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HomeMy WebLinkAbout07-61761 0, I r '• CHRISTOPHER HERBERT LAUGHMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW IN CUSTODY ANGELA LYNN RAU, Defendant NO. 07 - Co >7L CIVIL TERM COMPLAINT IN CUSTODY The Plaintiff, Christopher Herbert Laughman, pro se, sets forth the following cause of action in custody. 1. The plaintiff, Christopher Herbert Laughman, resides at 18 West Main Street, Plainfield, Cumberland County, Pennsylvania 17081. 2. To the best of Plaintiffs knowledge, Defendant, Angela Lynn Rau, currently resides with her parents at their residence located at 114 South Ridge Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. Plaintiff seeks primary custody of Name Present Residence AAee Tyler Mitchell Laughman 18 West Main Street 6 months old Plainfield, PA 17081 (DOB: 4/08/2007) The child was born out of wedlock. 4. The child is presently in the custody of Plaintiff, who resides at 18 West Main Street, Plainfield, Cumberland County, Pennsylvania 17081. During the past five years the child has resided with the following persons at the following addresses: Address 18 West Main Street Plainfield, PA Dates April 8, 2007 (child's birth) to September 15, 2007 Persons Plaintiff and Defendant 18 West Main Street Plainfield, PA September 16, 2007 to the present Plaintiff 0 0- The mother of the child is Angela Lynn Rau. She is single. The father of the child is Christopher Herbert Laughman. He is single. 5. The relationship of Plaintiff to the child is that of Father. The plaintiff currently resides with the following persons: Name Relationship Tyler Mitchell Laughman son 6. The relationship of Defendant to the child is that of Mother. Plaintiff has no knowledge with whom Defendant may currently reside. 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 8. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth, or any other state. 9. Plaintiff does 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 interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff has been the child's caretaker for most of the child's life; b. Plaintiff has and will continue to provide the child with a stable home and environment, including but not limited to, moral, emotional, and physical surroundings as required to meet the child's needs, and c. Plaintiff will permit reasonable supervised contact between Defendant and the child at times mutually agreed upon by the parties. 11. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. 1 '0- ¦ 7V WHEREFORE, Plaintiff requests the court to grant him shared legal custody and primary physical custody of the child, with Mother having supervised visitation at times mutually agreeable to the parties. Respectfully submitted, Christopher Herbert Laughman, Plaintiff, pro se 18 West Main Street Plainfield, PA 17081 (717) 249-8186 I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.§4904 relating to unsworn falsification to authorities. C stopher Herbert Laughman, Plaintiff, pro se .t 1h? rv CZ) `h ? 1 H. LAUGHMAN, V. ANGELA L. RAU, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 6176 CIVIL TERM IN CUSTODY PETITION FOR CUSTODY AND N and presents thf The Pe Road, Boiling The West Main The I born April 8, JV comes the Petitioner, Angela L. Rau, by her attorneys, Irwin & McKnight, >llowing Petition for Custody. 1. ioner, Angela L. Rau, is an adult individual with an address of 114 South Ridge prings, Cumberland County, Pennsylvania 17007. 2. )ondent, Christopher H. Laughman, is an adult individual with an address of 18 I, Plainfield, Cumberland County, Pennsylvania 17081. 3. ies are the natural parents of one (1) child, namely, Tyler Mitchell Laughman, 4. The Petitioner, Angela L. Rau, desires that the parties have shared legal custody of the minor child, Tyler Michell Laughman. 5. The Peti with periods of parties can , Angela L. Rau, desires primary physical custody of the said minor child rary physical custody to Respondent, Christopher H. Laughman, as the 6. The best the Petitioner's i pnmary pn,, herein, with provided he. ;s and permanent welfare of the minor child requires that the Court grant as set forth above. ORE, the Petitioner, Angela L. Rau, respectfully requests that she be awarded custody and shared legal custody of Tyler Michell Laughman as provided is of temporary physical custody to Respondent, Christopher H. Laughman, as By: Respectfully submitted, IRWIN & McKNIGHT A.'\VIcKnight, III, Esquire 60 West P fret Street Carli , ennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 Date: October 26, 2007 VERIFICATION The fors by counsel and document and 1 understand that 4904, relating ti ig Complaint for Custody is based upon information which has been gathered elf in the preparation of this action. I have read the statements made in this are true and correct to the best of my knowledge, information and belief. I statements herein made are subject to the penalties of 18 Pa. C.S.A. Section unsworn falsification to authorities. ijaA L. Rau Date: October 26, 2007 ? ?