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HomeMy WebLinkAbout08-1138t;ommonwealth of Pennsylvania County of Potter Commonwealth of Pennsylvania County of Potter p$ - x13,8 _ ?,?i v? ? I, Amy J. Moshier Prothonotary of the Court of Common Pleas - Civil Division, in and for said County, do hereby mtifir that the foregoing is a full, true and correct copy of the whole record of the case therein stated, wherein -Noliv E. +IsnSzj was the Petitioner and was the Respondent, so full and entire as the same remains of record before the said Court, at No. Q; oo-7- X4-74 IN TESTIMONY WHEREOF, I haeunt hand and affixed the seal said Court, this ie vyof. A.D., 20_2,j?- I, John B. Lode, President Judge of the 55 h Judicial District, composed of the Court of Common Pleas - Civil Division, do certify that Amy J. Moshier by whom the annexed record, certificate and attestation were made and given, and who, in her own proper handwriting thereunto subscribed her name and affixed the seal of the Court of Common Pleas - Civil Division of said County, was at the time of so doing, and now is the Prothonotary in and for said County of Potter, in the Commonwealth of Pennsylvania, duly commissioned and qualified to all whose acts, as such, full faith and credit are and ought to be given, as well as Courts of Judicature as elsewhere, and that the said record, certificate and attestation are in due form of law and mp*by the proper office. President Judge Commonwealth of Pennsylvania County of Potter 1, Amy L Moshier, Clerk of Court of the Court of Common - Pleas - Criminal Division in and for said. County, do certify that the Honorable John B. Leese by whom the foregoing attestation was made, and who had thereunto subscribed his name, was, at the time of making thereof; and still is President Judge of the Court of Common Pleas in and for said County of Potter, in the Commonwealth of Pennsylvania, duly commissioned and qualified; to all whose acts, as such, full faith and credit are and ought to be given, as well in Courts of Judicature as elsewhere. IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of said Court this x-60&' y of A.D., 20_ ,71rl? /'Court 150250,02062008 Potter County Pennsylvania P e 2 PYS835 Docket Entries 2??6/2008 Case No 2007-92479 HOLLY E HENSEL (VS) SHAWN A HENSEL Date Filed - - - - - - - - - - - - - FIRST ENTRY - - - - - - - - - - - - - - 1 5/21/07 COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE AND NOTICE TO DEFEND AND CLAIM RIGHTS FILED - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 2 9/18/07 ACCEPTANCE OF SERVICE SECTION 3301(C) DATED: 06-13-2007 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 3 9/18/07 PLAINTIFF'S AND DEFENDANT'S AFFIDAVIT OF CONSENT AND DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE (SIGNED BY BOTH PARTIES) - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 4 11/26/07 CUSTODY STIPULATION DATED 10-19-07 SIGNED BY BOTH PARTIES - - - - - - - - 002 Image page(s) exist(s) for this entry - - - - - - - - - - - - - - - - - - - - - - - - - - 5 11/26/07 PRAECIPE TO TRANSMIT RECORD - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 6 12/03/07 DECREE AND NOW DECEMBER 03 2007 IT IS ORDERED AND DECREED 'HAT PLAINTIFF AND DEFENDANT ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF ANY CLAIMS RAISED BY THE PARTIES TO THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED. NO SUCH CLAIM WAS RAISED BY EITHER PARTY. BY THE COURT *****ALL PAPERS IN THIS CASE ARE SCANNED AT THIS DOCKET ENTRY***** - - - - - - - - - - - - - - - - - - 008 Image page(s) exist(s)-for-this entry 7 12/03/07 CERTIFIED COPY OF DIVORCE DECREE SENT TO ATTORNEY FOR PLAINTIFF & NOTICE OF ENTRY OF DECREE SENT TO DEFENDANT - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 8 1/28/08 PETITION TO TRANSFER VENUE TO CUMBERLAND COUNTY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 9 1/31/08 ORDER TO TRANSFER CASE TO CUMBERLAND COUNTY DATED 1-29-08 - - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - - AND NOW FEB 6 2008 CERTIFIED A TRUE COPY AMY J. MOSHIER, PROTH./ CLERK-POTTER CO. PA 15625002062008 Potter County Pennsylvania P gge 1 PYS835 Docket Entries 2?D6/2008 Cover Sheet Case No 2007-92479 Plaintiff: HENSEL HOLLY E ** (VS) ** Defendant: HENSEL SHAWN A HOLLY E. HENSEL, IN THE COURT OF COMMON PLEAS OF Plaintiff POTTER COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SHAWN A. HENSEL NO. 2007-2479 Defendant ORDER OF COURT......____.... 13AND NOW, this day of C-` "?' , 2008, upon review of the attached Petition to Transfer Venue, it is hereby ORDERED that the above referenced action is to be transferred by the Prothonotary of Potter County, Pennsylvania to Cumberland County, Pennsylvania. C.C. Lorin Andrew Snyder, Esq. Michael E. Davis, Esq. Prothonotary of Potter County Prothonotary of Cumberland County -=J 1. FEB 6 2008 AND NOW CE TIFIED A TRUE COPY AMY J. MOSHIER, PROTH./ CLERK-POTTER CO. PA <?1 co \e i HOLLY E. HENSEL, IN THE COURT OF COMMON PLEAS OF Plaintiff POTTER COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SHAWN A. HENSEL, NO. 2007-2479 Defendant _ DIVORCE/CUSTODY PETITION TO TRANSFER VENUE AND NOW, comes Petitioner Shawn A. Hensel, by and through hls attorney, Lorin Andrew Snyder, Esq., and respectfully requests this Honorable?Co61 to transfer venue to the Court of Common Pleas of Cumberland County, Pennsylvania, and avers as follows: 1. Petitioner is Shawn A. Hensel, an adult individual who currently resides at 302 Hilltop Road, Newburg, Cumberland County, Pennsylvania 17240. 