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HomeMy WebLinkAbout08-2069LAURA LAUBACH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 6,'- ,2o[. ? Civil Term DOUGLAS TAYLOR, ACTION IN CUSTODY Defendant 1. Plaintiff is Laura Laubach, (hereinafter referred to as "Mother"), who currently resides at 176 Virginia Avenue, Carlisle, Cumberland County, Pa. 17013. 2. Defendant is Douglas Taylor (hereinafter referred to as "Father"). It is believed he lives with his mother, Mary Brehm, at 430 Nealy Road, Newville, Cumberland County, Pa., 17241. 3. Plaintiff and Defendant are the natural parents of the following child. Mother is seeking a custody order regarding the child. NAME DOB/AGE ADDRESS Matteo Taylor 11/20/06 176 Virginia Ave. Carlisle, Pa. 17013 Mother and Father are not married. Mother currently has primary physical custody of the child. CUSTODY COMPLAINT During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES DATES Laura Laubach P.O. Box 232 Diana and Rodney Benton, Pa. 17814 Van Pelt, (maternal grandparents) Birth - July 2007 Laura Laubach 176 Virginia Ave. July 2007 - Jan. 2007 Douglas Taylor Carlisle, Pa. 17013 Max Whitenight, cousin Laura Laubach Carrie Miller, friend Shawn Murphy, friend 176 Virginia Ave. Jan. 2007 - present Carlisle, Pa. 17013 The mother of the child is Laura Laubach. She currently resides at 176 Virginia Ave., Carlisle, Cumberland County, Pennsylvania. She is not married. The father of the child is Douglas Taylor. He currently resides with his mother, at 430 Nealy Road, Newville, Cumberland County, Pennsylvania. He is not married. 4. The relationship of plaintiff to the child is that of Mother. The plaintiff currently resides with the child and her friends. 5. The relationship of defendant to the child is that of Father. The defendant currently lives with his mother. 6. 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: The parties lived together until January 2007, when Father moved out and Mother retained physical custody of the child. Mother is seeking a custody Order which would confirm that she has primary physical custody. This request is the in the best interest of the child because it would provide stability for the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the child. Date: Respectfully submitted, J e Adams, Esquire .D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Custody 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. Date: y(i/oa' aura La ach, Plaintiff ?-5 S_,l ?1 r4?! 1 «??1 y ?? (? ?ytl? "? ? ??? r _ r'?q Q ? ? ? tl l +'' J i°1? N -i v ? ? ?? ?'? o ? LAURA LAUBACH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DOUGLASTAYLOR DEFENDANT 2008-2069 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 04, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at_ 4th Floor, Cumberland County Courthouse, Carlisle on Monday, April 28, 2008 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. 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/ john j. Mangan, r. Es . jbA 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 Ak Jo-h-h MAY 19 2008{N'' LAURA LAUBACH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-2069 CIVIL ACTION LAW DOUGLAS TAYLOR, IN CUSTODY Defendant ORDER OF COURT AND NOW this a49 ?4 day of May 2008, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: Legal Custody: The Father, Douglas Taylor, and the Mother, Laura Laubach, shall have shared legal custody of Matteo Taylor, born 11/20/2006. The parties shall have an equal right 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 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. Physical Custody: Mother shall have primary physical custody of the Child subject to Father's partial physical custody as follows: a. On May 18, 2008, the Father shall have the right to a visit with Matteo at Mother's residence from 5:00 pm until 8:00 pm should Father desire or deem appropriate. b. Commencing Saturday May 24, 2008, Father shall have physical custody every other weekend Saturday from 9:00 am until 3:00 pm and Sunday from 9:00 am until 3:00 pm. Should the parties agree that Father's custodial period with Matteo take place at paternal grandmother's residence in Newville, PA, Mother shall provide the transportation. In the absence of agreement, the parties shall meet at the designated times at the Carlisle Police station parking lot. C. Commencing Friday July 25, 2008, Father shall have physical custody of the Child on alternating weekends from Friday at 4:30 pm until Sunday at 4:30 pm. Should the parties agree that Father's custodial period with Matteo take place at paternal grandmother's residence in Newville, PA, Mother shall provide the transportation. In the absence of agreement, the parties shall meet at the designated times at the Carlisle Police station parking lot. d. Father shall have addition periods of physical custody of the Child as mutually agreed to and the parties may alter/expand said times and days as mutually necessary or proper. 