_ ? ? ? . ?:. ? =? ? ,? ?? ? ?? ? y N _ r ?l C3? ??? : - +..% ?r? - '1 r ? - : ? ??"i"V i ? ? t, Y'`'om CHRISTOPHER HERBERT LAUGHMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ANGELA LYNN RAU DEFENDANT 2007-6176 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Friday, October 26, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, November 20, 2007 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or pennanent 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/ ac ueline M. Verne Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ajj'?i 4?7 C4 16-r- O/ v?- {f,,yyv Div L 'I :Z HI 6Z 30 COOZ CHRISTOPHER H. LAUGHMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2007-6176 CIVIL ACTION LAW ANGELA L. RAU IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, October 31, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, November 20, 2007 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ac uc ne M. Verne 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 iv % I A DEC 0 4 2001 CHRISTOPHER HERBERT LAUGHMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. ANGELA LYNN RAU, Defendant : NO. 2007-6176 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this G4- day of 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is sche?led in Court Room No., of the Cumberland County Court House, on the A9 day of 2008, at ? 3e o'clock, _/?. M., at which time testimony will be taken. or purposes of this Hearing, the Father shall be deemed to be the moving party and 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 following shall remain in full force and effect. 3. The Father, Christopher Herbert Laughman and the Mother, Angela Lynn Rau, shall have shared legal custody of Tyler Mitchell Laughman, born April 8, 2007. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his 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 child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. r L 0 '0I R L- 33010OZ 4. The parties shall share physical custody on a week on/week off basis. The exchange day and time shall be Mondays at or before 9:00 a.m. Mother shall have the first week, beginning December 3, 2007 and the parties shall alternate on a weekly basis thereafter. Pick up and drop off shall be that the parties' respective baby sitters. The receiving party shall transport. 5. Christmas, 2007 shall be shared such that Father shall have physical custody of the child from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon and Mother shall have physical custody from 12:00 noon on Christmas Day to December 26 at 12:00 noon. The relinquishing party shall transport to parent's residence. 6. Neither party may relocate the child outside of the jurisdiction without prior Order of Court. In the event that a party wishes to visit outside of the jurisdiction, at lease 24 hour notice must be given to the non-custodial parent with a telephone number and location where the child will be. 7. 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, cc: Hannah Herman-Snyder, Esquire, counsel for Father Marcus A. McKnight, III, Esquire, counsel for Mother > 'I I td,_ /a/ Ile 7 tT-07 .DEC. 0 4 2001 CHRISTOPHER HERBERT LAUGHMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ANGELA LYNN RAU, Defendant PRIOR JUDGE: None NO. 2007-6176 CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tyler Mitchell Laughman April 8, 2007 Father 2. A Conciliation Conference was held December 3, 2007 with the following individuals in attendance: The Father, Christopher Herbert Laughman, with his counsel, Hannah Herman-Snyder, Esquire, and the Mother, Angela Lynn Rau, with her counsel, Marcus A. McKnight, III, Esquire. 3. Father's position on custody is as follows: Father seeks shared legal and primary physical custody. Father asserts that Mother abandoned the family residence leaving the baby behind. Father claims to have offered visitation time to Mother but she has only accepted the time sporadically. Father maintains that he has been the primary caregiver to the child. 4. Mother's position on custody is as follows: Mother seeks shared legal custody and primary physical custody. She asserts that Father works until 11:00 p.m. and his parents are caring for the child. 5. The Conciliator recommends an Order in the form as attached scheduling a Hearing and ordering shared legal custody and shared physical custody on a week on/week off basis. It is expected that the Hearing will require one-half day. 8-y o7 Date acq line M. Verney, Esquire 61 Custody Conciliator CHRISTOPHER HERBERT LAUGHMAN,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-6176 CIVIL ACTION - LAW ANGELA LYNN RAU, IN CUSTODY Defendant PRIOR JUDGE: KEVIN A. HESS PETITION TO WITHDRAW AS COUNSEL AND NOW comes Petitioner, Hannah Herman-Snyder, Esquire, counsel of record for the above-named Plaintiff, Christopher Herbert Laughman, and petitions the Court as follows: 1. Petitioner is the attorney of record for the above named Plaintiff, Christopher Herbert Laughman, having entered her appearance by attending a conciliation conference on or about December 3, 2007. 