CUSTODY PLAINTIFFS' PETITION FOR SPECIAL EMERGENCY RELIEF PURSUANT TO PA.R.CIV.P. 1915.13 1. The child who is the subject of the captioned action is Ethan Reinfeld ("Ethan") age nine years. 2. Ethan is currently in the custody of Jason Kozlowski and Ashley Kozlowski who reside at 554 Highland Street, Enhaut, Pennsylvania. 3. Ashley Kozlowski is the sister of the child's natural father, who is named as a Plaintiff herein; the father lives in Tunkhannock, Wyoming County, Pennsylvania. 4. The child's mother is the Defendant, Cori J. Wagner, who resides at 135 Bosler Avenue, Second Floor, Lemoyne, Cumberland County, Pennsylvania. 5. Although the Bosler Avenue address has been the child's primary residence since June, 2003, the child has spent extensive periods of time with Plaintiffs Jason and Ashley Kozlowski. 6. In fact, the child had been staying at the Kozlowskis' home from June 21, 2007 until the child returned to his mother's home on the night of July 26, 2007. 7. While still at his mother's home, on the morning of July 27, 2007, the child, on his own initiative, transported by bicycle to the West Shore Regional Police, the following items belonging to his mother: 1. a bag of marijuana; 2. marijuana roaches and 3. "blunts," marijuana smoking devices rolled similarly to a cigar. 8. Throughout the time that the mother has lived at the Bosler Avenue address, she and whatever paramour she may have at any given time have ingested illegal narcotics in the child's presence, enlisted the assistance of the child for that purpose (including having the child retrieve bags of marijuana from their car), exposed the child to pornography and, at least from time to time, been physically abusive toward the child by shaking him excessively. 9. On the morning of July 27, 2007, the child simply grew weary of seeing such illegal activity in his own home, and decided to take the items listed above to West Shore Regional Police. 10. The child is now in the custody of Plaintiffs Jason and Ashley Kozlowski, and Ashley Kozlowski is working with West Shore Regional Police, who have recommended to her that she file a custody action and this Petition for Special Emergency Relief. 11. Upon information and belief, West Shore Regional Police have made a referral to Cumberland County Child Protective Services, although Plaintiffs have not been able to verify that fact independently and at the time this Petition is being drafted (approximately t, C °+ ^~. ~_ !~ 2:40 P.M. on Friday, July 27, 2007) have not been contacted by Cumberland County Child Protective Services. 12. Under the circumstances described above, Plaintiffs' including the child's father, who agrees with all actions that his co-plaintiffs, his sister and brother-in-law, Ashley and Jason Kozlowski, have taken to this point, believe and therefore aver that an emergency order giving them custody of Ethan Reinfeld is necessary so that Ethan can be removed from what is obviously a destructive environment in his mother's home and, more immediately, so that Ethan can avoid reprisals from his mother because of him exposing his mother's criminal conduct to West Shore Regional Police on July 27, 2007. WHEREFORE, Plaintiffs request this Honorable Court to enter an Order on an emergency basis giving custody of the child, Ethan Reinfeld, to Plaintiffs Jason Kozlowski and Ashley Kozlowski, pending further Order of Court; Plaintiffs also request this Honorable Court to provide any other relief it deems appropriate. ~~ Attorney for I 'ntiffs 407 North on St., First Floor Harrisburg, PA 17101 (717) 238-3686 Supreme Court I.D. # 53729 VERIFICATION I, Ashley Kozlowski, Plaintiff in the foregoing action, verify that the facts set forth in the attached document are true and correct to the best of my knowledge, information and belief. I so state subject to the penalties of 18 Pa. C. S. §4904 (relating to unsworn falsification to authorities). 7~ g Date As ley Koz wski v -~ ~- ~ ~" `~ ~~..~ ~ r ~ .~- ~ -- , J ~ ~, cam, ;~- ...