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HomeMy WebLinkAbout03-6506 DANIEL M. BOARMAN, PLAINTIFF : THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLA VNIA v. :NO. 03 - ~S9(., ~tu~ll~ JEANNETIE A. BOARMAN, DEFENDANT : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY I. The Plaintiff is Daniel M, Boarman, residing at 1 Longwood Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Jeannette A. Boarman, at 39 Goldenrod Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks shared legal and physical custody of the following children: NAME PRESENT RESIDENCE D.O.B. The Plaintiff and the Defendant presently share custody of the children with the Plaintiff' having approximately 40% of the custodial time and the Defendant having approximately 60% of the time. Lindsey A. Boarman 39 Goldenrod Drive Carlisle, Pennsylvania and I Longwood Drive Mechanicsburg, Pennsylvania OS/26/94 Jordan A. Boarman 06/19/97 The children were not born out of wedlock. During the past five years, the children have resided with the following persons and at the following addresses: NAME RESIDENCE DATE Daniel M, Boarman (father) Jeannette A Boarman (mother) 5 Cedar Road Carlisle, Pennsylvania 1997 - 2002 Daniel M, Boarman (father) 300 Georgetown Road 05/01 - 12/02 Mechanicsburg, Pennsylvania Jeannette A Boarman (mother) 5 Cedar Road Carlisle, Pennsylvania 05/01 - 2002 Daniel M. Boarman (father) I Longwood Drive 12/02 - Present Mechanicsburg, Pennsylvania Jeannette A. Boarman (mother) 39 Goldenrod Drive Carlisle, Pennsylvania 2002 - Present The mother of the children is Jeannette A. Boarman, currently residing at 39 Goldenrod Drive, Carlisle, Pennsylvania, She is married. The father of the children is Daniel M. Boarman, currently residing at I Longwood Drive, Mechanicsburg, Pennsylvania. He is married. 4. The relationship of Plaintiff to the children is that of father. The Plaintiff currently resides with the following persons based on the custodial schedule as set forth in Paragraph 3 hereof. NAME RELATIONSHIP Jordan A Boarman Daughter Lindsey A Boarman Daughter 5. The relationship of Defendant to the children is that of mother. The Defendant currently resides with the following persons based on the custodial schedule as set forth in Paragraph 3 hereof. NAME RELATIONSHIP Daughter Daughter JordanA. Boarman Lindsey A. Boarman 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, the Plaintiff, Daniel M. Boarman, requests the court to grant shared legal and physical custody ofthe minor children, Jordan A. Boarman and Lindsey A. Boarman, to him. JAMES, SMITH, DIETTERICK & CONNELLY LLP Date: /2-/.5-03 VERIFICATION I verify that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: /02-/..5-03 42 - Daniel M. oarman, Plaintiff - ~ -lQ. 1 ....... p '" 0 ~ C.;J ,-::.;) '" c.... (-~ ..... rej ff~~ .J::: '1 c,;. ~ -r-"'"" ~ () ~r5 C:_J -- ~..~ (:) V) --.( -,'0'1, r- ~ '"'"-n ~ --,. : ;} .~') ~ :iTl ( , ;;:-'1 --.J f.'--' :__V ~, ~ DANIEL M. BOARMAN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNIY, PENNSYL VANIA v. 03-6506 CIVIL ACTION LAW JEANNETTE A. BOARMAN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, December 23, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa p, Greevy, Esq. , the conciliator, at 301 Market Street, Lemuyne, PA 17043 on Tuesday, January 27,2004 at 9:30 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 hearin!!. FOR THE COURT, By: Isl Melissa p, Greevy, 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 TILE 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) 249-3] 66 ~ #zv 'J--~~) ~[:e,c/ ~p~ ~ f2p ;P:. ~!,>1/ ~~ Eo ,:r.C/ ~7 fr~~~'PJ rO'~F..t'1 AH\!: ",':-1,:' ~;: : I "" I ('::' ~,-'1 rC"7 J V'.i ,-' '"~'.. t. ':';... '1"'''''''.>.''-'''1 ,-" 1..C~'~.!j',.,,)t-11Cdd 3Hl .JO :".)_J'!