2. A conciliation conference was held in regards to the above captioned matter on or about December 3, 2007, after which an Order was entered on December 6, 2007 scheduling a hearing for February 29, 2008 at 1:30 p.m. in Courtroom Number 4 of the Cumberland County Courthouse. 3. As of February 8, 2008, Plaintiff, Christopher Herbert Laughman, has informed Petition that he no longer wishes to retain her services and that he wishes for Petitioner to withdraw as counsel. 4. To the best of Petitioner's knowledge, Plaintiff does not seek a continuance in the matter scheduled for February 29, 2008 at 1:30 p.m. in Courtroom Number 4 of the Cumberland County Courthouse. 5. The Honorable Kevin A. Hess signed the Order of December 6, 2007 scheduling a hearing for February 29, 2008 at 1:30 p.m. in Courtroom Number 4 of the Cumberland County Courthouse. 6. Petitioner contacted Marcus A. McKnight, 111, Esquire, counsel for Defendant, and Attorney McKnight does not oppose Petitioner's request to withdraw as counsel for Plaintiff. 7. Plaintiff's mailing address is: P.O. Box 32 Plainfield, PA 17081 WHEREFORE, Petitioner requests this Honorable Court enter an Order whereby leave is granted to Petitioner, Hannah Herman-Snyder, Esquire, to withdraw her appearance, in the above-captioned matter, and whereby Plaintiff, Christopher Herbert Laughman, shall proceed pro se until such time as another attorney enters an appearance on his behalf. Respectfully submitted, N (a ?hrL ?!yma0,-L.?111a '1 Hannah Herman-Snyder, EsquA GRIFFIE AND ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)-243-5551 (800)-347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: %sibJ--A L NJ din' X1.1\ HANNAH HERMAN-SNYDEA, ESQUIRE CHRISTOPHER HERBERT LAUGHMAN,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-6176 CIVIL ACTION - LAW ANGELA LYNN RAU, IN CUSTODY Defendant PRIOR JUDGE: KEVIN A. HESS CERTIFICATE OF SERVICE I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the 11th day of February, 2008, cause a copy of Petitioner's Petition to Withdraw as Counsel to be served upon Defendant, via her attorney, and Plaintiff by first-class mail, postage prepaid, at the following addresses: Christopher Herbert Laughman P.O. Box 32 Plainfield, PA 17081 Marcus A. McKnight, III 60 West Pomfret Street Carlisle, PA 17013 DATE: - I1- 01 ` 4Am k\- O Hannah Herman-Snyder, Esqui e Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 C'a rv CZ5 cx*a - tzr rTi A y ?.. A d..A { r Ul 1 CIO f FEB 18 2008 CHRISTOPHER HERBERT LAUGHMAN,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-6176 CIVIL ACTION - LAW ANGELA LYNN RAU, IN CUSTODY Defendant PRIOR JUDGE: KEVIN A. HESS ORDER OF COURT AND NOW, this i3 'day of February 2008, upon consideration of the attached Petition to Withdraw as Counsel, it is hereby ORDERED AND DECREED that leave is granted to Petitioner, Hannah Herman-Snyder, Esquire, to withdraw her appearance, in the above-captioned matter. Effective upon the execution of this Order, Plaintiff, Christopher Herbert Laughman, shall proceed pro se until such time as another attorney enters an appearance on his behalf. By the Court, Cc: ? Christopher Herbert Laughman Plaintiff Hannah Herman-Snyder, Esquire Attorney for Plaintiff Marcus A. McKnight, Esquire Attorney for Defendant I a/l3lo ? Cl) ta. ,4 CHRISTOPHER H. LAUGHMAN, Plaintiff V. ANGELA L. RAU, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-6176 CIVIL CIVIL ACTION - LAW PRAECIPE FOR WITHDRAWAL OF COUNSEL AND APPEARANCE OF COUNSEL TO THE PROTHONOTARY: Please note my withdrawal as counsel for the Plaintiff in the above-captioned matter. Dated: BY: -- Hannah Herman-Snyder, squire Griffie & Associates 200 North Hanover Street Carlisle, Pennsylvania 17013 Kindly enter my appearance on behalf the Plaintiff in the above-captioned matter. Dated: I - I L - 000 BY: 4 ichael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 C°a ^' T, M t S' ' t r YkVyI CHRISTOPHER H. LAUGHMAN, Plaintiff V. ANGELA L. RAU, Defendant CIVIL ACTION - LAW MOTION FOR CONTINUANCE OF CUSTODY HEARING AND NOW, comes Christopher H. Laughman, by and through his attorney, Michael A. Scherer, Esquire, and respectfully represents as follows: 1. Christopher H. Laughman is the father in this custody case and undersigned counsel is in the process of entering his appearance in this matter on behalf of father. 2. Angela L. Rau is the mother of the child, Tyler Laughman, born April 8, 2007. Mother is represented by Marcus McKnight, Esquire. 3. A hearing has been set in this matter for February 29, 2008 at 1:30 p.m. before this Honorable Court. 4. Undersigned counsel is out of town on the date of the hearing and is new to the case and requested of opposing counsel that the matter be continued. 