2. Respondent is Holly E. Hensel, an adult individual who currently resides at 257 Newburg Road, Newburg, Cumberland County, Pennsylvania 17240. 3. Respondent filed for divorce in Potter County, Pennsylvania on May 21, 2007. 4. A Divorce Decree was issued by the Honorable John B. Leete on December 3, 2007, incorporating but not merging an attached Custody Stipulation regarding the parties' minor child. (Exhibit "A" is attached and incorporated herein as if fully set forth. 5. Neither the child nor either of the parties reside in Potter County. 6. Neither the child nor either of the parties have ever resided in Potter County. 7. Both of the parties have resided in Cumberland County throughout the entirety of their marriage. 8. The minor child has resided in Cumberland County throughout the entirety of his life. WHEREFORE, Petitioner respectfully requests this Honorable Court to enter an Order directing the above referenced action to be transferred by the Prothonotary of Potter County, Pennsylvania to Cumberland County, Pennsylvania. iyder, Esq. I.D. No. 203199 28 qgu KPitt Street Carlisle, PA 17013 (717) 245-9688 phone 717.245.2165 fax Attorney for Defendant IN THE C ZT OF COMMON PLEAS OF POTTER HOLLY E HENSEL vs. SHAWN A HENSEL Plaintiff Defendant DECREE AND NOW, DEC decreed that Plaintiff and Defendant matrimonv. The Court retains jurisdiction parties to this action for which a entered. No such claim was raised...by executed by the parties is attached I not merged with this decree. LINTY, PENNSYLVANIA CIVIL ACTION - LAW CASE NO. 2007-2479 IN DIVORCE 20 it is ordered and are divorced from the bonds of of any claims raised by the final order has not yet been either party.. A.Custody Stipulation iereto and incorporated into but BY THE COURT: SMOHN B. LEETE PRESIDENT JUDGE Reisman and Davis Attorneys for Plaintiff Law & Finance Building Pittsburgh, PA 15219 (412) 232-0406 True and Correct Copy certified from the Records of Potter Co., Penna. Pro thonc3eary HOLLY E. HENSEL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : POTTER COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SHAWN A. HENSEL, : NO. 07-2479 CIVIL TERM Defendant : IN DIVORCE ;v CUSTODY STIPULATION AND NOW, this / ci day of 2 c f 2007, it is hereby stipulated and agreed between the parties as follows: 1. David Hensel, born January 5, 2002, is the natural child of Shawn A. Hensel and Holly E. Hensel. 2. Shared legal custody of the child as contemplated by the Act of October 30, 1985, P.L. 264, 23 P.S. §5301, et seq., will be in both of the parties, as the natural parents. 3. Primary physical custody of the child shall be in the mother subject to the following periods of partial custody with the father, unless the parties agree otherwise: a. Every Tuesday and Thursday from 9 a.m. until 5 p.m. b. Every other weekend from 9 a.m. Saturday until 6 p.m. Sunday. 4. Alternating holidays from 8:00 a.m. to 7:00 p.m. The holidays shall be New Year's Day, Easter, Memorial Day, 4th of July, and Thanksgiving Day. 5. The parties shall alternate the Christmas holiday. The father shall have custody of the child from 6:00 p.m. Christmas Eve until 3:00 p.m. Christmas Day in odd numbered years and the mother shall have this period in even numbered years. The mother shall have custody of the child from 3:00 p.m. Christmas Day until 6:00 p.m. December 26th in odd numbered years and the father shall have this period in even numbered years. 6. Mother shall have physical custody from 8:00 a.m. until 7:00 p.m. on Mother's Day and Father shall have physical custody from 8:00 a.m. until 7:00 p.m. on Father's Day. 7. The party receiving custody shall provide transportation from the custodial parent's residence. 8. The exchange of custody shall occur at the custodial parent's 'residence, unless other arrangements are made and agreed to by both parties for an alternate place for the exchange of custody, 9. The custodial parent shall inform the non-custodial parent immediately of all medical appointments and problems pertaining to the child. 10. Neither parent shall do or say anything which may estrange the child from the other parent, injure the opinion of the child as to the other parent or hamper the free and natural development of the child's love and respect for the other parent. 11. Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 12. The custodial parent shall provide copies of the child's report card and other reasonable papers affecting the child's education, medical condition, or welfare. 13. Both parents shall be allowed to take the child on out-of-state trips and vacations as agreed to by the parents. Date ?/O LI Date Shawn MHnsel r ; Holly E. lbnsel VERIFICATION I, Lorin Andrew Snyder, Esq., attorney for Petitioner, Shawn A. Hensel, verify that the statements herein are true and correct, to the best of my knowledge and belief, based upon information provided by Petitioner, Shawn A. Hensel. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unsworn falsification to authorities. Date CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Motion to Transfer Venue upon Michael E. Davis, Esq., by depositing the same in the United States Mail, first class, postage pre-paid, on the twenty-fourth day of January, 2008, from Carlisle, Pennsylvania, addressed as follows: Michael E. Davis, Esq. Reisman and Davis Suite 1501 Law and Finance Building Pittsburgh, PA 15219 CES Lon ndrew nyder, Esquire - Su em rt I.D. No. 203199 2QSQuW i treet . Carlisle, PA 17613, (717) 245-9688 Attorney for Defendant U ", IN THE CO"T OF COMMON PLEAS OF POTTER JNTY, PENNSYLVANIA HOLLY E HENSEL Plaintiff VS. SHAWN A HENSEL CIVIL ACTION - LAW CASE NO. 2007-2479 IN DIVORCE Defendant DECREE AND NOW, DEC 3 20 20 it is ordered and decreed that Plaintiff and Defendant are divorced from the bonds of matrimony. The Court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. No such claim was raised by either, party. A Custody Stipulation executed by the parties is attached hereto and incorporated into but not merged with this decree. BY THE COURT: Why PRE NT JUDGE c7 M E _ c?> ii U- c? .; ° FEB 6 2008 AND NOW N CE TIRED A TRUE COPY ;; c AMY J. MOSHIER, PROTH./ CLERK-POTTER CO. PA Reisman and Davis Attorneys for Plaintiff Law & Finance Building Pittsburgh, PA 15219 (412) 232-0406 i ,f HOLLY E. HENSEL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : POTTER COUNTY, PENNSYLVANIA - . `. V. : CIVIL ACTION - LAW y SHAWN A. HENSEL, : NO. 07-2479 CIVIL TERM G; Defendant : IN DIVORCE _ l ^7 4 V CUSTODY STIPULATION co AND NOW, this _ / 9 day of ` Oc f 2007, it is hereby stipulated and agreed between the parties as follows: 1. David Hensel, bom January 5, 2002, is the natural child of Shawn A. Hensel and Holly E. Hensel. 2. Shared legal custody of the child as contemplated by the Act of October 30, 1985, P.L. 264, 23 P.S. §5301, et seq., will be in both of the parties, as the natural parents. 3. Primary physical custody of the child shall be in the mother subject to the following periods of partial custody with the father, unless the parties agree otherwise: a. Every Tuesday and Thursday from 9 a.m. until 5 p.m. b. Every other weekend from 9 a.m. Saturday until 6 p.m. Sunday. 4. Alternating holidays from 8:00 a.m. to 7:00 p.m. The holidays shall be New Year's Day, Easter, Memorial Day, 4t' of July, and Thanksgiving Day. 5. The parties shall alternate the Christmas holiday. The father shall have custody of the child from 6:00 p.m. Christmas Eve until 3:00 p.m. Christmas Day in odd numbered years and the mother shall have this period in even numbered years. The mother shall have custody of the child from 3:00 p.m. Christmas Day until 6:00 p.m. December 2e in odd numbered years and the father shall have this period in even iumbered years. 6. Mother shall have physical custody from 8:00 a.m. until 7:00 p.m. on Aother's Day and Father shall have physical custody from 8:00 a.m. until 7:00 p.m. on =aMer's Day. y r 2 00% 7. The party receiving custody shall provide transportation from the custodial parent's residence. 8. The exchange of custody shall occur at the custodial parent's residence, unless other arrangements are made and agreed to by both parties for an alternate place for the exchange of custody. 9. The custodial parent shall inform the non-custodial parent immediately of all medical appointments and problems pertaining to the child. 10. Neither parent shall do or say anything which may estrange the child from the other parent, injure the opinion of the child as to the other parent or hamper the free and natural development of the child's love and respect for the other parent. 11. Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 12. The custodial parent shall provide copies of the child's report card and other reasonable papers affecting the child's education, medical condition, or welfare. 13. Both parents shall be allowed to take the child on out-of-state trips and vacations as agreed to by the parents. 016 7 --I-L Date V /O//IL-I Date Shawn A. Hensel Holly E. Wilnsel i 3 S IN THE (?%2T OF COMMON PLEAS OF POTTER -JUNTY, PENNSYLVANIA HOLLY E HENSEL Plaintiff ) CIVIL ACTION - LAW VS. ) CASE NO. 2007-2479 SHAWN A HENSEL ) IN DIVORCE Defendant ) r`? w { PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Complaint filed on 05/21/2007. 3. Defendant served on 06/13/2007 by Acceptance of Service. 4. Related claims pending: None . 5. Defendant's Affidavit of Consent and Waiver of Notice required by Section 3301(c) of the Divorce Code executed on 09/12/2007 and filed 09/18/2007. 6. Plaintiff's Affidavit of Consent executed on 09/12/2007 and filed 09/18/2007. Attor or Plaintiff IN THE F CONN0N PLEAS OF POTTER C04TY . PENNSYLVANIA HOLLY E HENSEL ) Plaintiff ) CIVIL ACTION - LAW •V vs. ) w 4 ) CASH NO. 2007-2479 t a SHAWN A HENSEL ) -° I ) IN DIVORCE i Defendant ) C> -n ?M o " 'O m ? z '< a N C To RRM ITRY OF A Drvnurrg D ng =a ccoo 1• Complaint in Divorce under Section 3301(c) of the Divorce Code was filed in the above-captioned action. a. The marriage of Plaintiff and Defendant is irretrievably broken, and at least ninety days have elapsed from the date of filing and service of the Complaint. 3. We consent to the entry of a final decree in divorce without notice. 4. We understand we may lose our rights concerning alimony, division of property, lawyer's fees or expenses if we do not claim them before a divorce is granted. 5. We have been advised of the availability of marriage counseling and understand that we may request that the Court require us to participate in counseling. However, we hereby waive counseling. 