3. The transporting parent shall ensure that appropriate child seats/restraints are used in transporting the Child. 4. Holidays: The parties agree to alternate holidays beginning with Father having Memorial Day from 9:00 am until 6:00 pm and Mother having Fourth of July from 9:00 am until 6:00 pm. Father shall have Father's Day from 9:00 am until 3:00 pm. In the absence of agreement otherwise, the parties shall arrange holidays as attached. 5. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. The parties shall ensure that any and all communication between the parties be done in a civil and appropriate manner. 6. Neither party may say or do anything nor permit a third party to do or say 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. To the extent possible, both parties shall not allow third parties disparage the other parent in the presence of the Child. 7. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 8. During any periods of custody or visitation, the parties shall not possess or use non-prescribed controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 9. In the event the custodial parent should take the Children out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 10. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. 11. At any point after September 29, 2008, either party may contact the assigned conciliator for status update conciliation conference to address whether additional periods of custodial time with Father is necessary or appropriate. distribution: n ?Jane Adams, Esq. "? 'O'n ,Marlin Markley, Jr., Esq. ?t LQ(_ ,/fohn J. Mangan, Esq.a By the Court, HOLIDAYS AND TIMES EVEN ODD SPECIAL DAYS YEARS YEARS Easter Da 1St Half From 9 am until 3 m Father Mother Easter Day 2" Half From 3 m until 9 m Mother Father Memorial Day From 9 am until 6 pm Father Mother Independence Da From 9 am until 6 pm Mother Father Labor Day From 9 am until 6 m Father Mother Halloween From one hour before trick or Mother Father treating to one hour after trick or treating Thanksgiving 1" From 8 am Thanksgiving Day to 2 Father Mother Half m on Thanks ivin Da Thanksgiving 2° From 2 pm on Thanksgiving Day to Mother Father half noon the day after Thanksgiving Da Christmas 1 St Half From noon on 12/24 to noon on Mother Father 12/25 Christmas 2" Half From noon on 12/25 to noon on Father Mother 12/26 New Year's From 6 pm 12/31 until noon January Mother Father 1St (with the 12/31 year to control the even/odd determination) Mother's Da From 9 am until 3 pm Mother Mother Father's Da From 9 am until 3 m Father Father LAURA LAUBACH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-2069 CIVIL ACTION LAW DOUGLAS TAYLOR, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: f Name Matteo Taylor Date of Birth 11/20/2006 Currently in the Custody o Mother 2. A Conciliation Conference was held with regard to this matter on May 16, 2008 with the following individuals in attendance: The Mother, Laura Laubach, with her counsel, Jane Adams, Esq. The Father, Douglas Taylor, with his counsel, Marlin Markley, Jr., Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date JEsquire ciliator LAURA LAUBACH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DOUGLAS TAYLOR, : NO. 08 - 2069 CIVIL TERM Defendant : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY NOW, comes the plaintiff, LAURA LAUBACH, and presents this petition for modification of custody of the parties minor child, representing as follows: 1. Petitioner is LAURA LAUBACH, an adult individual residing at P.O. Box 232, Benton, Columbia County, Pennsylvania 17814. 2. Respondent is DOUGLAS TAYLOR, an adult individual residing at 508 West North Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of a minor child, namely, MATTEO TAYLOR (born November 20, 2006). 4. The parties are subject to an Order of this Court, dated May 20, 2008, a copy of which is incorporated herein by reference and attached hereto as Exhibits "A". 5. Petitioner seeks to modify the present custody order in effect by establishing a location for exchange of custody of the child that it is mid-way between the parties' respective residences (Sheetz, Route 15, Shamokin Dam, Pennsylvania). At present the parties live two hours apart and the petitioner makes the four hour round trip every other weekend. 6. Petitioner does not know of a person not a party to this proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as a party to this action. 