5. Opposing counsel refuses to extend the courtesy of a continuance to IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-6176 CIVIL undersigned counsel without imposing ridiculous conditions. I- w WHEREFORE, undersigned counsel requests this Honorable Court grant him the courtesy of a continuance of the hearing set for February 29, 2008 and set a new hearing for a time when undersigned counsel may be present to represent his client. Respectfully submitted, O'BRIEN, BARIC & SCHERER Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dir/domestic/laughman-chris/continuance.mot CERTIFICATE OF SERVICE I hereby certify that on February 21, 2008, I, Jennifer S. Lindsay, secretary at O'Brien, Baric & Scherer, did serve a copy of the Motion For Continuance Of Custody Hearing, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Marcus A. McKnight, III, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, Pennsylvania 17013 jVij6nkif)(51. Lind y ,-- _ ?;:'s ? _? 4_ :? .,.,-z . ? _ ? T?,, ? ?-? ?? r: .,`--;, ;M.,;; BY THE COURT, • FS 22 200 V ' CHRISTOPHER H. LAUGHMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007-6176 CIVIL ANGELA L. RAU, CIVIL ACTION - LAW Defendant ORDER OF COURT AND NOW, this day of , 2008, upon consideration of the 61 attached Motion For Continuance Of Custody Hearing, the hearing scheduled in this matter for Friday, February 29, 2008 at 1:30 p.m. is hereby continued the olnd day of , 2008, at 3 O e-m./p.m. in Courtroom No. ?- of the Cumberland County Courthouse, Carlisle, Pennsylvania. /Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, Pennsylvania 17013 Marcus A. McKnight, 111, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, Pennsylvania 17013 COP t ?-s ,n a t L(- i-' ^. 22"T ED` 26 L. t7 1 3 i.f' t i Lw CHRISTOPHER H. LAUGHMAN IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 07-6176 CIVIL ANGELA LYNN RAU, Defendant ORDER AND NOW, this Z'1' day of February, 2008, hearing in the above-captioned matter set for April 2, 2008, is continued to Friday, April 25, 2008, at 9:00 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. BY THE COURT, Michael A. Scherer, Esquire For the Plaintiff ,/Marcus McKnight, III, Esquire For the Defendant Am ? Co t £S "%>_t U /? os r'?tt Ali va 3i-li. -?l} CHRISTOPHER H. LAUGHMAN IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW ANGELA LYNN RAU, NO. 07-6176 CIVIL Defendant ORDER AND NOW, this day of March, 2008, hearing in the above-captioned matter set for April 25, 2008, is continued to Wednesday, May 28, 2008, at 1:30 p.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. " Michael A. Scherer, Esquire For the Plaintiff Marcus McKnight, III, Esquire For the Defendant :rlm C6P ? €s /n?at LEC BY THE COURT, S ' J L I M RQOZ Az? Ji v' ?iHi JO V CHRISTOPHER H. LAUGHMAN IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 07-6176 CIVIL ANGELA LYNN RAU, Defendant ORDER AND NOW, this S ` day of June, 2008, following hearing with respect to the child, Tyler Mitchell Laughman, born April 8, 2007, it is ordered and directed that: 1. The father and the mother shall share legal custody of Tyler. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well being including, but not limited to, all decisions regarding his 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 child including, but not limited to, medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical treatment planning meetings and evaluations with respect to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority, and copies of any reports given to them as parents including, but not limited to, medical records, birth certificates, school or educational attendance records, or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school VWAIASNN.3d kwX-) elNg1 !4:-:KW ? S :11 WV S- Nnr soot AWIO d+ HiOdd 3HI 3o1Af-1--rl1y pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights and the like. 2. The parties shall share physical custody with custody being in the father from Sunday at 1:00 p.m. until Tuesday prior to the commencement of his work shift. During the remainder of the week, custody shall be in the mother. 3. The mother and the father shall each be entitled to one week each year of uninterrupted custody with the child during that parent's vacation from work provided notice of same is given to the other parent at least thirty (30) days prior to the exercise of said weekly period. 4. The parties shall alternate the period from Christmas Eve at 12:00 noon until Christmas Day at 12:00 noon, and Christmas Day at 12:00 noon until December 26th at 12:00 noon, commencing in 2008 with the period from Christmas Eve at 12:00 noon until Christmas Day at 12:00 noon in the mother. The party who will be out of custody on Christmas morning shall have custody of the child on the preceding Thanksgiving Day during times as the parties shall agree, and if they cannot agree, from 9:00 a.m. until 5:00 p.m. The parties shall alternate the remaining holidays during the year as they shall agree, during such hours as they agree, and absent an agreement with respect to the hours, said custody shall be exercised from 9:00 a.m. until 5:00 p.m. 5. Neither party may relocate the child outside of the jurisdiction without prior order of court. In the event that a party wishes to visit outside of the jurisdiction, at least twenty-four- hour notice must be given to the non-custodial parent with a telephone number and location where the child will be. 6. 