6. Defendant hereby waives notice of intention to request entry of a [? divorce decree. y 7. We understand that we will not be divorced entered by the Court and that a cop until a divorce decree is each of us immediately after it is filed with etheeProwill sent thonotary. to EACH OF US verifies that the statements made in this Aff idavit are true and correct. Each understands that to the penalties of 18 Pa. C. e f also statements Section 4904 rela ingi ton unsworn made falsification to authorities. Plaintiff's Signature Dated ?7 • s? Defendant's Sig Sworn to and subscribed by Defendant only before me, a lpu?lic, thi day of COMMONWEALTH OF PENNSYLVANM NOTARIAL SEAL DEBORAH WARREN, Notary PubbNc w4membiq Too., (1Mnbniand Nhr_ notary a0_(2.:?r_ f z Tf-. IK'?K 70 ? 0 Cn 7 = rn 0-+1 ?. -'t7 rn co T" T'1 o ? ?v v IN THE COURT OF COMMON PLEAS OF POTTER COUNTY, PENNSKTAIO -[ p N C N -1 CAD U+ HOLLY E HENSEL Plaintiff } vs. ) SHAWN A HENSEL ) ) Defendant ) CIVIL ACTION - LAW CASE NO. 2007-2479 IN DIVORCE ACCEPTANCE OF SERVICE, SECTION 3201(c) I, the undersigned, Defendant herein, personally received and accepted service of a true and correct copy of the Complaint Under Section 3301(c), Notice to Defend and Claim Rights, and Notice of Availability of Counseling in the above-captioned action. I naive the 30-day expiration of the writ herein in agreement with Plaintiff to do so in accordance with P.R.C.P. 1003 and further agree to the entry of a decree in divorce by the Court of Common Pleas of Potter County, Pennsylvania. I verify that the statements made herein 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__ '3102 Z ad?' Defendant .2s Mailing C AI' -'i" A / 22 t cz s of Defendant i r i ..:'f 3 i x t i IN THE COUR?*F COMMON PLEAS OF POTTER COPWY, PENNSYLVANIA HOLLY E HENSEL Plaintiff VS. CIVIL ACTION - LAW CASE NO. CD SHAWN A HENSEL ) IN DIVORCE _ 1. C) ¢. Defendant ) M COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE Si,-. E?- c n5 Plaintiff resides at 257 NEWBURG RD, NEWBURG, PA 17240. Co V2. Defendant resides at 257 NEWBURG RD, NEWBURG, PA 172.40.. 3. Plaintiff and/or Defendant has/have been (a) bonafide resident(s) of the Commonwealth of Pennsylvania for at least six months immediately prior to the commencement of this action. 4. Plaintiff married Defendant on 11/18/2000 at NEWBURG, PA. 5. There has been no prior action of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that marriage counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in marriage counseling. 8. Plaintiff requests the Court to enter a decree of divorce. 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. Section 4904 relating to unsworn falsification to authorities. Plaintif ?t i Date: 4? 1 ,03? 007 Re' n and Davis Stanley J. Reisman Michael E. Davis Attorneys for Plaintiff Law and Finance Building Pittsburgh PA 15219 (412) 232-0406 _I NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth on the other side of this page, you must t6ke prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree- ecree of divorce or annulment may be entered against you by the, Court. A judgment may also be entered against you for any other claim or relief requested in this paper by the Plaintiff. You may lose money or property or other rights important to vou, including custody or visitation of your child or children. However. in this suit, only a divorce is being sought. No claim or relief is requested by the Plaintiff for child support, child custody or visitation, money, real estate, vehicles. mobile homes, any other personal propert%,, debts, alimonv, pensions, retirement plans or benefits, bank accounts or attornev's fees and expenses. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Amy J. Moshier, Prothonotary Potter County Courthouse One East Second Street, Room 23 Coudersport, PA 16915 Telephone: 814. 274.9740 READ OTHER SIDE r c> 0 HOLLY E. HENSEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SHAWN A. HENSEL, NO. 08 - 113 F C ZA- Defendant CUSTODY PETITION TO MODIFY CUSTODY AND NOW, comes Petitioner Shawn A. Hensel, by and through his attorney, Lorin Andrew Snyder, Esq., who avers as follows: 1. Petitioner is Shawn A. Hensel, an adult individual who currently resides at 302 Hilltop Road, Newburg, Cumberland County, Pennsylvania 17240. 2. Respondent is Holly E. Hensel, an adult individual who currently resides at 257 Newburg Road, Newburg, Cumberland County, Pennsylvania 17240. 3. Respondent filed for divorce in Potter County, Pennsylvania on May 21, 2007. 4. A Divorce Decree was issued by the Honorable John B. Leete of the Court of Common Pleas of Potter County on December 3, 2007, incorporating but not merging an attached Custody Stipulation regarding the parties' minor child. (Exhibit "A" is attached and incorporated herein as if fully set forth.) 5. A Petition to Transfer Venue was filed in Potter County on January 28, 2008. 6. Transfer of venue was directed by the Honorable John B. Leete by Order dated January 29, 2008. (Exhibit "B" is attached and incorporated herein as if fully set forth.) 7. A docket was created for the newly transferred case in Cumberland County on February 21, 2008. 8. Petitioner is seeking modification of the Custody Stipulation/Order entered into by the Court of Common Pleas of Potter County, Pennsylvania, on December 3, 2007, regarding David Hensel, born January 5, 2002, currently residing at 257 Newburg Road, Newburg, PA 17241. 9. Petitioner seeks more substantial periods of physical custody of the child for reasons set forth below. 10. The child is presently primarily in the custody of Respondent. 11. The child has lived with the following parties and at the following addresses: Shawn and Holly Hensel Father & Mother Birth to June 2007 257 Newburg Road Newburg, PA 17240 Holly Hensel Mother June 2007 to Present 257 Newburg Road Newburg, PA 17240 12. Petitioner is the natural father of the child. 