-s ~ ~~ ~ ~ ~ 6 Ga ~ ~ fa 0 ~JUL 30 2DD7t~ RONALD D. REINFELD, JR., : IN THE COURT OF COMMON PLEAS OF JASON KOZLOWSKI and :CUMBERLAND COUNTY, PENNSYLVANIA ASHLEY KOZLOWSKI, p /'~` ~ Plaintiffs : NO. 0 ?- ~ ~ 1 V'u'~'`'~ v. :CIVIL ACTION -LAW CORI J. WAGNER, :CUSTODY Defendant ORDER AND NOW, this 3~~ of July, 2007, upon consideration of Plaintiffs' Petition for Special Emergency Relief Pursuant to Pa.R.Civ.P. 1915.13, it is hereby ORDERED that the Petition is granted. Custody of the child, Ethan Reinfeld shall remain with Plaintiffs Jason and Ashley ozlowsk' at their home in Enhaut, Pennsylvania, pending f .The Cou further directs that a conciliation date be chosen and service of the Complaint in the captioned action be made as soon as practicable. BY COUR J. Distribution: Anthony T. McBeth, Esq. 407 North Front Street, Harrisburg, PA 17101 Cori J. Wagner, 135 Bloser Avenue, Second Floor, Lemoyne, PA 17043 ~~a~o7 ~1 4" t bl~~l~.~ti`l,,~r ~~af~r~ ~~ ~- ~t1~ tO~Z ~.10~ ~~i1~.~~~d ~H1. ~0 RONALD D. REINFELD, JR. AND JASON KOZLOWSKI AND ASHLEY KOZLOWSKI PLAINTIFF V. CORI J. WAGNER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • 07-4469 CTVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, August 03, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. ,the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, September 04, 2007 at 1:30 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 ale five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information. about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 1~~1Gtyvr.l.U~a 3N1 ~0 ~; ~ :~ ~~-fl31l~ DONALD D. REINFELD, JR., JASON KOZLOWSKI and ASHLEY KOZLOWSKI, Plaintiffs v. CORI J. WAGNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-04469 CIVIL TERM CIVIL ACTION -LAW CUSTODY ORDER AND NOW, this ~ ~ day of , 2007, upon consideration of Plaintiffs' Motion for Entry of Order Pursuant to Stipulation, and the Court having reviewed the Stipulation attached to the Motion, the Court finds that the Stipulation does indeed promote the best interests and permanent welfare of the child who is the subject of this action, namely Ethan David Reinfeld, born October 14, 1997. Accordingly, it is hereby ORDERED as follows: 1. Plaintiffs Jason Kozlowski and Ashley Kozlowski shall have primary physical custody Ethan David Reinfeld. Further, Ethan's actual place of residence will be the home of Plaintiffs Jason Kozlowski and Ashley Kozlowski, located at 554 Highland Street, Enhaut (Dauphin County), Pennsylvania; 2. Plaintiff Donald D. Reinfeld shall have visitation or partial custody of Ethan David Reinfeld from time to time as the parties may agree; 3. Defendant Cori J. Wagner shall have visitation or partial custody of Ethan David Reinfeld on alternating weekends from Friday at 7:00 P.M, until Sunday at 9:00 P.M., subject to the provisions of the following paragraph; 4. Notwithstanding the provisions pf the previous paragraph, the parties acknowledge that Cori J. Wagner is currently facing criminal charges in Cumberland County, Pennsylvania and that a condition of her bail on said charges is that she have no contact with Ethan David Reinfeld; accordingly, partial custody shall not begin for Cori J. Wagner until the first Friday after she provides written evidence (in the form of a certified copy of an order of court or other documentary evidence satisfactory to the Plaintiffs herein) that she is no longer prohibited #rom contact with Ethan David Reinfeld; 5. Legal custody shall be shared by Donald D. Reinfeld, Jr., Jason Kozlowski, Ashley Kozlowski and Cori J. Wagner. With respect to their shared legal custody, the Parties shall consult with each other relative to all important decisions concerning Ethan David Reinfeld, including such matters as health, education and religion; 6. All parties shall refrain from making derogatory comments about the other parties in the present of the child. The parties shall likewise assure, to the extent possible, that other household members and guests comply with this prohibition; 7. During any period of custody or visitation, the