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, 144 Hess, J. J Michael A. Scherer, Esquire /For the Plaintiff vMarcus McKnight, III, Esquire For the Defendant Am (26p, 1ES LC q S-/0s CHRISTOPHER H. LAUGHMAN, Plaintiff/Respondent V. ANGELA L. RAU, Defendant, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW . Map ; 2007 - 6176 CIVIL TER1V 7 0 33. F u ?--:. IN CUSTODY r _ PETITION FOR MODIFICATION OF CUSTODY -i rV AND NOW comes the Petitioner, Angela L. Rau, by her attorneys, Irwin & McKnight, P.C., and presents the following Petition for Custody. 1. The Petitioner, Angela L. Rau, is an adult individual with an address of 38C East Water Street, Middletown, Pennsylvania 17057. 2. The Respondent, Christopher H. Laughman, is an adult individual with an address of 149 East Louther Street, Carlisle, Cumberland County, Pennsylvania 17013. 3 The parties are the natural parents of one (1) child, namely, Tyler Mitchell Laughman, born April 8, 2007. 4. Current custody of the minor child has been determined by an Order of Court issued on June 5, 2008 by the Honorable Kevin A. Hess. A copy of said Order is attached hereto and marked as Exhibit "A". 4 3.co P0 ArT4 01- 4641 a"271966 5. The Petitioner, Angela L. Rau, desires that the parties have shared legal custody of the minor child, Tyler Michell Laughman. 6. The Petitioner, Angela L. Rau, desires primary physical custody of the said minor child with periods of temporary physical custody to Respondent, Christopher H. Laughman, as the parties can agree. 7. The best interests and permanent welfare of the minor child requires that the Court grant the Petitioner's request as set forth above. WHEREFORE, the Petitioner, Angela L. Rau, respectfully requests that she be awarded primary physical custody and shared legal custody of Tyler Michell Laughman as provided herein, with periods of temporary physical custody to Respondent, Christopher H. Laughman, as provided herein. By: Respectfully submitted, IRWIN & McKNIQKT, P.C. Marcus . Mc fight, II, Esquire Attorne for Plai tiff 60 West Pomfret et Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 Date: 7a),g r CA 11 a 0 ? Z EXHIBIT "A" T . CHRISTOPHER H. LAUGHMAN IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 07-6176 CIVIL ANGELA LYNN RAU, Defendant ORDER AND NOW, this -T-'- day of June, 2008, following hearing with respect to the child, Tyler Mitchell Laughman, born April 8, 2007, it is ordered and directed that: 1. The father and the mother shall share legal custody of Tyler. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well being including, but not limited to, all decisions regarding his 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 child including, but not limited to, medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical treatment planning meetings and evaluations with respect to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority, and copies of any reports given to them as parents including, but not limited to, medical records, birth certificates, school or educational attendance records, or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights and the like. 2. The parties shall share physical custody with custody being in the father from Sunday at 1:00 p.m. until Tuesday prior to the commencement of his work shift. During the remainder of the week, custody shall be in the mother. 3. The mother and the father shall each be entitled to one week each year of uninterrupted custody with the child during that parent's vacation from work provided notice of same is given to the other parent at least thirty (30) days prior to the exercise of said weekly period. 4. The parties shall alternate the period from Christmas Eve at 12:00 noon until Christmas Day at 12:00 noon, and Christmas Day at 12:00 noon until December 26`h at 12:00 noon, commencing in 2008 with the period from Christmas Eve at 12:00 noon until Christmas Day at 12:00 noon in the mother. The party who will be out of custody on Christmas morning shall have custody of the child on the preceding Thanksgiving Day during times as the parties shall agree, and if they cannot agree, from 9:00 a.m. until 5:00 p.m. The parties shall alternate the remaining holidays during the year as they shall agree, during such hours as they agree, and absent an agreement with respect to the hours, said custody shall be exercised from 9:00 a.m. until 5:00 p.m. 5. Neither party may relocate the child outside of the jurisdiction without prior order of court. In the event that a party wishes to visit outside of the jurisdiction, at least twenty-four- hour notice must be given to the non-custodial parent with a telephone number and location where the child will be. 6. 