HomeMy WebLinkAbout07-5327IN THE COURT OF COMMON PLEAS
OF COMBERLAND COUNTY, PENNSYLVANIS
CIVIL DIVISION
CONTRACTOR: FlY~Y l~cavating, Inc.
168 W. Airport Road
Lititz, PA 17543
AND
South Middleton Township
520 Park Drive
Boiling Springs, PA 17007
M ~.~V
NON-LIEN AGREEMENT
NO.
WHEREAS, the parties hereto did on the 5th day of ~t~, 2~7 ,enter into an agreement
(hereinafter the "Contract"}, therein and whereby said Contractor undertook and agreed to furnish all
materials, labor and equipment, etc., to complete the work for Spring Meadows Park Phase 2 Utilities to the
South Middleton Park site located on State Road No. 174, Boiling Springs, PA 17007.
NOW, THEREFORE, the Contractor for itself and any and all subcontractors, materiahnen and parties
acting for, through or under the Contractor or for, through or under any of them, does covenant and agree
that it will not at any time suffer or permit any mechanics' lien or any other lien, attachment or other
encumbrance, under any laws, regulations, or orders, Federal, State or local, or otherwise by any person or
persons whomsoever, to be put or remain on the building or premises, into or upon which any work is done
or labor or materials are famished under this Contract, and the Contractor has not obtained absolute title;
and the Contractor agrees, further, that any mechanics' lien, materialmens' lien or any other lien,
attachment or other encumbrance or claim of third party, however arising (whether through the
Contractor's or Owner's or any other persons action or inaction, and whether valid or invalid), until it is
removed shall preclude any and all claim or demand for any payment whatsoever under or by virtue of the
Contract, and in the event that same is not removed, the Owner at its discretion may remove same at the
expense (including legal fees) of the Contractor, and without regard to the validity of invalidity thereofl
The Contractor expressly agrees further, that no lien shall attach to the real estate, building, structures, or
any other improvement to the Owner either on behalf of the Contractor herein or on behalf of any
subcontractor, mechanic, journeyman, laborer, materialman, or person performing improvement or
premises of said Owner, or on behalf of any other person. Neither the Contractor or any other person
supplying the materials, equipment, machinery or other property, or performing work or labor in or upon
the building or the work, included in this Contract shall have the right to file a mechanic's lien against the
building or premises.
Contractor warrants and represents that at the time of execution hereof no work of any kind has been done
and no materials of any kind have been furnished, delivered or ordered in connection with the performance
of this Contract of any supplemental contract of extra work.
This stipulation and waiver is made and intended to be filed with the Cumberland County Prothonotary
within ten (10) days after the date hereof, in accordance with the requirements of Act of Assembly of
Pennsylvania, in such case provided.
In WITNESS WHREOF, we have hereunto set our hands and seals, intending thereby to become legally
bound this 6th day of Septet[Iber , 20 07.
Wittlinger 1~am Removal
Yellow Breeches Creck
Boiling Springs, Cumberland County, PA
OWNER:
South Middleton Township
500 Park Drive
Boiling Springs, PA 17007
CONTRACTOR:
Flyway E~ccavating, Inc.
BY:
Bradf C7.ta}ab
President
Wittlinger Dam Removal
Yellow Breeches Creek
Boiling Springs, Cumberland County, PA
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SCOTT D. HALDEMAN, IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. OS-5327
DEBRA S. HALDEMAN, :CIVIL ACTION -LAW
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, upon consideration of the attached complaint, it is hereby directed that the
parties and their respective counsel appear before ,the
Conciliator on the day of , 2007 at .m., at
Carlisle, Pennsylvania, for a 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.
~~
FOR THE COURT,
Date of
Order:
BY:
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FROTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE PA 17013
(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. 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.