parties to this stipulation shall not possess or use any controlled substance, neither shall they consume alcohol beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and guests comply with this prohibition; 8. The party whose period of custody, partial custody or visitation is about to begin shall be responsible for all transportation to effect such custody; 9. Because of a typographical error made in the office of Plaintiffs' counsel, it is necessary for the parties to agree, and the parties do agree, that the proper designation of Plaintiff Reinfeld in the captioned action is in fact Donald D. Reinfeld, Jr. ~t Ronald D. Reinfeld, Jr., as has been incorrectly articulated on one or more pleadings) and that the Court may rely upon this paragraph as an agreement among the parties to amend the caption so that the Reinfeld Plaintiff is hereinafter designated as Donald D. Reinfeld, Jr., the amendment is hereby ORDERED and the amendment shall be reflected on this Order; It is further ORDERED that, should any of the parties move from their present residence, they shall provide the other parties with their new address, new telephone number, new a-mail address, new cellular phone number or any other means of contact (and shall similarly provide their new telephone number, new a-mail address or their new cellular phone number, even if they do not change their present residence) within five days of either moving or obtaining a new telephone number, cell phone number or a-mail address, as the case may be. Distribution: Anthony T. McBeth, Esq. 407 North Front Street, Harrisburg, PA 17101.E Q,~l c,~.~: P~t% ~ Cori J. Wagner, 135 Bloser Avenue, Second Floor, Lemoyne, PA 17043 ~ Edward E. Guido, Judge f~ r T r; ' ~i -. ~~ 'rte ! ~~ ~~~ L I u~'~ ~~i ~r~::.~.~~~.. Anthony T. McBeth, Esquire 407 North Front Street Harrisburg, PA 17101 (717) 238-3686 Attorney for Plaintiffs DONALD D. REINFELD, JR., JASON KOZLOWSKI and ASHLEY KOZLOWSKI, Plaintiffs v. CORI J. WAGNER, Defendant IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-04469 CIVIL TERM CIVIL ACTION -LAW CUSTODY PLAINTIFFS' MOTION FOR ENTRY OF ORDER PURSUANT TO PARTIES' STIPULATION A hearing on Plaintiffs' Petition for Special Emergency Relief in the captioned action is currently set for August 10, 2007 at 9:15 A.M. 2. In the interim, Plaintiffs and Defendant, who are the parents, aunt and uncle of Ethan David Reinfeld (born October 14, 1997) have entered into a written stipulation faF custody that all parties believe to be in the best interests of and promoting the perman~~t welfare of Ethan David Reinfeld. The stipulation is attached hereto. 3. The stipulation provides that both parents believe the terms of the stipulation to be promoting the best interests and permanent welfare of Ethan David Reinfeld; accordingly, Plaintiffs request that the Court enter an Order adopting the stipulation as the Court's Order with respect to custody of Ethan David Reinfeld, and the Court can accomplish this by entering the proposed order submitted herewith. WHEREFORE, Plaintiffs request this Court to enter an Order adopting the parties' stipulation with respect to custody of Ethan David Reinfeld, and to provide any other relief the Court deems appropriate. o~'V ate (717) 238-3686 Supreme Court I.D. # 53729 ~tSony T. Mc6 t Esq. Attorney for Plai ti 407 North Front first Floor Harrisburg, PA 17101 2 DONALD D. REINFELD, JR., JASON KOZLOWSKI and ASHLEY KOZLOWSKI, Plaintiffs v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-04469 CIVIL TERM CIVIL ACTION -LAW CORI J. WAGNER, :CUSTODY Defendant STIPULATION BY AND BETWEEN DONALD D. REINFELD. JR.. FATHER JASON KOZLOWSKI. ASHLEY KOZLOWSKI AND CORI J. WAGNER. MOTHER WITH RESPECT TO THE CUSTODY OF ETHAN DAVID REINFELD. BORN OCTOBER 14. 