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HomeMy WebLinkAbout07-5154LESLIE J. REDMOND, Plaintiff v. JOSHUA A. REDMOND, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW • D7 - S~ 5 ~ NO. CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Leslie J. Redmond, adult individuals currently residing at 433 West Louth~r Street, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Joshua A. Redmond, an adult individual currently residing at 8 Mt. Rock Road, Newville, Cumberland County, Pennsylvania. 3. The Defendants are the natural parents of two (2) children, namely, Aubrey Noelle Redmond and Summer Leah Redmond, both born May 25, 2005. The children were born in wedlock. 4. For the past five (5) years, or since the children's birth, the children have resided with the following persons at the following addresses for the following periods of time: NAME Leslie J. Redmond Timothy and Robin Redmond (Paternal grandpazents) Leslie J. Redmond Leslie J. Redmond Leslie 1. Redmond and Joshua A. Redmond Leslie J. Redmond and Joshua A. Redmond Leslie and Joshua Redmond, Timothy and Robin Redmond (Paternal grandparents) ADDRESS DATES 433 West Louther Street August 9, 2007 Cazlisle, PA 17013 to Present 8 Mt. Rock Road June 2007 to Newville, PA 17241 August 9, 2007 6367 Hampton Place #1 September 2006 to Ft. Riley, Kansas 66442 June 2007 6367 Hampton Place #1 Apri12006 to Ft. Riley, Kansas 66442 September 2006 13 Wiltshire West August 2005 to Carlisle, PA 17013 Mazch 2006 101 West Big Spring Avenue May 2005 to Newville, PA 17241 August 2005. The natural mother of the children is Leslie J. Redmond who resides as aforesaid. She is married. The natural father of the children is Joshua A. Redmond, who resides as aforesaid. He is married. 5. The relationship of the Plaintiff to the children is that of natural mother. The Plaintiff currently resides with the children at issue. 6. The relationship of the Defendant to the child is that of natural father. Defendant currently resides alone. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the children. 8. Plaintiff has no information of any custody proceedings concerning the children pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfaze of the children to grant the relief requested for the following reasons: a. Plaintiff can provide for the day to day needs of the children; b. `Plaintiff has been the primazy cazetaker since the birth of the children, caring for them alone since September 2006; and c. Mother can provide a stable home for the children. 10. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. 11. The parties have reached an agreement in this matter and ask that the Court sign the Stipulation and Agreement being filed concurrently with the Custody Complaint as an Order. WHEREFORE, Plaintiff requests your Honorable Court to enter the Order regazding the parties' Custody Stipulation and Agreement, which is being filed concurrently with the Custody Complaint. Respectfully submitted, Hannah Herman-Snyder, Es uire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Cazlisle, PA 17013 (717) 243-5551 (800) 347-5552 . . VERIFICATION I verify that the statements made in the foregoing document aze true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: i~~ Q9 ~~ LESLIE J. REDMOND ~, v tc f") ~a ~ c`,ti = ~ ~ ~ -- ~•. G'~ c~ z -~ ~ r r' - ~ I,7 L;/ ti c Q 9.J .{ ~ 3 ~ ~. YY ~~^^ ~ t =- ~ ~t xn i ~ f LESLIE J. REDMOND, Plaintiff v. JOSHUA A. REDMOND, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION~(-LAW NO. ~ 7 ~'~~ IVIL TERM IN CUSTODY CUSTODY STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between Leslie J. Redmond, (hereinafter referred to as "Mother") and Joshua A. Redmond, (hereinafter referred to as "Father"). WHEREAS, the parties are the natural parents of two children, namely, Aubrey Noelle Redmond and Summer Leah Redmond, both born May 25, 2005 (hereinafter referred to as "children"); WHEREAS, the parties wish to enter into a comprehensive stipulation and agreement relative to physical and legal custody of the children. NOW THEREFORE, in consideration of mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: 1. The parties shall share legal custody of the children. 2. Mother shall exercise primary physical custody of the children. 3. Father shall exercise partial physical custody of the children every other Friday for a six (6) hour time period, with his periods of custody being supervised by Mother or ~s Father's parents, as agreed upon between the parties, with custody being exercised as such until the parties agree otherwise. 