SCOTT D. HALDEMAN, IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
w. N0.05-5327
DEBRA S. HALDEMAN, :CIVIL ACTION -LAW
Defendant IN DIVORCE & CUSTODY
PETITION TO MODIFY CUSTODY
1. Petitioner is Scott D. Haldeman, (hereinafter referenced as "Petitioner"), Father of the
children, Aubriana L. Haldeman, born April 17, 1997 and Karina W. Haldeman, born September
11, 2002; Petitioner currently resides at 30 Spring Garden Estates, Carlisle, Cumberland County,
Pennsylvania 17013.
2. Respondent is Debra S. Haldeman, (hereinafter referenced as "Respondent"), Mother
of the children, Aubriana L. Haldeman and Karina W. Haldeman, and Defendant in the above-
captioned matter; Respondent currently resides at 120 Hope Drive, Boiling Springs, Cumberland
County, Pennsylvania 17007.
3. The children, Aubriana L. Haldeman ,was born on April 17, 1997, and is ten (10)
years of age and Karina W. Haldeman, was born September 11, 2002, and is five (5) years of age,
(hereinafter referenced as "Children") presently reside with Mother at 120 Hope Drive, Boiling
Springs, Cumberland County, Pennsylvania 17007.
4. An Order of Court dated June 6, 2006, issued by the Honorable M. L. Ebert, Jr.,
granted Petitioner and Respondent shared legal custody of the Children and primary physical
custody with Respondent. A copy of said Order is attached hereto as Exhibit "A" and is
incorporated herein by reference.
5. The parties' residence has remained unchanged since the entry of the aforementioned
Order of Court.
6. Father has not been able to enjoy the custodial periods as set forth in the Custody
Order due to Mother's actions, as described more fully below.
7. Mother has not encouraged a normal relationship between the minor children and
Father.
8. Mother has consistently spoken to the children in a manner which is designed to make
them afraid of father, including but not limited to, telling the children that they are unsafe with
Father when he is driving.
9. Children, as a result of Mother's consistent haranguing concerning the Father and his
driving ability, are unreasonably fearful around Father concerning his driving.
10. Father believes and therefore avers that it is Mother's intention to continue this
course of action such that Father shall have no reasonable opportunity to continue a normal
Father-Child relationship with his children.
11. Father has driven with his children in the car countless times since the beginning of
this case on October 12, 2005, all without incident.
12. Father has recently been awarded the Certificate of Safe Driving from ABF, his
employer, and has been given a two (2) year safe driving award.
13. Father continues to drive for a living.
14. Mother has acted in a controlling manner, such that she has not discussed with Father
the amount of time which he may be able to have with the Children during his free time but,
rather, has consistently dictated to Father what she will permit him to have with his Children.
See Exhibit "B" attached hereto.
15. Mother has claimed to this Honorable Court, in a letter which was forwarded to my
office from this Honorable Court on November 5, 2007, that Father was not using his CPAP
device for sleeping; This is simply false. A copy of said letter is attached hereto as Exhibit "C"
and is incorporated herein by reference.
16. Mother is extremely controlling concerning father driving with the children.
17. Father notified his employer, ABF, of his sleep apnea condition.
18. Mother, in the aforementioned letter, claimed that Father's testimony was perjury
without any proof thereof, showing that she is not carefully controlling her words to this
Honorable Court.
19. Mother claimed that Father "ran into the back of someone's vehicle, due to following
too close, no doubt due to drowsy driving." This is simply not true and Mother has offered no
evidence thereof. This statement is another example of Mother's lack of control of her own
actions.
20. Father believes and therefor avers that Mother is consistently asking the Children
concerning Father's activities at his home; she recites in her letter to this Honorable Court that
the youngest children "Feel a heavy burden of wanting to believe her father but knowing that he
can not stay awake." This statement presumes to know a great deal without offering any proof
thereof whatsoever.
21. The detailed information contained in the second full paragraph on Page Two of the
aforementioned letter shows that Mother is having detailed discussions with her Children
concerning Father's behavior. Father presents this as further evidence of Mother's lack of control
and paranoia concerning these issues.