1997 WHEREAS, the Parties to this Stipulation are the parents, aunt and uncle of Ethan David Reinfeld, born October 14, 1997 and WHEREAS, the Parties desire to settle the pending action filed to Cumberland County Action Number 07-04469 Civil Term, wherein Donald D. Reinfeld, Jr., Jason Kozlowski and Ashley Kozlowski seek primary physical custody of Ethan David Reinfeld and WHEREAS, the Parties have agreed to a custody arrangement that they believe and represent to be in the best interests and permanent welfare of Ethan David Reinfeld, THE PARTIES HEREBY STIPULATE AS FOLLOWS: 1. Plaintiffs Jason Kozlowski and Ashley Kozlowski shall have primary physical custody Ethan David Reinfeld. Further, Ethan's actual place of residence will be the home of Plaintiffs Jason Kozlowski and Ashley Kozlowski, located at 554 Highland Street, Enhaut (Dauphin County), Pennsylvania; 2. Plaintiff Donald D. Reinfeld shall have visitation or partial custody of Ethan David Reinfeld from time to time as the parties may agree; 3. Defendant Cori J. Wagner shall have partial custody of Ethan David Rein#eld on alternating weekends from Friday at 7:00 P.M. until Sunday at 9:00 P.M., subject to the provisions of the following paragraph; 4. Notwithstanding the provisions of the previous paragraph, the parties acknowledge that Cori J. Wagner is currently facing criminal charges in Cumberland County, Pennsylvania and that a condition of her bail on said charges is that she have no contact with Ethan David Reinfeld; accordingly, partial custody shall not begin for Cori J. Wagner until the first Friday after she provides written evidence (in the form of a certified copy of an order of court or other documentary evidence satisfactory to the Plaintiffs herein) that she is no longer prohibited from contact with Ethan David Reinfeld; 5. Legal custody shall be shared by Donald D. Reinfeld, Jr., Jason Kozlowski, Ashley Kozlowski and Cori J. Wagner. With respect to their shared legal custody, the Parties shall consult with each other relative to all important decisions concerning Ethan David Reinfeld, including such matters as health, education and religion; 6. All parties shall refrain from making derogatory comments about the other parties in the present of the child. The parties shall likewise assure, to the extent possible, that other household members and guests comply with this prohibition; 7. During any period of custody or visitation, the parties to this stipulation shall not possess or use any controlled substance, neither shall they consume alcohol beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and guests comply with this prohibition; 2 8. The party whose period of custody, partial custody or visitation is about to begin shall be responsible for all transportation to effect such custody; 9. Because of a typographical error made in the office of Plaintiffs' counsel, it is necessary for the parties to agree, and the parties do agree, that the proper designation of Plaintiff Reinfeld in the captioned action is in fact Donald D. Reinfeld, Jr. (not Ronald D. Reinfeld, Jr., as has been incorrectly articulated on one or more pleadings) and that the Court may rely upon this paragraph as an agreement among the parties to amend the caption so that the Reinfeld Plaintiff is hereinafter designated as Donald D. Reinfeld, Jr., such designation beginning with the Order that adopts this stipulation; 10. The parties stipulate that they have correct current addresses and telephone numbers for each other, and the parties further stipulate that, should any of them move from their present residence, they shall provide the other parties with their new address, new telephone number, new a-mail address, new cellular phone number or any other means of contact (and shall similarly provide their new telephone number, new a-mail address or their new cellular phone number, even if they do not change their present residence) within five days of either moving or obtaining a new telephone number, cell phone number or a-mail address, as the case may be; 11. The parties specifically desire that this stipulation be adopted as and made an order of the Cumberland County, Pennsylvania Court of Common Pleas in the case known as Donald D. Reinfeld, Jr., Jason Kozlowski and Ashley Kozlowski v. Coy J. Wagner, Cumberland