4. All Father's periods of partial physical custody shall be exercised in Cumberland County, unless otherwise agreed by the parties. 5. Father shall provide all transportation for his periods of partial physical custody, and his vehicle shall be equipped with proper car seats for the children. 6. It is affirmed that the Court of Common Pleas of Cumberland County, Pennsylvania, had jurisdiction over the issue of custody of the children in this case at the time the proceedings were initiated and, further, by agreement of the parties and Order of Court, the Court has retained jurisdiction over these matters so that it is appropriate for the Court to enter an Order of Court. Further, the parties request that the Court of Common Pleas of Cumberland County, Pennsylvania, enter this as an Order of Court. 7. Any modification or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing and only if executed with the same formality as this Stipulation and Agreement. 8. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it ~is not the result of any duress or undue influence. f ,~ 9. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other P~3'• 10. All prior Orders in this matter are hereby vacated. IN WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. WITNESSETH: ~~, JI..Y 1\ 1 Ld~/.1.1~L1~ Date LESLIE J. REDMOND d- u G ~ Date J A A. REDMOND ~.' '~ r s . ~ ~~~' l .. ,. r r COMMONWEALTH OF PENNSYLVANIA: ~ "'.. SS. COUNTY OF ~" bU On this, the ~~ day of ~~~ , 2007, before me the undersigned officer, personally appeared Leslie J. Redmond, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the foregoing instrument and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hind and official seal. -~ Notary COMMONWEALTH OF PENNSYLVANIA: .. SS. COUNTY OF Q~ On this, the o20'~ day of ~""--0 ~-d~ , 2007, before me the undersigned officer, personally appeared Joshua A. Redmond, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing instrument and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ary Public COMMONWEALTH OF PENNSYLVANIA Nofa~ial Seal Joama M. Metridc, Nohary Pudic Soutl~ ~ ~~ ~Y'~-~9 ~Y My C.ommi~sbn Ekes Jay 28, 2008 Member, Pennsvlvan43 a^~ ~^~^~~~~ Of Notaries ("') rv f - ~ C"a ~., ;'' `n r„i ti3 f',j?1 ~: ~, 1V T Terri _ ~~iC~~ =_ v~?.r .4, / L` .> (, J • 'S ., LESLIE J. REDMOND, Plaintiff v. JOSHUA A. REDMOND, Defendant AU G 2 9 200?' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. ®7" ~l SC~VIL TERM IN CUSTODY ORDER OF COURT AND NOW this ` day of v , 2007, the attached Custody Stipulation ~_ and Agreement isrhereby made an Order of Court. BY THE COURT, ~/~ ~%. J. cc: Hannah Herman-Snyder, Esquire Attorney for Plaintiff Joshua A. Redmond, Pro Se ~1:~ 's,§ '..+ .., ~ „ i ~ ~ #, :~~ L~ ~' ~ ~' „ ~ ~;~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LESLIE J. REDMOND, Plaintiff, v. !JOSHUA A. REDMOND, Defendant. CIVIL ACTION - LAW NO: 07-5154 civil term IN CUSTODY PETITION TO MODIFY CIISTODY ORDER AND NOW, comes Defendant, JOSHUA A. REDMOND, by and through his attorney, Melody L. Hanisek, Esquire, and files the following Petition to Modify Custody. ~l. Defendant, Joshua A. Redmond, is an adult individual residing at 920 Main Street, South Williamsport, Lycoming County, Pennsylvania. 2. Plaintiff, Leslie J. Redmond, is an adult individual residing at 433 West Louther Street, Carlisle, Cumberland County, Pennsylvania. 3. The parties are the parents of two (2) minor children, Aubrey Noelle Redmond and Summer Leah Redmond, both born May 25, 2005. 4. The children were born of the parties' marriage. 5. The children are presently in the custody of the Plaintiff. 6. From the date of the children's birth until approximately June 2406 they resided with Plaintiff and Defendant at various locations. ,7. From September 2006 through approximately June 2007, the Defendant was deployed to Iraq and thus the children remained in the Plaintiff's physical custody during that time. ~'8. From approximately June 2006 until present the children have resided with the Plaintiff; with Defendant having partial custody. ~9. The relationship of the Defendant to the children is that of their father. ~1.0. The relationship of the Plaintiff to the children is that of their mother. ~11. The Defendant has not participated as a party in other litigation concerning the custody the children in this, or any other Court. 