22. Father has consistently stayed within this Honorable Court's Order of July 11, 2006
concerning the driving restrictions placed on him. A copy of the July 1 1, 2006 Order is attached
hereto as Exhibit "D" and is incorporated herein by reference.
23. Mother has not consistently kept Father informed concerning the Children's medical
appointments.
24. Mother has attempted in every conceivable way to alienate Father from his Children.
25. Father believes and therefor avers that Mother's concerns over Father's former
medical condition are completely out of control and lacking touch with reality.
26. Mother consistently has taken actions which slow down the process of finalizing the
Divorce and has not cooperated with her own counsel or opposing counsel with a view to
finalizing the Divorce.
27. Mother has not cooperated with Father or worked together with Father in order to
allow Father to continue his normal paternal relationship with his Children.
28. Father believes and therefor avers that Mother has told the Children that Father is not
safe to be around.
29. This case has had previous ruling issues by the Honorable M. L. Ebert, Jr.
30. Plaintiff s counsel has sought concurrence from opposing counsel, Leslie Beam,
Esquire concerning the filing of the present action. Attorney Beam does not concur with the
filing of the Petition to Modify Custody.
WHEREFORE, Plaintiff respectfully requests the following:
1. Father be awarded primary physical custody of the Children;
2. That Mother be ordered to submit to psychological evaluation and appropriate
treatment;
3. That Mother be ordered to refrain from telling her children that Father is an unsafe
driver or an unfit Father;
4. Award Mother periods of partial physical custody as the parties agree, but not less
than every other weekend.
Date: ~
Respectfully submitted,
~~,
Mark A. Mateya, quire
Attorney ID No. 78931
P.O. Box 127
Boiling Springs, PA 17007
(717) 241-6500
(717) 241-3099 Fax
Counsel for Petitioner
VERIFICATION
I, Scott D. Haldeman, verify that the facts set forth in the foregoing pleading are true and
correct to the best of my knowledge, information, and belief. I understand that false statements
herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to
authorities.
DATED: ' v~ f ~' d
Scott D. Haldeman
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RECEIVED MAt~{~~ ~.rvL
SCOTT D. HALDEMAN,
Plaintiff
V.
DEBRA S. HALDEMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.2005-5327 CIVIL ACTION -LAW
IN CUSTODY
e
ORDER OF COURT
AND NOW, this ~ day o , 2006, upon
consideration of the attached Custody Conci iation Report, it is ordered and directed as
follows:
1. A Hearing is sched led in Co rt R m No. ~ , of the Cu berl nd
County C rt House, on the day of , 2006, at
o'clock, ~. M., at which time testimony will be to n. For purposes of this Hearing,
the Father shall be deemed to be the moving party a shall proceed initially with
testimony. Counsel for each party shall file with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of witnesses who will
be expected to testify at the Hearing and a summary of the anticipated testimony of each
witness. These Memoranda shall be filed at least ten days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the prior Order
of Court dated February 2, 2006 shall remain in full force and effect with the following
modifications:
3. Paragraph 3A(1) is deleted.
4. Paragraph 3A(5) is deleted and replaced with the following: "One
overnight per week as Father's schedule permits."
5. Paragraph 3A(6) is deleted and replaced with the following: "During the
summer every Tuesday unless Mother is off from work."
6. Paragraph 3 B(1)-`Monday' shall be replaced with `Tuesday.'
7. Paragraph 3B(5) shall provide "One overnight per week when Karina is
ready and Father's schedule permits."
8. Paragraph 4 shall be deleted in its entirety.
J~
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9. The parties may modify this Order by mutual agreement. In the absence
of mutual consent, the terms of this Order shall control.
BY THE COURT,
Jn r
M. L. Eb rt, Jr., J.
cc: Mark Mateya, Esquire, counsel for Father
Lindsay D. Baird, Esquire, counsel for Mother
TREE CoP~r FRoM~-RECORD
~T mcyny wh:~r~~f,, t hero unto:~set my T~anti
e i of rtisle, Pa.