County No. 07-4469 Civil Term and 3 12. The parties acknowledge that each has been represented by counsel (Donald D. Reinfeld, Jr., Jason Kozlowski and Ashley Kozlowski, represented by Anthony T. McBeth, Esquire and Cori J. Wagner, represented by Gail Guida Souders, Attorney at Law) and that the parties have consulted with their respective counsel to the parties' satisfaction with respect to the parties' entry into this stipulation. b8109 ~O ~ Date 4Q~04/o7 Date ~ jai o'~ Date ~~ Date i ~ Donald D. R , Jr. ~~ Cori J. Wagn COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. On this, the ~ day of i ._.2007, before me, the undersigned officer, personally appeared DO ALD D. REINFELD, JR., known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. bonnie /1o Huq, Notary Pub My Commission Expires: ~'of~~.cau~r,in~r ~ ~ E~-es July 7, 2011 Member, Penns 11van?a gsu;xjarion of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. On this, the ~ day of GvlT , 2007, before me, the undersigned officer, personally appeared JAS N KOZLOWSKI, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purpose therein contained. IN WITNESS WHEREOF, I have h nto set my hand and notarial seal. ,= ~` ~ l/ ary Public My Commission Expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Bonnie Jo Hup, Notary PubNc filly OF Harrisb~xg, f~auphirt County My Corrxnission E~in3s July 7, 2011 Member, Pennsytvanla ttsso~lation of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. On this, the ~ day of , 2007, before me, the undersigned officer, personally appeared ASHL OZLOWSKI, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. Public ~.vmmuivWEALTH OF PENNSYLVANIA My Commission Expires: ~~ e~~~~c Myc, ~ry Member, Pennsylvania AssaciAtion of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. On this, the day of lcl~ , 2007, before me, the undersigned officer, personally appeared CORI J. WAGNER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. ~~ C / o#ary Pubic My Commission Expires: COMMONWEALTH OF PENNSYLVANIA Notarral Seal Bonnie Jo HuN, Notary PubNc CUy Of Harrisburg, DattpFih ~ My Comrriission E~ires July 7.2011 Member, Pennsylvania Assc+clatlon of Notaries auc ~1 zoos RONALD D. REINFELD, JR. and IN THE COURT OF COMMON PLEAS OF JASON KOZLOWSKI and :CUMBERLAND COUNTY, PENNSYLVANIA ASHLEY KOZLOWSKI Plaintiffs vs. 07-4469 CIVIL ACTION LAW LORI J. WAGNER . Defendant IN CUSTODY ORDER AND NOW, this 30th day of August, 2007 ,the conciliator, being advised by plaintifF s counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for September 4, 2003_ is cancelled. FOR THE COURT, • Dawn S. Sunday, Esquire Custody Conciliator jt* ~ It t "1 d DONALD D. REINFELD JR., JASON KOZLOWSKI and ASHLEY KOZLOWSKI Plaintiffs VS CORI J. WAGNER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 07-04469 CIVIL TERM CIVIL ACTION- CUSTODY STIl'ULATION FOR AN AGREED ORDER OF CUSTODY AGREEMENT, made this ~,~,,,_ day of March 2009, by and between Donald D. Reinfeld, Jr., hereinafter referred to as "Father," Cori J. Wagner, hereinafter referred to as "Mother," and Jason Kozlowski and Ashley Kozlowski (hereinafter called "Uncle and Aunt") are uncle and aunt of the Ethan D. Reinfeld. WITNESSETH WHEREAS, Mother and Father hereto are the natural parents of one minor child Ethan David Reinfeld, born October 14 1997; and WHEREAS, the parties have come to an agreement concerning the issues of child custody; and WHEREAS, the parties desire that this Stipulation be entered as an Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW THEREFORE, intending to be legally bound, the parties hereby stipulate and agree as follows: 1. It is the intention of the parties and the parties agree that they shall have joint legal custody. The parties agree that major decisions concerning their child, including, but not necessarily limited to, the child's 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 the child's best interest. Each party agrees not to impair the other party's rights to primary physical custody and partial custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning their child 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 primary physical custody. With regazd to any emergency decisions which must be made, the parent having primary physical custody of the child at the time of the emergency shall be pen~nitted 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. 