13. Respondent is the natural mother of the child. 14. Petitioner entered into the terms of the Custody Stipulation attached in Exhibit "A," with primary physical custody vested in Respondent, upon the expressed assurance of Respondent that she would not relocate out of state. 15. Respondent almost immediately reneged on her agreement to remain in Pennsylvania, having set in motion plans to relocate to 5021 Grand Oak Circle, Apt. 101, Chester, Chesterfield County, Virginia 23831. 16. It is believed that Respondent is likely to complete her move to Virginia, at the latest, in early April, 2008. 17. Respondent plans to relocate to Virginia to cohabitate with and eventually marry her current gentleman friend. 18. Respondent will be essentially the one and only blood relative of the child in Virginia. 19. The child currently has neither family nor friends in Virginia, 20. The child's extended family, both paternal and maternal, reside in the vicinity of where the child currently lives in Cumberland County, Pennsylvania. 21. The child's circle of friends consists mainly of his cousins, who reside in Cumberland County, Pennsylvania. 22. The child currently attends kindergarten in Cumberland County. 23. The December 3, 2007, Custody Stipulation/Order, was fashioned and agreed to under the expressed understanding that both parties would remain in the vicinity of their residence at the time the custody agreement was reached. 24. Respondent's relocation to Virginia will render the existing Custody Stipulation/Order patently impractical and nearly useless. 25. The impracticality of the current Custody Stipulation/Order will allow Respondent as primary physical custodian to essentially usurp physical custody of the child. 26. Petitioner fears that, without modification of the existing custody order, Respondent's relocation to Virginia will result in permanent damage to a continuing, meaningful relationship with his son. 27. Petitioner's home will provide a stable and safe home environment for the child. 28. Petitioner's home will provide a vital, ongoing link between the child and his extended family - cousins, grandparents, uncles and aunts. 29. Petitioner will foster the child's ongoing relationship with all of his next-of- kin. 30. The best interest and permanent welfare of the child will be best served by granting the relief requested for the reasons stated above. WHEREFORE, Plaintiff requests your Honorable Court to schedule a conciliation conference and subsequently grant Petitioner's request for modification of the December 3, 2007 Custody Stipulation/Order and grant Petitioner more significant physical custody befitting the parties' change in circumstances. Respectfully Submitted, c5 4 / 6f Date T Corr ?;der, Esq. 2 o itt Street Ch-As-le, PA 17013 717-245-9688 phone 717.245.2165 fax Attorney for Petitioner VERIFICATION 1, Shawn A. Hensel, verify that the statements contained in the Petition to Modify Custody are true and correct, to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unsworn falsification to authorities. $7l?U.ln 2 Cl ?/-c.? s e? Date Shawn A. Hensel IN THE COURT OF COMMON PLEAS OF POTTER COUNTY, PENNSYLVANIA ' HOLLY E HENSEL Plaintiff vs. SHAWN A HENSEL CIVIL ACTION - LAW CASE NO. 2007-2479 IN DIVORCE Defendant DECREE AND NOW" DEC 3 gg ; 20 it is ordered and decreed that Plaintiff and Defendant are divorced from the bonds of matrimony. The Court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. No such claim was raised,. by either party. A Custody Stipulation executed by the parties is attached hereto and incorporated into but not merged with this decree. BY THE COURT: S/JOHN B. LEETE PRESIDENT JUDGE Reisman and Davis Attorneys for Plaintiff Law & Finance Building Pittsburgh, PA 15219 (412) 232-0406 Tru& and Correct Copy certified from the Records of Potter Co_., Penna. Prothon ary HOLLY E. HENSEL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : POTTER COUNTY, PENNSYLVANIA CIVIL ACTION - LAW _ SHAWN A. HENSEL, : NO. 07-2479 CIVIL TERM - V Defendant : IN DIVORCE i 'e1 CUSTODY STIPULATION AND NOW, this ____L__ day of Oc f 2007, it is hereby stipulated and agreed between the parties as follows: 1. David Hensel, born January 5, 2002, is the natural child of Shawn A. Hensel and Holly E. Hensel. 2. Shared legal custody of the child as contemplated by the Act of October 30, 1985, P.L. 264, 23 P.S. §5301, et seq., will be in both of the parties, as the natural parents. 3. Primary physical custody of the child shall be in the mother subject to the following periods of partial custody with the father, unless the parties agree otherwise: a. Every Tuesday and Thursday from 9 a.m. until 5 p.m. b. Every other weekend from 9 a.m. Saturday until 6 p.m. Sunday. 4. Alternating holidays from 8:00 a.m. to 7:00 p.m. The holidays shall be New Year's Day, Easter, Memorial Day, 4th of July, and Thanksgiving Day. 5. The parties shall alternate the Christmas holiday. The father shall have custody of the child from 6:00 p.m. Christmas Eve until 3:00 p.m. Christmas Day in odd numbered years and the mother shall have this period in even numbered years. The mother shall have custody of the child from 3:00 p.m. Christmas Day until 6:00 p.m. December 26th in odd numbered years and the father shall have this period in even numbered years. 