\''}-IJ.T1L~ -. .....,. '-,- # ' ::! "~.' DANIEL M. BOARMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 03-6506 JEANNETIE A. BOARMAN, Defendant CIVIL ACTION - LAW IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYL VANIA : ss. COUNTY OF DAUPHIN AND NOW, this 5th day of January, 2004, personally appeared before me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly sworn according to law, deposes and says that a copy of the Custody Complaint and Order scheduling the conciliation conference was served on the Defendant, Jeannette A. Boarman, on December 31, 2003, by certified mail number 7002086000042141 9635, as evidenced by the return receipt card attached hereto and made a part hereof. Sworn to and subscribed before me this 5& , NOTARIAL SEAL . Jean l. Kosier, Notary Public City of Hummeistown,County of Dauphin My Commission Expires Feb, 9, 2004 ~ ._"---'"-'~~-~ ;-t Ii ,! if; ii !II Iff! i! " Hf . 7002 08bO 0004 2141 9b35 - .. - r ,.. .. .... " Ii ~ C) ", C) =~ C =~ ., --;:: <-. --l ;:Rw, --" ::--~,.. -'~'l ?:JJ :;f: n1rn Z~ I ;80 ~,-;. -' :.:)c\ '--::'" --'----! -c <0 ""1:J '~f,~ :Jo'() ;:;;0 :l>c:: r:'l ,-.( ~ Ul :~,-~ Go> -, y/ I FEB 1 8 2004 '&J Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6506 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY NIEL M. BOARMAN, v, JEANNETTE A. BOARMAN, Defendant ORDER OF COURT AND NOW, this x()-rt day of February, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Leaal Custodv. The parties, Daniel M. Boarman and Jeannette A. Boarman, shall have shared legal custody of the minor children, Jordan A. Boarman, born May 26, 1994 and Lindsey A. Boarman, born June 19, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, 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. 95309, 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 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. 2. Phvsical Custodv. Mother shall have primary physical custody. Father shall have partial custody which shall be arranged as follows: A. To commence February 6, 2004, on alternating weekends from Fridays at 6:00 p.m. until Monday morning when the children are returned to school or daycare by Father. B. Effective February 11, 2004, each Wednesday at 6:00 p.m. until Thursday morning when the children are returned to school or daycare. C. Effective February 12, 2004, alternating Thursdays from 6:00 p.m. until Friday morning when the children are retumed to school or daycare. 3. TransDortation. The parent relinquishing custody shall be responsible for providing transportation incident to the custodial exchange. v. f',r'{:'\l,\.,~::: \, I ~ :jd A1NnC/'-' . ~:\i'~nJ 62 :6 IW 92 ~;1~ ~OGZ t)j'rilCi\-.!CH.lJ)C'd ]-\1 :10 3',]'d:\O-C13lU NO. 03-6506 CIVil TERM 4. Reasonable Teleohone Contact. Both parties shall have the right to reasonable telephone contact with the children during the other party's period of custody/visitation. The children may initiate a telephone call to the non-custodial parent upon their request. Neither party shall interfere with the other party's telephone contacts with the children. Each party shall make all reasonable efforts to promptly return calls or messages left by the other party regarding the children. 5. Holidavs. A. Christmas. The sharing of custody for the Christmas holiday shall be arranged on an AlB schedule. Segment A shall be from December 24th at Noon until December 25th at 2:00 p.m. Segment B shall be from December 25th at 2:00 p.m. until December 26th at 6:00 p.m. In even- numbered years, Mother shall have Segment A and Father shall have Segment B. In odd-numbered years, Father shall have Segment A and Mother shall have Segment B. B. Thanksaivina. The Thanksgiving holiday shall be divided into two segments, Segment A and Segment B. Segment A shall be from the day before Thanksgiving at 6:00 p.m. until Thanksgiving Day at 2:00 p.m. Segment B shall be from 2:00 p.m. Thanksgiving Day until Friday at 6:00 p.m. In even-numbered years, Father shall have Segment A and Mother shall have Segment B. In odd-numbered years, Mother shall have Segment A and Father shall have Segment B. C. Easter. Each year, Mother shall have the Easter holiday from 6:00 p.m. the Saturday before Easter until 2:00 p.m. on Easter Sunday, Each year, Father shall have custody on Easter Sunday from 2:00 p.m. until Monday morning. D. Alternatina Holidavs. The parties shall alternate the following holidays