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, Hess, J. ,/Michael A. Scherer, Esquire For the Plaintiff v/Marcus McKnight, III, Esquire For the Defendant Am (2opl iEs '"b"IF.c `?r?oa VERIFICATION The foregoing Petition for Modification of Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. _ 4v" 1 Angela L. Rau Date: March 1, 2012 CHRISTOPHER H. LAUGHMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA C i 7 rv 2007-6176 CIVIL ACTION LAW ?M x> -:= A t 'r; ANGELA L. RAU IN CUSTODY ' DEFENDANT CD r-_ ORDER OF COURT AND NOW, Friday, March 09, 2012 , upon consideration of the attached Co mplai nt, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at MDJ Office, 1901 State St., Camp Hill, PA 17011 on ___ Friday, April 13, 2012 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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: Is/ Melissa P. Greem Esq._ ? Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 deii cop l'd ? /y1G?i???l?f e m yl ed ej , ALL - t7?eevy (oorwX" or i Pd Popy ?e '0/a AT __ CHRISTOPHER H. LAUGHMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 07-6176 CIVIL ANGELA L. RAU, Defendant CUSTODY IN RE: PETITION TO INTERVENE ORDER AND NOW, this day of April, 2012, the scheduling of a hearing on the h petitioner/grandmother's Petition to Intervene is DEFERRED pending the outcome of the conciliation conference in this case scheduled for April 27, 2012, at 10:30 a.m. This order is entered with the understanding that the proposed intervenor(s) may attend the conciliation conference. BY THE COURT, 14 /C , ?? Michael A. Scherer, Esquire For the Plaintiff Marcus A. McKnight, III, Esquire For the Defendant /Lori K. Serratelli, Esquire For Proposed Intervenor Melissa P. Greevy, Esquire Conciliator :rlm ecp,es ma-leaf ,2(/ t r_) Hess, P. J. .a ._%.. CHRISTOPHER H. LAUGHMAN, Plaintiff vs. ANGELA L. RAU, Defendant IN THE COURT OF COMMON PLEAS OF i, CUMBERLAND COUNTY, PENNSYLVANU rnm rn CIVIL ACTION - LAW NO. 07-6176 CIVIL m CUSTODY A IN RE: PETITION TO INTERVENE nAn'pl? r.a a?. 01- - r- 4) 7 w AND NOW, this day of May, 2012, hearing on the Petition to Intervene is set for Wednesday, May 30, 2012, at 1:30 p.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. BY THE COURT, Michael A. Scherer, Esquire For the Plaintiff v Marcus A. McKnight, III, Esquire For the Defendant I/ Lori K. Serratelli, Esquire For Proposed Intervenor rlm top;cs ma,bfd 5/9li 'wt Kevin . Hess, P. J. 7 rya C3 w_„ ' i 73 CO -: - 7 -? -< ?r Cam' O -? >C N v CA CHRISTOPHER H. LAUGHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW • ?' by' Pr3 2007 - 6176 CIVIL TERM - ?- ANGELA L. RAU, r` Defendant IN CUSTODY NOTICE TO PLEAD TO: BARBARA LAUGHMAN and her attorney, Lori K. Serratelli, Esq. YOU ARE HEREBY NOTIFIED that you must responsively plead to the within Answer to Paternal Grandmother's Petition to Intervene and Request for Continuance, pursuant to Pa. R.C.P. 2252(d) within twenty (20) days after service, or a default judgment may be entered against you. By: Date: May 30, 2012 Marcus A. McKnight, III, Esq. Michael A., Scherer, Esq. Lori K. Serratelli, Esq. Melissa P. Greevy, Esq. IRWIN & McKNIGHT, P.C. A. WKnight, III, Esquire 60 st Pomfre Street Carl e, Pennsyl aria 17013-3222 (717) 24;5-Y Supreme Court ID. No. 25476 Attorney for Defendant, Angela L. Rau CHRISTOPHER H. LAUGHMAN, Plaintiff V. ANGELA L. RAU, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 6176 CIVIL TERM IN CUSTODY ANSWER TO PATERNAL GRANDMOTHER'S PETITION TO INTERVENE AND REQUEST FOR CONTINUANCE WITH NEW MATTER AND NOW, this 30th day of May, 2012, comes the Defendant, Angela L. Rau, by her attorneys, Irwin & McKnight, P.C., and presents the following Answer to Paternal Grandmother's Petition to Intervene and Request for Continuance with New Matter: 1. The averments in paragraph one (1) of Paternal Grandmother's Petition to Intervene and Request for Continuance are admitted. 2. The averments in paragraph two (2) of the Paternal Grandmother's Petition to Intervene and Request for Continuance are denied. On the contrary, it is denied that Christopher Laughman resides at 149 East Louther Street, in Carlisle, Pennsylvania. 3 The averments in paragraph three (3) of the Paternal Grandmother's Petition to Intervene and Request for Continuance are admitted. 4. The averments in paragraph four (4) of the Paternal Grandmother's Petition to Intervene and Request for Continuance are admitted 5. The averments in paragraph five (5) of Paternal Grandmother's Petition to Intervene and Request for Continuance are specifically denied. On the contrary, the child was to be in the custody of the natural father. The averments of paragraph five (5) are therefore denied. 