6. Mother shall have physical custody from 8:00 a.m. until 7:00 p.m. on Mother's Day and Father shall have physical custody from 8:00 a.m. until 7:00 p.m. on Father's Day. 7. The party receiving custody shall provide transportation from the custodial parent's residence. 8. The exchange of custody shall occur at the custodial parent's residence, unless other arrangements are made and agreed to by both parties for an alternate place for the exchange of custody. 9. The custodial parent shall inform the non-custodial parent immediately of all medical appointments and problems pertaining to the child. 10. Neither parent shall do or say anything which may estrange the child from the other parent, injure the opinion of the child as to the other parent or hamper the free and natural development of the child's love and respect for the other parent. 11. Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 12. The custodial parent shall provide copies of the child's report card and other reasonable papers affecting the child's education, medical condition, or welfare. 13. Both parents shall be allowed to take the child on out-of-state trips and vacations as agreed to by the parents. Date Date Shawn A. Hensel Holly E. nsel HOLLY E. HENSEL, Plaintiff V. SHAWN A. HENSEL Defendant IN THE COURT OF COMMON PLEAS OF POTTER COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007-2479 ORDER OF COURT AND NOW, this day of ) A/ , 2008, upon review of the attached Petition to Transfer Venue, it is hereby ORDERED that the above referenced action is to be transferred by the Prothonotary of Potter County, Pennsylvania to Cumberland County, Pennsylvania. BY THE COURT: S/,JOHN 8- LEETE J. C.C. Lorin Andrew Snyder, Esq. Michael E. Davis, Esq. Prothonotary of Potter County Prothonotary of Cumberland County CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Petition to Modify Custody upon Holly Hensel, by certified mail, return receipt requested, postage pre- paid, and by depositing the same in the United States Mail, first class, postage pre-paid, on the Twenty-First day of February, 2008, from Carlisle, Pennsylvania, addressed as follows: Holly E. Hensel 257 Newburg Road Newburg, PA 17240 TURD L_&W OFFICES LLo ndrew §fiyder, Esquire upreme rt I. D. No. 203199 ?2N out Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Petitioner w d O u? 0 d 0 l J r1). N) r•- 4 HOLLY E. HENSEL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-1138 CIVIL ACTION LAW SAWN A. HENSEL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, February 28, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 10, 2008 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: /s/ Hubert X. Gilroy, 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, (10 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 .17 r- HOLLY E. HENSEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SHAWN A. HENSEL, NO. 08 - 1138 Defendant CUSTODY CUSTODY STIPULATION AND NOW, this PO day of r rr-k , 2008, it is hereby stipulated and agreed between the parties as follows: 1. All previously existing custody orders are hereby vacated. 2. David Jesse Hensel (hereinafter the "Child"), born January 5, 2002, is the natural child of Shawn A. Hensel (hereinafter the "Father") and Holly E. Hensel (hereinafter the "Mother"). 3. Shared legal custody of the child as contemplated by the Act of October 30, 1985, P.L. 264, 23 P.S. §5301, et seq., will be in both of the parties, as the natural parents. Major decisions concerning the Child, including, but not necessarily limited to, the Child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the Child's best interest. Each parent shall not impair the other party's rights to shared legal custody of the child. Each parent shall not alienate the affections for the Child from the other party. Each parent shall notify the other of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the parent then having physical custody. With regard to any emergency decisions that must be made, the party having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as thereafter possible. Each parent shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a guardian or custodian. r. . Primary physical custody of the Child shall be in the Mother subject to the 4. with the Father: following periods of partial physical custody a. The Father shall have custody of the Child every other weekend from 7 p.m. Friday until 7 p.m. Sunday. b. The Father shall have custody of the Child in the summer, with from the second day following the last day of school until July 31 st. C. The Mother shall have custody of the Child for one week inJune and July, during the Father's period of summer custody, which weeks to be mutually agreed upon by the parties. d. The Father shall have custody of the Child for one week in August, which week to be mutually agreed upon by the parties. from 7 pm. on the holiday 5. Custody of the Child shall alternate and rotate, Easter, Memorial eve to 7 p.m. on the day of the holiday, for the following holidays: Day, and the Fourth of July. a. The Father shall have custody of the Child on Memorial Day in even-numbered years. b. The Mother shall have custody of the Child on Easter and the Fourth of July in even-numbered years. of the Child on Easter and the C. The Father shall have custody Fourth of July in odd-numbered years. d. The Mother shall have custody of the Child on Memorial Day in odd-numbered years. 