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SCOTT D. HALDEMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V• : N0.2005-5327 CIVIL ACTION -LAW
DEBRA S. HALDEMAN, : IN CUSTODY
Defendant
PRIOR JUDGE: M. L. Ebert, Jr., J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Aubriana L. Haldeman April 17, 1997 Mother
Karina W. Haldeman September 11, 2002 Mother
2. A Conciliation Conference was held May 23, 2006 with the following
individuals in attendance: The Father, Scott D. Haldeman, with his counsel, Mark
Mateya, Esquire, and the Mother, Debra S. Haldeman, with her counsel, Lindsay D.
Baird, Esquire.
3. The Honorable M. L. Ebert, Jr. previously entered an Order of Court on
February 2, 2006 providing for shared legal custody, Mother having primary physical
custody and Father having periods of partial physical custody. The Order restricted
Father from driving the children more than a 15-mile radius from his home.
4. Father's position on custody is as follows: The only issue for
determination is whether the restriction on driving should continue. Father was
previously diagnosed with Sleep Apnea, causing him to fall asleep while driving. Father
asserts that he uses his mechanical sleep device while at home, but not while he is away
from home, working. Father is a long haul truck driver. His employer is aware of his
medical condition. Father asserts that he has not fallen asleep at the wheel and presents
his driving logs to prove that he is driving and has had no accidents.
5. Mother's position on custody is as follows: Mother is concerned about the
safety of the children and believes that Father should use his sleeping device every night
yam:
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as it is more effective when used daily. Mother requests that the driving restriction of no
more than a 15-mile radius from home continue until Father proves he is using the device
daily and is not a safety concern to the children.
6. The Conciliator recommends an Order in the form as attached scheduling
a Hearing and granting the parents shared legal custody, Mother primary physical
custody and Father periods of partial physical custody. It is expected that the Hearing
will require one-half day.
Date acq line M. Verney, Esquire
Custody Conciliator
Comcast ~Vebmail -Email Message Page 1 of 1
From: DEBAUBKAR@aol.com
To: ttraveler3@comcast.net
Subject: Re: (no subject)
Date: Monday, October 29, 2007 7:59:07 PM
PAY AT"T"ENTION:
AUBRI'S CLASS STARTS AT 6:45, SO THAT IS WHEN WE ARRIVED!!!!!!-!!!!!
KARINA WAS NOT FEELING WELL, SO SHE DIDN'T GO TO HER CLASS TONIGHT, BUT THAT
WOULD NOT HAVE PERTAINED TO YOU.
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Comcast Webmail -Email Message Page 1 of 1
From: DEBAUBKAR~aol.com
To: ttraveler3(c~comcast.net
Subject: Re: (no subject)
Date: Monday, November 05, 2007 5:18:02 PM
Tomorrow I have the day off. The girls will be with me all day and evening.
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Comcast ~~Iebmail -Email Message Page 1 of 1
From: DEBAUBFCAR~aol.com
To: ttraveler3 at~comcast.net
Subject: Re: (no subject)
Date: Monday, November 05, 2007 8:13:22 PM
Scott:
You seem to always want to follow certain parts of the Court Order and only when it suits you.
If you want to add some time on the weekend, we take from the week. Otherwise, we follow the COURT
ORDER, which indicates you are to have them one overnight.
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~omcast ~JVebmail -Email Message Page 1 of 1
From: DEBAUBKAR@aol.com
To: ttraveler3@comcast.net
Subject: (no subject)
Date: Monday, November 05, 2007 5:28:37 PM
For as long as you are on this new shift, we will do away with Tuesday evening visits, as you will have
extra time on the weekend.
I would like the girls to be home just before lunch or before Karma's nap on Sunday. You pick "both" up
on Friday after I get home from work; I will pick both up on Sunday.