commencing with Mother having Memorial Day in 2004: Memorial Day, Independence Day, and labor Day. The custodial time for these holidays shall commence at 6:00 p.m. the day before the holiday and conclude at 8:00 p.m. the day of the holiday. E. Mother's Dav / Father's Dav. Mother shall have custody for Mother's Day. Father shall have custody for Father's Day. The custodial period for these days shall commence at 6:00 p.m. the day before the holiday and continue until Monday morning when the children are returned to school or day care. NO. 03-6506 CIVIL TERM 6. Vacation. Each parent shall be entitled to two (2) non-consecutive vacation weeks, to commence with their custodial weekend. The parties shall provide each other with thirty (30) days written notice of their intended vacation plans. In the event that the parties have scheduled overlapping vacations, the parent first providing written notice shall have first choice of the vacation time. In the event that the planned vacation time requires absence from school, the vacationing parent will follow all required school protocol for excused absences for purposes of educational vacations. 7. Sick Davs. Father shall be responsible for providing care for the children in the event of illness on Tuesdays. Mother shall be responsible for providing care for the children in the event of illness on Thursdays. Otherwise, the parent who has custody of the children in the morning for breakfast shall be the parent to arrange for care in the event that the children are ill and unable to attend school or daycare. Mother shall use her best efforts to work with her employer and the school to seek to change her day off to a Tuesday or Wednesday commencing with 2004/2005 school year. In the event that Mother is able to make that change, the parent then having custody shall be responsible for providing care for the children if they are unable to attend school or daycare due to illness. BY THE COURT: /ld J. Dlst: ",.fohn J, Connelly, Jr,. Esquire, P,Q, Box 650, Hershey, PA 17033 ~rbara Sumple-Sulllvan, Esquire, 549 Brtdge Street, New Cumbertand, PA 1'7070 :222851 o ~ ~&-O '-l Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6506 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY DANIEL M. BOARMAN, v. JEANNETTE A. BOARMAN, Defendant 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 conceming the children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Jordan A. Boarman May 26,1994 Mother Lindsey A. Boarman June 19, 1997 Mother 2. A Complaint for Custody was filed by Father on December 17, 2003. A Custody Conciliation Conference was held on February 5, 2004 with the following individuals in attendance: the Father, Daniel M. Boarman, and his counsel, John J. Connelly, Jr., Esquire, Esquire; the Mother, Jeannette A. Boarman, and her counsel, Barbara Sumple-Sullivan, Esquire. 3. The parties reached an agreement in the form of an Order as attached. J~/b{)~ u~J;ilfL tSf1~ Melissa Peel Greevy, Esquire Custody Conciliator Date :224160 John 1. Connelly, Jr., Esquire Attorney LD, No. 15615 James Smith Dietterick & Connelly, LLP P,Q. Box 650 Hershey, P A 17033 Attorneys for Petitioner DANIEL M, BOARMAN, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 03-6506 JEANNETTE A. BOARMAN, Defendant/Respondent CIVIL ACTION - LAW IN CUSTODY PETITION TO MODIFY EXISTING CUSTODY ORDER AND COMES NOW, Petitioner, Daniel M, Boarman, by and through his attorneys, James, Smith, Dietterick & Connelly, LLP by John J. Connelly, Jr., Esquire, and files the following Petition to Modify Existing Custody Order and in support thereof, respectfully represents as follows: I. The Petitioner is Daniel M. Boarman, Plaintiff in the above-captioned action, who currently resides at 1302 King Arthur Drive, Mechanicsburg, Pennsylvania 17050. 2, The Respondent is Jeannette A. Boarman, Defendant in the above-captioned action, who currently resides at 39 Goldenrod Drive, Carlisle, Pennsylvania 17013. 