12. The Defendant has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. 13. The Defendant 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. 14. The existing custody order is dated August 30, 2007, and is attached as Exhibit "A". X15. Since the issuance of the custody order, there have been significant changes of circumstances that would mandate that the custody order should be changed. 16. The best interest and permanent welfare of the children will be served by granting the relief requested since Defendant is able to properly provide and care for the children. ~17. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. 18. Wherefore, the Defendant respectfully requests that this Honorable Court modify the existing custody order so to increase the Defendant's periods of partial custody. Respectfully submitted, By: Melody H isek, Esquire MIELE & YMSZA, P.C. 36 West Fourth Street Williamsport, PA 17701 (570)322-2113 I.D. #201487 Dated: December 7, 2007 1 ~AUG 2 9~D07 LESLIE J. REDMOND, IN TIdE COURT UI~ COMI~~IUN PLEAS OP Plaintiff : CUA~TBERLAND COUl\TTY; PrNNSYLVANI!-1 ~,. :CIVIL ACTION - LA~~~ N0. ~ ~ / Sf CI~ IL TERM JOSHUA A. REDMUND, Defendant IN CUSTODY ORDER Or COURT A.ND NO~~,t this ,~~~ day of ~ 2U07; the attached Custody Stipulation -. and Agreement is:hereby made an Urder of Court. T3Y THE COURT, /sl ~ ~~ J. cc: Hamlal: HermairSnyder, Esquire Attorney for Plai»tJf Joshua A. Redmond, Pro Se EXHIBIT A :s~ _.~ r~ °~ ~ . ..~, P~ad~~rt..~. L,l:SLII-~ .l. T:Ill1~~C)N1~, 1N "1'I IE COUIZ`I C)1~ CC~h~IMON PLI.AS C)h Plaintiff CU1~~BL~RLANI) COUN"1~1'. I'I:NNS~YLVAN~IA v. CIV1I~ ACfI70N - L,AW .IUSNUA A. REDMONI~, N0. CIVIL'hI~P.A~1 r. , ,• Defendant :. ._ ',, IN CUS`fUD~' __, .: ~;~ _ cM1, CtISTO~Y STII't,TLATION ANI) AC:i<2E)G>~~ INT - . .. TI-IIS STIPLILATI01~~ AND AGREEMENT entered into tJle day and year 1lereindfi~,r set forth; b}' and betv,~een Leslie ,i. Redmond; (hereinafter referred to as "A~Iother"j and .Ioshua. A. Redmond, (hereinafter referred to as "Father"j V~'I~EREAS, the parties are the natural parents of t\~,~o children, Hamel}-, Aubrey Noelle Redmolid and Summer Leah Redmond; both born 1\9a}~ 25. 20U~ (hereinafter referred to as `'children`''); }T~~'HERI.AS. the parties \~~ish to enter into a comprehensive stipulation and agreement relative to physical and ]e~aJ custody of the children. NO~~i THER)/FOR)/, in consideration of mutual covenants; promises alld a.oreements as hereinafter set forth.; the parties stipulate and agree as folloti~~s: 1. The parties shall share legal custody of the children. 2. Mother- shall exercise primary physical custody of The clliJdl-en. ~. 1=ather shall exercise: , ::?-tia] pll}~sical custody cf illy: ~. ~_,'c~cn every other 1 rida;~ .or ~: S1 ~ i ~ ')Lll" ill)lt: hei'IOCI. \%,']t11 1115 ] Ci':~ • ~~ C;f C± • `."d\' bCil)n SLhel \ 15t:'_ .~, 1~Iolli''' •11 Lather's parents, as agrccu ~~pon between the parties; wi~i~l ~.:!~siody being exercised as such until the parties agree otherwise. 4. All Father's periods of partial physical custody shall be exercised in Cumberland County, unless otherwise agreed by the parties. 5. Father shall provide all transportation for his periods of partial physical custody, aid his vehicle shall be equipped with proper car seats for the children. 6. It is affirmed that the Court of Common Pleas of Cumberland County, Pemisylvania, had jurisdiction over the issue of custody of the children in this case at the time the proceedings were initiated and, further, by agreement of the parties and. Order of Court, the Court has retained jurisdiction Deer these matters so that it is appropriate for the Court to enter an Order of Court. Further, the parties request that the Court of Common Pleas of Cumberland County; Pennsylvania, enter this as an Order of Court. 7. Any modification or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing and. only if executed with the same formality as this Stipulation and Agreement. 8. The parties aclulowledge that they have read azzd understand the provisions of this Agreement. I/ach party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or u~~due iiu~luence. ~). The parties stipulate thal in makinb this Acrecment. there has been no fraud, concealment. overreaclzint,,, coereicm. or other unfair dealinL on the hart of the other parr-. l U. All prior Orders in this matter a~-e hereby >>acatcd. IN ~~~I'I'NESS VJI-II~P.LOI~. The parties hereto iniendin~ to be legally bound by the terms hereof. set forth their hands and seals the da}~ and year hereinafi.er mentioned. ~~~ITNESSETH: '~ Y~ ~~ Date `LESLIE J. REDMOND ~ ~ ~G Date SIIUA A. REDMOND C`UM1v~iON~~~IAI~T7l O1' P>/:~fi~SYLA~.r-~l~il.