Deb
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t;omcast vVebmail -Email Message Page 1 of 1
From: DEBAUBKAR~aol.com
To: ttraveler3~comcast.net
CC: Ibeam a~kopelaw.com
Subject: (no subject)
Date: Friday, October 19, 2007 5:35:58 PM
Scott:
You have continued to come in my house without permission nor prior notice to me. This has continued
despite my continuous and repeated requests for some courtesy, respect, consideration. Yes, indeed,
your name is still on this mortgage. However, you have not lived here for almost TWO years. This is my
Dome. You have your own home. I deserve privacy and respect.
The neighbors report to me frequently that you are here.
You took advantage of knowing when the girls and I were making a trip to visit my family mid
September, and decided that was a perfect opportuntity to come in here and take whatever you wanted.
I have no problem with you having things that belong to you. There is a proper manner that should be
taken for you to acquire things that you have nat previously. And, as you know, as I have been going
through things in the house, I have been giving you things that belong to you.
I do have a problem with you deciding, after two years, that maybe you are entitled to things that I may
be using. That is stealing, in my opinion.
It is a HUGE violation, in my opinion, for you to be an opportunist on your day off, but my work day, to
again violate my home. (today, as an example)
Aubri should NOT be reporting, nor the neighbors, that you had been in the house quite some time
before she got off the bus.
Also, Friday is not a visitation day for you, and my home is not your visitation sight. You have no
business being here, without my knowledge nor permission.
Lesley:
I am sending you a copy of this a-mail, because this has gone on way too long. If he doesn't stop, and
stop immediately, I am asking you to seek a Court Order to keep him out of this house.
Deb Haldeman
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RECEfVED I!Q`; ~ ~ 200
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COMMONWEALTH OF PENNSYLVANIA
NINTH .1UDICIAL DISTRICT
CUMBERLAND COUNTY
M. L. EBERT, JR. COURTHOUSE
JUDGE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013-3387
(717) 240-6292
FAx (717) 240-6460
November 5, 2007
Shane B. Kope, Esquire
4660 Trindle Road
Suite 201
Camp Hill, PA 17011
Mark Mateya, Esquire
P. O. Box 127
Boiling Springs, PA 17007
Re: Scott Haldeman v. Debra Haldeman
05-5327 Civil
Gentlemen:
Enclosed please find a letter just received by Judge Ebert.
Very truly yours,
~~~ ~
Beth A. Stambaugh
Administrative Coordinator
Enclosure
r'
U
Gil~r ~
The Honorable Skip Ebert, Judge
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Dear Judge Ebert:
Re: Haldeman case
Each time my children ai•e sent fot- a visit with their father, I
wonder if that will be that last time that I see them alive. Because, as you
know, Scott Haldeman has severe sleep apnea. Despite this and despite a
history of not following medical advice, and testimony from Scott himself that
he doesn't use the CPAP because "he doesn't like it", he was given increased
travel with his daughters. This is a nightmare that I live with every day, and
never expected that a Coui•t of la~~, designed to protect children, would put
their lives at risk.
I love my children more than you will ever know. This situation has
been eating away at me. I lived «~ith Scott Haldeman for ten years. I know
him; I know «~hat he is all about. I testified that Scott was not able to stay
awake in a car for longer than ten to fifteen minutes. My testimony was the
truth. However, it didn't seem to matter «~ho was mo1-e credible or
1•esponsible when the Order ~-as dictated. I was the driver in our family for•
ten years. Scott started professional truck driving, after- our separation. I
immediately notified my attorney out of feal• for public safety. Scott testified
that his trucking company knew that he had sleep apnea and still allowed him
to drive. It was a lie. He hid his illness from his company and put the public
at risk. In fact, most of Scott's testimon~~ vc~as perjury. 1'et, it didn't matter.
T'he lives of these girls did not matter. That keeps going through my mind
ever since that hearing, of which I will never forget, and never understand. I
can not understand how it is that the lives of these children did not matter. I
could not believe it was happening; I still can not believe it.