6. The averments in paragraph six (6) of the Paternal Grandmother's Petition to Intervene and Request for Continuance are beyond the scope of knowledge of the Defendant. They are therefore denied and proof thereof is demanded. 7. The averments in paragraph seven (7) of the Paternal Grandmother's Petition to Intervene and Request for Continuance are beyond the scope of knowledge of the Defendant. They are therefore denied and proof thereof is demanded. 8. The averments in paragraph eight (8) of the Paternal Grandmother's Petition to Intervene and Request for Continuance are specifically denied. 9. The averments in paragraph nine (9) of the Paternal Grandmother's Petition to Intervene and Request for Continuance are specifically denied. On the contrary, a copy of the Consent to Custody Agreement is attached hereto and marked as Exhibit "A" 10. The averments in paragraph ten (10) of the Paternal Grandmother's Petition to Intervene and Request for Continuance are specifically denied. The hearing was cancelled when the parents resolved the case. WHEREFORE, the Defendant, Angela L. Rau, respectfully requests that the Petition of the Paternal Grandmother be dismissed. NEW MATTER OF DEFENDANT ANGELA L. RAU AND NOW, this 30th day of May 2012, comes the Defendant, Angela L. Rau, by her attorneys, Irwin & McKnight, P.C. and makes the following New Matter: 11. The averments of fact contained in the Answers to paragraph one (1) through eleven (11) of the Petition are hereby incorporated by reference and are made a part of this New Matter. 12. The Paternal Grandmother's Petition to Intervene and Request for Continuance has failed to meet the requirements of 23 Pa. C.S.A. 5313 which requires a period of grandparent custody of twelve (1'2) months. WHEREFORE, the Defendant, Angela L. Rau, respectfully requests that the Petition of the Paternal' Grandmother be dismissed. Respectfully submitted, IRWIN & McKNIGHT, P.C. By: A. Mc"ight, III, Esquire 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 Date: May 30, 2012 EXHIBIT "A" CHRISTOPHER H. LAUGHMAN, Plaintiff V. ANGELA L. RAU, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 6176 CIVIL TERM IN CUSTODY CONSENT TO CUSTODY AGREEMENT 1, CHRISTOPHER LAUGHMAN, am the natural father of Tyler M. Laughman, born April 8, 2007. t I agree that Angela L. Rau, the natural mother of Tyler M. Laughman, should ha,e primary physical custody of Tyler M. Laughman. I will exercise periods of temporary physical custody of Tyler M. Laughman at times I am able to arrange with Angela L. Rau. We will continue to exercise joint legal custody of Tyler M.'Laughman. I hereby sign this Agreement this 2nd day of April 2012. WITNESISETH: Tye _ (SEAL) QAZ H H H. LAUGHMAN COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS On this, the 2nd day of April 2012, before me this undersigned officer, personally appeared Christopher H. Laughman, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set lmyh vial s 11 Ilk 44, COMMONW OF NSYLVANIA Notarial Seal Martha L. Noel, Notary Public carllle eoro, cumberland County No ary Public my Commission Expires Sept 18, MEMBER, PENNSMANTA ASSOQA" OF NOTARIES VERIFICATION The foregoing document is based upon information, which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understandthat false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. By: ANG A L. RAU Date: MAY 30, 2012 CHRISTOPHER H. LAUGHMAN, Plaintiff V. ANGELA L. RAU, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 6176 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Lori K. Serratelli, Esq. Michael A. Scherer, Esq. Serratelli, Schiffman & Brown, P.C. 19 West South Street 2080 Linglestown Road Carlisle, PA 17013 Suite 201 Harrisburg, PA 17110 Melissa P. Greevy, Conciliator 301 Market Street P.O'. Bog 109 Lemoyne, PA. 17043 IRWIN & McKNIGHT, P.C. By: M us A. cKnight, III, Esquire 60 st Po et Street Car isle, 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: May 30, 2012 CHRISTOPHER H. LAUGHMAN,: Plaintiff V ANGELA L. RAU, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007-6176 CIVIL TERM IN CUSTODY IN RE: PETITION TO INTERVENE ORDER OF COURT AND NOW, this 30th day of May, 2012, after hearing, the petition of Barbara Laughman, the paternal grandmother, to intervene is granted. By the Court, Kevin A. Hess, P.J. Lori K. Serratelli, Esquire For Proposed Intervenor / Marcus A. McKnight, III, Esquire For the Defendant bg - ? `' .?> r? 4 . 9 CHRISTOPHER H. LAUGHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2007 - 6176 CIVIL TERM ANGELA L. RAU, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ,5?' day of June 2012, based upon the consent of the natural parents, the following Custody Order is entered: The Order of Court dated June 5, 2008 is vacated. 