6. The Thanksgiving holiday shall alternate and rotate as follows: in a. The Father shall have custody of the Child on Thanksgiving even-numbered years, from 7 p.m. on Thanksgiving Eve until 12 p.m. on the Saturday immediately following Thanksgiving. the Child on Thanksgiving in odd- b. The Mother shall have custody numbered years. 7. The Christmas and New Year's holidays shall alternate and rotate as follows: a. In "Year A," the Father shall have custody of the Child from 9 a.m. on December 24th until 4 p.m. on December 28th. b. In "Year B," the Father shall have custody of the Child from 9 a.m. on December 28th until 4 p.m. on January 1st. C. The "Year A" custody scenario shall occur in odd-numbered years. d. The "Year B" custody scenario shall occur in even-numbered years. 8. The Mother shall have physical custody of the Child from 9 a.m. until 6 p.m. on Mother's Day and the Father shall have physical custody of the Child from 9 a.m. until 6 p.m. on Father's Day. 9. While in the presence of the Child, no party shall make or permit to be made by any person, any remarks or actions which could in any way be construed as derogatory or uncomplimentary to the other parent, or in any way injure the opinion of the Child as to the other parent, or in any way estrange the Child from the other parent. It shall be the responsibility of each party to uphold the other parent as one to whom the Child owes love and respect. 10. Both parents shall have liberal and reasonable telephone contact with the Child when the Child is in the custody of the other parent. 11. The custodial parent shall provide to the non-custodial parent, in a timely fashion, any and all information regarding the Child's educational progress, religious training, mental health, physical health, welfare and social events, including copies of the Child's report card and other reasonable papers affecting the child's education, medical condition, or welfare. 12. Each parent shall make a reasonable effort to ensure the Child's well- rounded development by involving the Child in at least one extracurricular activity and ensuring that the Child possesses and actively uses a library card. 13. The exchange of custody shall occur at a halfway-point between the two parties' residences, defined as the McDonalds restaurant at Exit 222 off of Route 81, unless otherwise mutually agreed upon by the parties. 14. The provisions in this Order shall be strictly adhered to unless otherwise agreed upon by the parties herein. The parties are free to modify the terms of this Order but, in order to do so, the Court makes it clear that both parties must be in complete agreement to any new terms. In other words, both parties must consent on what shall be the new terms of the custody arrangement or visitation schedule. 15. In the event either party wishes to modify this Stipulation/Order, they may petition to have the case scheduled with the Court. /. Date Date 3111,167 Date Shawn A.-Hansel Holly J. T 3Scv Ol/ mil' ors • 7 ty ?`' ' -?? ,rrv sa?do - gOlY1?F' ?,I a :.. .,t d{ I:? 11 :6 14V ?I NVW HIE MAR 14 2008 r''/ HOLLY E. HENSEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW SHAWN A. HENSEL, NO. 2008-1138 Defendant IN CUSTODY COURT ORDER AND NOW, this ( day of March, 2008, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. Gl( K Hubert X. Gil y, Esquire Custody Co iliator ?? ???' i ? ? ?1 ?l1 1 ? i.?: ? ('-+.. ? _ ? .1 ?..' i "?; ? ?J r ' ,,? , _ ?? `"" ?, ? -- _• --.... ? ?? 7-, .? ? ?? O ~~ 1 HOLLY E. HENSEL IN THE COURT OF COMMON PLEAS OF 1'I,A[NTIFF CUMBERLAND COUNTY, PENNSYLVANIA ~~ 2008-1138 CIVIL ACTION LAW SHAWN A. HENSEL DF:FI~,NDANT IN CUSTODY ORDF,R OF COURT AN[) NOw', _ Friday, Jul~_02, 2010 ,upon consideration of the attached Complaint, it is h~rcby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, pit 4th Floor ,Cumberland County Courthouse, Carlisle on Friday, August 13, 2010 _ _ at 10:30 AM for a Prc-I-Icarin~~ Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent. order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilro Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans ~~rith Disabilites Act o~f 1990. For information about accessible facilities and reasoi~~able accommodations available to disabled. individuals having business before the court, please contact our office. All. arrangements must he made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled con fercnce or hearing. YOU SHOULD "TAKE THIS PAPER TO YOUR ATTORNEY A"T ONCE. IF YOU DO NOT 1-IAVI~ AN A"I'TORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFF~1.~E S~T ~ FC}R~fF{ BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. C o '' umberland Count Bar Association -r3~ ~ ~_ ~ ;~: ' 32 South Bedford Street ~ ~ ~ ~, ,xc~-~ ~Q-?.r~~ Carlisle, Pennsylvania 17013 •~. ~ ~. ~ ~ ` ', I. _ ~ w U a Telephone (7] 7) 249-3166 Z 7• 1 C~ /l~c~-1i cam. >'~•~ ~~ -~-b '~~ ~ ~ ~. w -c- ~~` :. , , ~ ~~ ~ ~... -~ ~ ~ 7- a• ~ o ~ lac ~~- ail 's ~;te... `~" my _ ABOM ~' KuTLiLAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 HOLLY E. HENSEL, Plaintiff v. SHAWN A. HENSEL Defendant zoo ~~t~ -~ ~~ ~~: ~~. C~''s1.