Haldeman
Page two
Scott has had a couple accidents since oul• separation. He ran into
the back of someone's vehicle, due to following too close, no doubt due to
drowsy driving; and he 1•an into a cul•b, causing his tii•e to be shredded, also
no doubt due to di•ovvsy driving.
I am told by my daughters i-egulai•ly that he does not use his cpap
machine. He tells my youngest it is because he doesn't snore anymore. This
isn't even about snoring. It is about episodes of not breathing throughout the
night that deprives his brain of oxygen. My oldest daughter, who is only ten,
feels a heavy burden of wanting to believe her father but knowing that he can
not stay awake. She tries her hardest to keep conversation going in the car so
that he stays awake. She gets tired herself---she is a child. She is also in the
back seat, and is not always aware that he is stal-ting to nod off, until it is too
late. She, being a child, also enjoys playing while she is a passenger in a car.
She can not be responsible to keep her and her sister from being killed. That
should be the responsibility of her parent.
Please advise me as to what I am supposed to do. I can not sit back
just waiting for something tet•rible to happen to my children. How can I live
with that? There were no safeguards established for these precious girls. In
fact, there was not even a conversation with a physician as to the seriousness
of the issue, despite my attempts to provide that. There was not even the
opportunity provided to verify he was in treatment for his sleep apnea prior to
the Order being entered. At the. court hearing, he was not in treatment, and
testified to the fact. Yet, his travel v~~ith the girls was expanded. I do not even
know if there is currently an established physician of «~hom I could report my
concerns. I was left with nothing, no v~~ay to protect these girls. The only
thing that I was left with is knowing that each time these girls go for a visit
«~ith their father and he travels ~-ith them, he puts their lives at risk, with the
blessing of the Cumberland County Coul•t.
Page thl-ee
Haldeman
Please, I am asking for something that I can do to protect them. I need to
know where he is supposed to be betting treatment so that I can notify his
physician of his continued lack of compliance. I need something.
Sincerely,
~ I~~ ~ OLQd~~a.r~.
Debra S. Haldeman
SCOTT D. HALDEMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5327 CIVIL
V.
CIVIL ACTION -LAW
DEBRA S. HALDEMEN,
Defendant 1N CUSTODY
ORDER OF COURT
AND NOW, this 11th day of July, 2006, after hearing in the above-captioned
matter, the following temporary order is entered:
1. The Father will be allowed to drive a motor vehicle in which his children are
passengers within 40 miles of his home.
2. The Father is directed to submit to a new medical evaluation regarding his
sleep apnea problem. The evaluation should include specific recommendations
regarding the effect that sleep apnea may have upon Scott D. Haldeman's ability to
safely operate a motor vehicle.
3. Counsel for the parties shall attempt to reach an agreement with regard to
those practices which Scott D. Haldeman could take prior to and during extended motor
vehicle trips with his children. Should no agreement be reached, each party shall submit
its proposed safety conditions to the Court on or before July 28, 2006. .
By the Court,
M. L. Ebert, Jr., J,
Mark A. Mateya, Esquire
Attorney for Plaintiff
Lindsay D. Baird, Esquire
Attorney for Defendant
bas
r~uE C~oPY FROM RECORE~
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~ ~ ~ ~ ~ Gerlic~, Alt.
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Prothonalwrv
CERTIFICATE OF SERVICE
I, hereby certify that I have served a copy of the foregoing Petition to Modify Custody
was filed on the following person(s) by depositing a true and correct copy of the same in the
United States Mail, first class, postage prepaid, at Boiling Springs, Cumberland County,
Pennsylvania addressed to:
Leslie J Beam Esq.
Kope & Associates LLC
4660 Trindle Road Ste 201
Camp Hill PA 17011
~.
Mark A. Mateya, E uire
Attorney ID No. 78931
Post Office Box 127
Boiling Springs, PA 17007
(717) 241-6500
Date: ~ Z~ ~
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