3, The parties are the parents of two minor children, Jordan A. Boarman, born May 26, 1994 and Lindsey A, Boarman, born June 19,1997, who are subject of the existing Order more particularly set forth in the Order dated February 20,2004 and attached hereto and marked as Exhibit "A". 4, Providing Petitioner with an additional overnight every other week would give Petitioner each Wednesday and Thursday overnight and every other weekend through Monday morning thereby equalizing the custodial arrangement. 5. Respondent is currently cohabitating with another individual named Wesley Beard who has been spending a significant amount of time with the parties' children, Petitioner believes that it is in his children's best interest for him to share custody equally with the Respondent and given the current schedule, minimal change is necessary for this to occur. WHEREFORE, your Petitioner, Daniel M. Boarman, requests that this Honorable Court enter an Order setting forth a schedule of adding an additional night every other week to his current custodial schedule which is in the children's best interest given the current circumstances, Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY Date: "3 \ '3 \ ) G \.., VERIFICATION I, Daniel M. Boarman, verifY that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. Section 4904 relating to unsworn falsification to authorities. Date: 3 \3 \ \ 0 l Daniel M. Boarman, Petitioner DANIEL M, BOARMAN, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. No,: 03-6506 JEANNETTE A. BOARMAN, Defendant/Respondent CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I, John J, Connelly, Jr" Esquire, of James, Smith, Dietterick & Connelly LLP, attorney for the Petitioner, Daniel M. Boarman, hereby certifY that I have served a copy of the foregoing Petition to ModifY Existing Custody Order on the following on the date and in the manner indicated below: VIA CERTIFIED MAIL, RESTRICTED DELIVERY FIRST CLASS, PRE-PAID Jeannette A. Boarman 39 Goldenrod Drive Carlisle, PA 17013 Respectfully submitted, JAMES, SMITH, D1ETTERICK & CONNELLY ~ Date: 3 \'3 \\0(, ~~/ ,\( By. " John\!. CO~I,IX' Jr., Esquire ^,~ey r P~tltioner '. Post Office ox 650 Hershey, PA 17033 (717) 533-3280 PA I.D. No, 15615 EXHIBIT "A" ~E8 1 e 200.4 )J Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 03-6506 CIVIL TERM DANIEL M, BOARMAN, v, JEANNETTE A. BOARMAN, CIVIL ACTION - LAW IN CUSTODY Defendant ORDER OF COURT AND NOW, this 1.0 +~ day of February, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1, Leaal Custodv. The parties, Daniel M, Boarman and Jeannette A Boarman, shall have shared legal custody of the minor children, Jordan A Boarman, born May 26, 1994 and Lindsey A Boarman, born June 19, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, 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, 95309, 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 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. 2. Phvsical Custodv. Mother shall have primary physical custody, Father shall have partial custody which shall be arranged as follows: A. To commence February 6, 2004, on alternating weekends from Fridays at 6:00 p.m. until Monday morning when the children are returned to school or daycare by Father. B. Effective February 11, 2004, each Wednesday at 6:00 p.m. until Thursday morning when the children are returned to school or daycare, C. Effective February 12, 2004, alternating Thursdays from 6:00 p,m, until Friday morning when the children are returned to school or daycare. 3, Transportation. The parent relinqUishing custody shall be responsible for providing transportation incident to the custodial exchange. NO, 03-6506 CIVIL TERM 4, Reasonable Telephone Contact. Both parties shall have the right to reasonable telephone contact with the children during the other party's period of custody/visitation. The children may initiate a telephone call to the non-custodial parent upon their request. Neither party shall interfere with the other party's telephone contacts with the children, Each party shall make all reasonable efforts to promptly return calls or messages left by the other party regarding the children. 