2. The natural parents shall have shared legal custody of the minor child, Tyler M. Laughman. All non-emergency decisions affecting the child's growth and development shall be considered major decisions and shall be made by the parents jointly, after discussion and consultation with each other, and with a view towards obtaining and following the child's best interests which decisions shall include, but not limited to: choice of camp, if any; medical treatment, specifically including any medications prescribed for the children; dental treatment; education; scholastic or athletic pursuits; and other extracurricular activities. 3. The mother, Angela L. Rau, will have primary physical custody of the minor child, Tyler M. Laughman. 4. The father, Christopher H. Laughman, will have periods of temporary physical custody of the minor child, Tyler M. Laughman, as the parties agree is in his best interest. 5. Pursuant to the terms of 23 Pa.C.S. § 5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious, or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher, or other authority as well as copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records, report cards, and medical insurance cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to- school nights, and the like. 6. The parties shall share all holidays as is mutually agreed upon in advance by the parties. 7. The parties shall keep each other advised immediately relative to any emergencies concerning the minor child and shall, further, take any necessary steps to ensure that the health and wellbeing of the child is protected. These steps shall include providing a safe, secure, and clean home environment during their respective periods of custody, and ensuring that the child has adequate meals and nutrition. During any illness or medical emergency, each party shall have the right to visit the child as often as he or she deems consistent with the proper medical care of the child. 8. There shall be reasonable telephone contact by the parties with the child during the periods when the child is not in the custody of that party. 9. Neither party shall do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love or affection for the other party. 10. Neither party shall schedule activities or appointments for the child which would require their attendance or participation at said activity or appointment during a time when he is scheduled to be in the physical custody of the other parent without that parent's express prior approval. H. It shall be the obligation of each parent to make the child available to the other in accordance with the physical custody schedule and to encourage them to participate in the plan hereby agreed and ordered. 12. Neither party shall remove the child from the Commonwealth of Pennsylvania except for vacations when said party has custody of the minor child as provided herein. Each parent shall inform the other parent if he or she desires to remove the child overnight from the Commonwealth of Pennsylvania by providing notice at least ten (10) calendar days prior to the anticipated date of departure. In such an instance, the party who desires to remove the child shall provide the other parent with a general schedule of the planned vacation and its location or locations, along with a telephone number or numbers, including area code, where the child may be reached. 13. Neither party shall be permitted to relocate the residence of the child to significantly impair the ability of another person to exercise custody unless every individual who has custody rights to the child consents to the proposed relocation. The party proposing to relocate must comply with the notice requirement pursuant to 23 Pa.C.S.A. §5537(a). 14. The parties may temporarily alter the schedule of physical custody as is mutually agreeable in order to accommodate special family events or other changes in their schedule. If the parties cannot agree on any such changes, the terms and provisions of this Order shall control. ? Marcus A. McKnight, III, Esq. ? Michael A. Scherer, Esq Lori K. Serratelli, Esq. ? Melissa P. Greevy, Esq. Wp', E'S By the Court, Kevin A. ess, President Judge i° Lr, 2 _ CHRISTOPHER H. LAUGHMAN, Plaintiff V. ANGELA L. RAU, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 6176 CIVIL TERM IN CUSTODY CONSENT TO CUSTODY AGREEMENT I, CHRISTOPHER LAUGHMAN, am the natural father of Tyler M. Laughman, born April 8, 2007. I agree that Angela L. Rau, the natural mother of Tyler M. Laughman, should h* primary physical custody of Tyler M. Laughman. I will exercise periods of temporary physical custody of Tyler M. Laughman at times I am able to arrange with Angela L. Rau. We will continue to exercise joint legal custody of Tyler M. Laughman. I hereby sign this Agreement this 2nd day of April 2012. WITNESSETH: (SEAL) H H H. LAUGHMAN COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND On this, the 2nd day of April 2012, before me this undersigned officer, personally appeared Christopher H. Laughman, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my h cia11 s i r MM OF P NNSYLVANIA Seai Notary Public berland County No ary Public es SePL 18, 2015 MEMBER, PENNVLY.ANTA ASSOCIATION OF NpTARIES