~: I - SS. CU1~Tl~7'Y Or ~~Ixr~a~cf On this. the ~~~' day of ~ ,, ~=~, .2007. before me the undersigned officer, personally appeared Leslie .}. Rodmond. Icno~~>» t~~ 3ne ("ar satisfactoril~~ pro~~en} to 1~c i,hc persons ~~hose dames are subscribed to the foregoing instrument and ach~~o~~,~lc;dge. iha.i s3~e executed the same for the purposes therein contained. IN lX~ITI\iESS ~~+~1-IERLOP. l herew~to set my hand and of'f`icial seal. ~ L ~ ~ ~- I~~ota~ ~ P blic ~YIy~C',onrn ~ni„~Ma tb~mbK S~ COMI~hUN~~'E.4LTI~ OF PEN]~S~'LVAI~TI/~: COL`1\TTY OF SS. On this; the ~~ day. of .200%, before me the undersi ~Tned officer. personally appeared Joshua A. Redmond, ]cno~~%n io me (or satisfactorily proven) to be the person ~~~hose name is subscribed to the foregoing instrument and ac}cnor~~led~e that he executed the same for the purposes iherei.n contained. IN V,?ITNESS ~~THEREOF, I herewrio set my hand a11d official seal. No • public ~ -------- COMMONWEALTH ur ~~r.ivS1'LVANIk Notarial Seal Joanna M. AAerridc, Notary Public South Wi~iamsport Bono, t.ycorning County My Commissiai Expires July 28, 2008 Member, Pennsylvania A?~~cia~:nn Of dot&ries n '~' .Z .W t~ ~ 0 ~_ "~ ~ na :.~ r~~ :7 -- ~~ ~~i5 -,- < <~ ~ %~3 `4 . _ ~i~~~ ,~ C.:. '4 LESLIE J. REDMOND IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOSHUA A. REDMOND DEFF.,NDANT • 2007-5154 CIVIL ACTION LAW 1N CUSTODY ORDER OF COURT AND NOW, Tuesday, December 18, 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 Wednesday, January 16, 2008 at 2:00 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. 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/ ohn .Man an 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 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. 1F 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 ~t'yu~j~ ~ ~,~1K~' J~r~pvi" T ~' I~..i.i Yi Ft_r-., V ~I ~V ~E~ ~ ~ ~~~ +~{iV C_ ~ ~/ ~ ~/ Add1.U~~1G~ilt~~d 3H1 ~4 ~~~~1~ h y. "`++ LESLIE J. REDMOND, Plaintiff v. JOSHUA A. REDMOND, Defendant Prior Judge: J. Wesley Oler, Jr., J. JAN 2 3 2DD8~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-5154 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW this ` 3 r day of January, 2008, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: Legal Custody: The Father, Joshua Redmond, and the Mother, Leslie Redmond, shall have shazed legal custody of Summer Leah Redmond, born 5/25/2005, and Aubrey Noelle Redmond, born 5/25/2005. The parties shall have an equal right to make all major non- emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regazding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each pazent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one pazent has possession of any such records or information, that parent shall be required to shaze the same, or copies thereof, with the other pazent within such reasonable time as to make the records and information of reasonable use to the other pazent. 2. Physical Custody: Mother shall have primary physical custody of the Children subject to Father's partial physical custody as follows: a. Commencing January 18, 2008 through February 22, 2008, Father shall have physical custody of the Children from Friday 2:00 pm, or as otherwise mutually agreed to, until Saturday 2:00 pm, or as otherwise mutually agreed to. Father's physical custody for this time period shall occur at paternal grandparents' or great-grandparents' residence in Cumberland County unless otherwise mutually agreed to. Transportation to and from the paternal grandparents'/ or great grandparents' residence shall be arranged between the parties as mutually agreed to. b. On Sunday, Mazch 2, 2008, Father shall have physical custody of the Children at his residence from 2:00 pm unti16:00 pm. Mother shall transport the Children to Father's residence for this visit. c. On Sunday, March 9, 2008, Father shall have physical custody of the Children from 12:00 pm unti16:00 pm. Father shall be responsible for the transportation for this visit. d. Father shall have addition periods of physical custody of the Children as mutually agreed to 3. Holidays and Birthdays: A holiday schedule shall be established on the Mazch 12, 2008 status update conciliation at 9:00 am. t.