~ , ~iV;Y -.: .,_;~~ r ;, ,, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO.08-1138 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY AFFIDAVIT OF SERVICE I, Kara W. Haggerty, hereby certify that I did serve a true and correct copy of the Petition to Modify Custody, upon the Plaintiff, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, on July 2, 2010, at Fayetteville, Pennsylvania, addressed as follows: Holly Hensel 1032 Knob Hill Road Fayetteville, PA 17222 Return card acknowledging receipt on July 2, 2010, is attached as Exhibit "A". ABOM & KUTULAKIS, LLP t Date: ,~ ~ ~ ~~~ ~c ~ L, C~- - ~ ~. , `C. Kara W. Haggerty, Es txit(e 2 West High Street Carlisle, PA 17013 (717)249-0900 Attorney for Plainti~ I.D. No: 86914 aS - /~3~ o-z~ ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this cans to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. Sig , ure X' B• gee by (Prlnied Name) // r / I~-ol~~ `~,,,~- to3a Kn•m~ ~, (lo( -~ P~ ~7zZZ C~ ~~ ^ Agent D. IsHelivery address different from item-~ If YES, enter delivery address below: ^ No a. ~enrrce Type ~Cerdffed Mail ^ Express Mall O Registered ^ Retum Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) Y~ 2. Article Number (~+fer~rom,ark~~1 7028 1830 023 5942 5616 PS Form 3811, February 2004 Domestic getum Receipt 102585-02•M-1540 Exhibit "A" AUG 1 8 LU1U HOLLY E. HENSEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW SHAWN A. HENSEL, NO. 2` H-1138 Defendant IN CUSTODY Prior Judge: The Honorable Edward E. Guido COURT ORDER NOW, this o4l?aY of August 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is s heduled in Cou oom No. 3 of the Cumberland County Courthouse on the oR day of , 2010 at ?.m. At this hearing, the father shall be the moving party and shall proceed initially with testimony. Counsel for the parties, or the parties themselves if they do not have counsel, shall file with the Court and opposing counsel/party a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this court's prior order of March 10, 2008, shall remain in effect subject to the following modifications: A. Once school starts, father's periods of alternating weekends shall commence when the child is released from school on Friday afternoon until Monday morning when the father shall return the child to school. 3 B. For the remainder of the summer, father's periods of custody shall include from Friday, August 13, 2010, through Wednesday, August 18 at 6:00 p.m. Additionally, father's periods of custody shall be from Friday, August 20 at 6:00 p.m. through Tuesday, August 24, at noon. C. Father's pre-planned trip to Orlando in November shall continue as scheduled and father shall have custody for that trip. 3. In th event mother retains legal counsel and her attorney believes that a second custody conciliation would aid in a possible amicable resolution of the case, mother's attorney may contact the custody conciliator directly to schedule another custody conciliation prior to the hearing. BY , Edward E.'Guido, Judge cc: !'/Kara W Haggerty, Esquire d Ms. Holly E. Hensel 1) 1 0-L lei t '. . W w HOLLY E. HENSEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW SHAWN A. HENSEL, NO. 0"-1138 Defendant IN CUSTODY Prior Judge: The Honorable Edward E. Guido CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: David Jesse Hensel, born January 5, 2002 2. A Conciliation Conference was held on August 13, 2010, with the following individuals in attendance: The mother, Holly E. Hensel, who appeared without counsel, and the father, Shawn A. Hensel, with his counsel, Kara W. Haggerty, Esquire 3. There is an existing order from March of 2008 which gave father extensive time in the summer and alternating weekends during the school year. Father is now seeking a traditional 50/50 shared custody arrangement on a week on/week off basis. Although mother may be inclined to agree to something along those lines during the summer, mother believes she should retain primary physical custody during the school year. The parties are unable to reach an agreement and the Conciliator recommends an Order in the form as attached. Date: August (3-1 2010 HGilroy, Esquire Custody Conciliator } k ~ HOLLY E. HENSEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW SHAWN A. HENSEL, NO. 08-1138 Defendant CUSTODY ORDER OF COURT AND NOW, this 21st day of October, 2010, after hearing, our Order of August 24, 2010 is vacated. Paragraph 4 of our Order of March 10, 2008 is amended to provide the following: 4. Primary Physical Custody: a. Mother shall have primary physical custody of the child during the school year, with partial physical custody in Father every other ~ ~ ~ weekend from Thursday after school until Monday ~o 0 0~ at the beginning of school. It shall be Father's z ~~ ~ ~ ~ ° ~ responsibility to pick the child up after school ~ w~ ~ ~~-~*,._ on Thursday and to deliver him to school on =1esi ~-M ~„~ o ww ~Q- Monday . ~ N (~ b. Beginning the Sunday after school recesses for the summer, the parties shall share physical custody on a week-on/week-off basis. The custody exchange shall occur at 7:00 p.m. on Sunday evenings unless otherwise agreed to by the parties. The school year schedule shall recommence after Father has had his first full week of partial custody in August. c. Father shall have custody of the child from after school on November 9, 2010 until he returns from the trip to Disney World on November 15, 2010. 4,. ., ~ Hensel v. Hensel No. 08-1138 Civil Term Paragraph 13 shall be amended to provide the exchange of custody shall occur at the Turkey Hill in Shippensburg unless otherwise mutually agreed upon by the parties. In all other respects, our Order of March 10, 2008 shall remain in full force and effect. By the Court, Edward E. Guido, J. Holly E. Hensel 716 Pinola Road Shippensburg, PA 17257 Kara W. Haggerty, Esquire Attorney for Defendant srs 1 ES rr~ t ~4c~. ! o~ss~~a