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 given to either party as a parent. 2. Primary physical custody of Ethan David Reinfeld shall be with the Mother, Cori J. Wagner. 3. Father, Donald D. Reinfeld Jr., shall have partial custody of Ethan D. Reinfeld as all the parties mutually agree. 4. The holidays will be determined as all the parties mutually agree upon. 5. Father shall have custody of child on Father's Day from and Mother shall have custody of child on Mother's Day. 6. The parties shall share transportation. 7. During any period of custody or visitation the parties to this order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible that other household members and/or house guests comply with this prohibition. 8. Each parent shall be entitled to reasonable telephone contact with the child when he is in the custody of the other parent. 9. Neither pazent shall permanently relocate if the relocations would necessitate a change in the visitation schedule or if the relocation would 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. 10. Both pazents shall refrain from making derogatory comments about the other pazent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. 11. It is understood and stipulated by the parents that upon mutual agreement expanded or altered schedule may be agreed between the parents for and in the best interest of the child. d~ Date Cori J. W er 03 Zo D9 Date 3 ~~o coq Date 31 Zo1 Da e `_ ?.~ > ----_> Donald D. Reinfeld, Jr. n Kozlowski As ey Ko wski COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: SS: On the~7~ day of t~A~ , 2009, before me, a Notary Public, personally appeared Cori J. Wagner known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. Na~rARIAI.sEal LLO~DP.9CFWOF~61, NODIRIf PIrBIC LONIER RUfTON10YYNBMBP, QNIPFMI COI~R14 AI COMMISSION EXPIRES MAY 2, 2008 No Pu lic COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: SS: On the ~8 day of 1~~ , 2009, before me, a Notary Public, personally appeared Donald D. Reinfeld Jr. known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. Now~Al.seu. _ ~owER~R~XPniN~ COAINISSION EXPIRES MAYS 2008 Notary Pu lic COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: SS: On the 2 ° day of M~+~- , 2009, before me, a Notary Public, personally appeared Jason Kozlowski known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. sFx U.f7YD P., NOT11iiYPUBIIC LOYMEH FAXiO!ll0YYN9FNP, QM111PlNI OOIkRx Pl4 COMMISSION EXPIRES MAY 2, 2009 Notary Public COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: ~ SS: On the ~~ day of 'C~p~- , 2009, before me, a Notary Public, personally appeared Ashley Kozlowski known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. No~w+u:sEa. LLaYD P. SCI, N001NY Pll~1C LOYYER ROf lON TOWAi~tl; GM~Fr! COIMQK ~ COUMMSSION EXPiIE,S MAY 2, 2009 Notary Public ,,n -~ _ -a a.~ i-~ ,, r,.~ ,.,_ ~~° ,: x _ _ t,~ <,~> ~.- -<: V, .. MAR s o zaae ~ ., DONALD D. REINFELD JR., : IN THE COURT OF COMMON PLEAS JASON KOZLOWSKI and :CUMBERLAND COUNTY, PENNSYLVANIA ASHLEY KOZLOWSKI . Plaintiffs : NO: 07-04469 CIVIL TERM VS :CIVIL ACTION- CUSTODY CORI J. WAGNER . Defendant ORDER OF COURT AND NOW this ~ ~~ da of ~ • ` ~ 2009, the parties y having reached an agreement regarding the best interests of the subject minor child, Ethan D. Reinfeld, it is hereby ORDERED and DECREED that the terms of the stipulration entered into between the parties, which is attached hereto, is entered as an Order of Court. BY ,COURT: J. ~i§tribution: ,/ n J. Wagner-4240 K Williamsburg, PA 17109 nand Ashley Kozlowski-554 Highland Street, Enhaut, PA 17113 ~nald D. Reinfeld Jr.-353 A Street Carlisle, PA 17013 3~~~~~ .~ i ~ ~ ~ i ~ ~i~ ^UU4