~~ ~ Y ik.ay t.~~ r 41 ~ ~ I_ tr.ir^_•~~~ L. ti~ v.~r~ f-1 (.5.... ~~. F~. C + _- .~~ ~ ~... ^ L~ t ~ j.~..! `~ 4. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties dispazage the other pazent in the presence of the Children. 6. In the event of a medical emergency, the custodial parry shall notify the other parties as soon as practicable after the emergency is handled. 7. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of 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 provision. 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. 9. A status update conciliation conference is hereby scheduled for March 12, 2008 at 9:00 am. Said conference shall be via telephone, unless the parties desire to appear in person. The purpose of said conference is to establish whether Father shall commence overnight custody of the Children at his residence and to establish a holiday schedule. The assigned conciliator shall initiate said conference. By the Court, Distribution: -~Iannah Herman-Snyder, Esquire /Melody Hanisek, Esq., 36 West Fourth Street, Williamsport, PA 17701 /John J. Mangan, Esquire ~~~,s 'aS rr~t l£~. /~~~~8 ,: .. ~. LESLIE J. REDMOND, Plaintiff v. JOSHUA A. REDMOND, Defendant Prior Judge: J. Wesley Oler, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-5154 CIVIL ACTION LAW : IN CUSTODY CUSTODY CONCII.IATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVII, 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: Name Date of Birth Currently in the Custody of Aubrey Noelle Redmond 5/25/2005 Mother Summer Leah Redmond 5/25/2005 Mother 2. A Conciliation Conference was held with regard to this matter on January 16, 2008 with the following individuals in attendance: The Mother, Leslie Redmond, with her counsel, Hannah Herman-Snyder, Esq. The Father, Joshua Redmond, with his counsel, Melody Hanisek, Esq. 3. The parties agreed to the entry of an Order in the form as attached. t ~~~ ~ ---____.. Date John . M gan, Esquire Cus dy onciliator rrat i a ~ooe ~} LESLIE J. REDMOND, Plaintiff v. JOSHUA A. REDMOND, Defendant Prior Judge: J. Wesley Oler, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-5154 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW this Zb day of Mazch 2008, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. The prior Order of Court dated January 23, 2008 is hereby VACATED. 2. Legal Custody: The Father, Joshua Redmond, and the Mother, Leslie Redmond, shall have shared legal custody of Summer Leah Redmond, born 5/25/2005, and Aubrey Noelle Redmond, born 5/25/2005. The parties shall have an equal right to make all major non- emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other pazent. To the extent one pazent has possession of any such records or information, that parent shall be required to shaze the same, or copies thereof, with the other pazent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: Mother shall have primary physical custody of the Children subject to Father's partial physical custody as follows: a. Commencing Mazch 21, 2008, Father shall have physical custody of the Children at his residence every other weekend from Friday 1:30 pm, or as otherwise mutually agreed to, until Saturday 1:30 pm, or as otherwise mutually agreed to. b. Commencing May 16, 2008, Father shall have physical custody of the Children at his residence every other weekend from Friday 1:30 pm, or as otherwise mutually agreed to, until Sunday 1:30 pm, or as otherwise mutually agreed to. c. For these custody exchanges, Father shall pick up the Children at Mother's residence on Friday and Mother shall pick up the Children at Father's residence at the end of Father's weekend custodial period. Upon mutual agreement, the parties may pick a neutral half way point between the parties' residences for the custody exchanges. d. It is understood that the Children may be starting apre-school program in the fall of 2008 and the exchange times may need to be altered. In the absence of mutual agreement, the parties may request this issue to be addressed with the assigned Conciliator. e. Father shall have addition periods of physical custody of the Children as mutually agreed to. ..;r t~ t ~~ C) C7 7 t~,_ - ~~': ~ - ~ tT. ~ i~ . LL. ~ m ay' N ~ 4. Holidays and Birthdays: a. Christmas shall be split into two twenty four hour blocks. In 2008, Father shall have the Children in