5, Holidavs, A. Christmas. The sharing of custody for the Christmas holiday shall be arranged on an AlB schedule. Segment A shall be from December 24th at Noon until December 25th at 2:00 p.m. Segment B shall be from December 25th at 2:00 p.m. until December 26th at 6:00 p.m. In even- numbered years, Mother shall have Segment A and Father shall have Segment B. In odd-numbered years, Father shall have Segment A and Mother shall have Segment B. B, Thanksaivina, The Thanksgiving holiday shall be divided into two segments, Segment A and Segment B. Segment A shall be from the day before Thanksgiving at 6:00 p.m. until Thanksgiving Day at 2:00 p.m, Segment B shall be from 2:00 p.m. Thanksgiving Day until Friday at 6:00 p.m, In even-numbered years, Father shall have Segment A and Mother shall have Segment B, In odd-numbered years, Mother shall have Segment A and Father shall have Segment B. C, Easter. Each year, Mother shall have the Easter holiday from 6:00 p.m. the Saturday before Easter until 2:00 p.m. on Easter Sunday, Each year, Father shall have custody on Easter Sunday from 2:00 p.m, until Monday morning, D. Alternatina Holidavs. The parties shall alternate the following holidays commencing with Mother having Memorial Day in 2004: Memorial Day, Independence Day, and Labor Day, The custodial time for these holidays shall commence at 6:00 p.m. the day before the holiday and conclude at 8:00 p.m, the day of the holiday, E, Mother's Dav / Father's Dav, Mother shall have custody for Mother's Day. Father shall have custody for Father's Day, The custodial period for these days shall commence at 6:00 p.m, the day before the holiday and continue until Monday morning when the children are returned to school or day care, NO. 03-6506 CIVIL TERM 6. Vacation. Each parent shall be entitled to two (2) non-consecutive vacation weeks, to commence with their custodial weekend, The parties shall provide each other with thirty (30) days written notice of their intended vacation plans. In the event that the parties have scheduled overlapping vacations, the parent first providing written notice shall have first choice of the vacation time. In the event that the planned vacation time requires absence from school, the vacationing parent will follow all required school protocol for excused absences for purposes of educational vacations. 7, Sick Davs, Father shall be responsible for providing care for the children in the event of illness on Tuesdays. Mother shall be responsible for providing care for the children in the event of illness on Thursdays. Otherwise, the parent who has custody of the children in the morning for breakfast shall be the parent to arrange for care in the event that the children are ill and unable to attend school or daycare. Mother shall use her best efforts to work with her employer and the school to seek to change her day off to a Tuesday or Wednesday commencing with 2004/2005 school year. In the event that Mother is able to make that change, the parent then having custody shall be responsible for providing care for the children if they are unable to attend school or daycare due to illness. BYTHE COURT' 11, 15/ ~Mn-J yj n.a.J J, Dist: John J. Connelly, Jr" Esquire, P.O. Box 650, Hershey, PA 17033 Barbara Sumple-Sullivan, Esquire, 549 Bridge Street, New Cumberland, PA 17070 :222851 TRUE COPY FROM RECORD In Testimony Wn"T" ',i h,,'r0 unto set my hand and the seal of said Co rt at Carlisle, Pa. Th' ....J,/.t;..... ...Ee..D:....,. DANIEL M. BOARMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6506 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY v. JEANNETTE A. BOARMAN, Defendant 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 THE CUSTODY OF Jordan A. Boarman Lindsey A. Boarman May 26, 1994 June 19, 1997 Mother Mother 2. A Complaint for Custody was filed by Father on December 17, 2003, A Custody Conciliation Conference was held on February 5, 2004 with the following individuals in attendance: the Father, Daniel M. Boarman, and his counsel, John J. Connelly, Jr., Esquire, Esquire; the Mother, Jeannette A, Boarman, and her counsel, Barbara Sumple-Sullivan, Esquire. 3. The parties reached an agreement in the form of an Order as attached, J~!bvY Ui'f)~/~ Melissa Peel Greevy, Esquire Custody Conciliator Date :224160 A..J G ~ n , c ,', t- 1 U( D '-- -"'.,." ~ ~ \) ~ -"":) w "'-< . '\:, 90 ~ (,1 ----------.:J ---z ", -, }: -r---. -----C., DANIEL M, BOARMAN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v, 03-6506 CIVIL ACTION LAW JEANNETTE A. BOARMAN DEFENDANT IN CUSTODY ORnER OF COlJRT AND NOW, Wednesday, Aprill_~,..2006 , upon consideration nf the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa p, Greevy, Esq. , the conciliator, at MD.J..IV!,a"~,I,~,,,,e,LI901 State St., Camp Hill, P A 17011 on Thursday, Jnue 08, 2006 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 accomplishcd, to detine 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 conlerence, Failurc to appear at the conference may provide grounds for entry of a temporary or permanent order. Thc court hcreby directs the partics to furnish any and all existing Protcction from Ahusc orders, Special Rclicf orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl(. FOR THE COURT, By: Isl ..Melissa P. Gre~Yl'11.BL.~~..J.b.V Custody Conciliator fA' 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 thc 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 HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TilE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedfi.>rd Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~'?a~'W"-" -#;v:;z ti7'lM/ ~&J 'Xl- uch ~;':7- PPtr 7.?'~/ ;>~ft, 'lU- ,;>(' '.~ wrrn?tDfJ ~ .~. /'t/zM/-M7? ;---11J -J,7 <.7(',/7 "..1 .'7 I.! \ :"\;: \\ \',~ .;J ., :., . '.~ . 1'1. ,- DANIEL M. BOARMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLANDCOUNTY,PENNSYLVAN~ DOCKET NO.: 03-6506 v. CIVIL ACTION - LAW JEANNETTE A. BOARMAN, Defendant IN CUSTODY ENTRY OF APPEARANCE Please enter the appearance of the undersigned as counsel for the Defendant, ] eannette A. Boarman, in the above-captioned matter. Respectfully submitted, ABOM & KUTULAKIS, LLP ~ Kara W. Haggerty Attorney J.D. 86914 36 South Hanover Street Carlisle, P A 17013 Attornry for Difendant Dated: May 11, 2006 8 s:: '"Om mrr -,.. ......-. ..c::..:......../.. Zl".' ~ .,;:~:~~~ rst, :;....- '. j;; ('" z." 5>0 c ~ ~ <=:::l <=:::l 0'\ .:It ::::.. -< ff: ~~ j5? Q6 ::r: ,-j 26 of11 -I ~ -< -,:, :z ~ c.n -.J / '~y~ . 1 Plaintiff R !:: eE' V E!J .' U L 1 0 "nC5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6506 CIVIL TERM DANIEL M, BOARMAN, v. JEANNETTE A. BOARMAN, CIVIL ACTION - LAW IN CUSTODY Defendant ORDER OF COURT AND NOW, this / gd1 day of July, 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. This Court's order of February 20, 2004 shall remain in full force and effect pending further Order of Court or agreement of the parties, except as follows: A. Upon two hours notice to Mother and the children's babysitter, Father may elect to commence his custodial weekends as early as 4:00 p.m. on Friday, B. Mother will have custody for the weekends of July 28, 2006 through July 30, 2006, and August 4, 2006 through August 6, 2006. Father will have custody from August 11, 2006 through the conclusion of his vacation week, which is scheduled for the week of August 14, 2006, These adjustments to the weekend periods of custody have been arranged such that the children have no more than two weekends in a row away from either parent. C, Mother's Day and Father's Day custodial periods shall be defined as 9:00 a.m, on the holiday until 7:30 a.m. the following morning. 2. A hearing i~cheduled in ~m Number 1 of the Cumberland County ~urthouse, on the (P day of ~A .J ,2006, at 9 ; B 0 o'clock , .M., at which time testimony will be taken. For the purposes of the hearing, the Father, Daniel M. Boarman, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of witnesses who are 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, ('. {'" " , I.... C, . ,j..- >>. ,~l .-' .... BY THE COURT: J. Dist: Kara W. Haggerty, Esquire, 36 S. Hanover Street, Carlisle, PA 17013 John J. Connelly, Jr., Esquire, P. O. Box 650, Hershey, PA 17033 . ~ 1~/3-0(, ~ c+..