the first block from 12/24 at 10:00 am until 12/25 at 10:00 am. For these exchanges, the parties shall meet on 12/24 at a mutually agreed upon half way point and Father shall transport the Children back to Mother on 12/25 by 10:00 am. The second block shall be from 10:00 am on 12/25 until 10:00 am on 12/26. In 2008, Mother shall have the second block. The parties shall reverse their respective blocks and exchange obligations in all subsequent years. b. Halloween: Should trick or treat night fall on the same night for Father's and Mother's respective communities, Father shall come to Mother's community to attend with Children and Mother. Should trick or treat night fall on different nights for Mother's and Father's respective communities, on Father's trick or treat night, Father shall pick the Children up at 1:30 pm at Mother's residence and the parties shall meet half way at a mutually agreed upon location at 1:30 pm the following day. The parties shall notify one another of their respective communities' trick or treat nights thirty days prior to the trick or treat nights. c. Birthday: Each pazent shall be entitled to enjoy one day from 10:00 am unti16:00 pm with the girls, whether on exactly their birthday or on some other mutually agreed to day. Transportation for this day shall be arranged between the parties as agreed upon. d. All other major holidays shall be alternated or shared as mutually agreed upon. 5. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 6. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties disparage the other parent in the presence of the Children. 7. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 8. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consumeibe under the influence of 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 provision. 9. Vacation: Each parent shall have two weeks of vacation with the Children per year. This vacation clause shall take effect August 30, 2008. The vacation periods shall not be consecutive for more than seven days. The requesting pazent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regulaz physical custody schedule. In the event the parties schedule conflicting vacations, the parry first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regazding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand/alter this vacation time by mutual agreement. 10. Out of state travel: Prior to departure, the parties will provide each other with information regarding the intended destination and a telephone number at which they can be reached during their absence from the Commonwealth of Pennsylvania. 11. Relocation: The parties aze litigating this custody action based upon the Mother's residence in Cumberland County, Pennsylvania. If either party intends to establish residency more than fifty (50) miles from their current residences, he or she must give to the other pazent at least sixty (60) days' written notice in advance of the proposed move, in order to allow the parties to confer prior to the move and to establish a mutually satisfactory arrangement in light of the changed circumstances. In the event the parties are unable to reach an agreement, the Court of Common Pleas of Cumberland County shall have jurisdiction over them to fashion an appropriate custody Order. 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. By the Court, Distribution: ~Iannah Herman-Snyder, Esquire Melody Hanisek, Esq., 36 West Fourth Street, Williamsport, PA 17701 /John J. Mangan, Esquire ifs iri2.~l£Cl.. 3~2vf o s ~M LESLIE J. REDMOND, Plaintiff v. JOSHUA A. REDMOND, Defendant Prior Judge: J. Wesley Oler, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-5154 CIVIL ACTION LAW : IN CUSTODY CUSTODY CONCII.IATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVII. PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Aubrey Noelle Redmond 5/25/2005 Mother Summer Leah Redmond 5/25/2005 Mother 2. A Conciliation Conference was held with regard to this matter on January 16, 2008, an Order was issued January 23, 2008 and an updated conciliation conference was held on March 12, 2008 with the following individuals in attendance: The Mother, Leslie Redmond, with her counsel, Hannah Herman-Snyder, Esq. via telephone The Father, Joshua Redmond, with his counsel, Melody Hanisek, Esq. via telephone 3. The parties agreed to the entry of an Order in the form as attached. 3 ~~ `_ Date Jo J. gan, Esq ' stod Conciliato