8. The best interests and permanent welfare of the child will be served by granting the relief requested. WHEREFORE, petitioner requests the Court to modify the current custody Order by adjusting the location for the exchange of custody between the parties as aforesaid. I?bveM? Me peh ,,a4_, 2009 U Petitioner VERIFICATION I do hereby verify that the acts set forth in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4404, relating to unsworn falsification to authorities. Vajembcr Moo *11 .34_, 2009 3 U BACH LAURA LAUBACH PO BOX 232 BENTON PA 17814 DOUGLAS TAYLOR W- / spruc r 4c%e CARLISLE PA 17013 LAURA LAUBACH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-2069 CIVIL ACTION LAW DOUGLAS TAYLOR, IN CUSTODY Defendant K11-4 P FA V (11?.Ulliu -I IT, r1 1144 .. IN ACCORDANCE WrM CU1VMERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Matteo Taylor 11/20/2006 Mother 2. A Conciliation Conference was held with regard to this matter on May 16, 2008 with the following individuals in attendance: The Mother, Laura Laubach, with her counsel, Jane Adams, Esq. The Faber, Douglas Taylor, with his counsel, Marlin Markley, Jr., Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date J J. Esquire fonciliator 03/27/2009 15:35 5709250323 LAURA LAUBACH, Plaintiff V. DOUGLAS TAYLOR, Defendant ROD VANPELT PAGE 02 MAY i e=or/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-2069 CPAL ACTION LAW IN CUSTODY 0-RDER O r COM AND NOW this of May 2008, upon consideration of the attached Custody _Cga!?day Conciliation Report, it is Ordered and Directed as follows: 1. Lc Cur dv: The Father, Douglas Taylor, and the Mother, Laura Laubaeh, shall have shared legal custody of Matteo Taylor, born 11/202006. The parties shall have au equal right 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 ragords and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child 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 infomia?tion of reasonable use to the other parent. 2. Physical C dY: Mother shall have primary physical custody of the Child subject to Father's partial physical custody as follows: a. On May 18, 2008, the Father shall have the right to a visit with Matteo at Mother's residence from 5:00 pm until 9:00 pm should Father desire or deem appropriate. b. Commencing Saturday May 24, 2008, Father shall have physical custody every other weekend Saturday from 9:00 an until 3:00 pm and. Sunday from 9:00 am until 3:00 pm. Should the parties agree that Father's custodial period with Matteo take place at paternal ms's residence in Newville, PA, Mother shall provide the transportation. In the absence of agreement, the parties shall meet at the designated times at the Carlisle Police station parking lot. C. Commencing Friday July 25, 2008, Father shall have physical custody of the Child on alternating weekends from Friday at 4:30 pm until Sunday at 4:30 pm. Should the parties agree that Father's custodial period with Matteo take place at paternal grandmother's residence in Newville, PA, Mother shall provide the transportation. In the absence of agcAw? the parties shall meet at the designated times at the Carlisle Police , n parking lot d. Father shall have addition periods of physical custody of the Child as mutually agreed to and the parties may alter/expand said times and days as mutually nocessay or proper. 3. The transporting parent shall ensure that appropriate child seatstrestraints are used in transporting the Child. K x? ' 4. Holidays: The parties agree to alternate holidays beginning with Father having Memorial Day from 9:00 am until 6:00 pm and Mother having Fourth of July from 9:00 am until 6:00 pm. Father shell have Father's Day from 9:00 am until 3:00 pm. In the absence of agreement otherwise, the parties shall arrange holidays as attached. S. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. The parties shall ensure that any and all communication between the parties be done in a civil and appropriate manner. 6. Neither party may say or do anything nor permit a third party to do or say 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. To the extent possible, both parties shall not allow third parting disparage the other parent in the presence of the Child, - -- 7. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable aft the emergency is handled. 8. During any periods of custody or visitation, the parties shall not possess or use non-prescribed controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 9. In the event the custodial parent should take the Children out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 10. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control, 11. At any point after September 29, 2008, either parry may contact the assigned conciliator for status update conciliation eonfavnce to addrm whether additional periods of custodial time with Father is neoewary or appropriate. By dw Court, rho ? 4L .j'". Distribution: Jane Adams, Esq. Marlin Markley, Jr., Esq. John J. Mangan, Esq. TRUE COpr I.; F :: ? a.? -in Town lmy whareof, l two ur'F5 V, i J9 .: ?d cowl ' i Low ? ifai?. 171 rNa deY S «rothondtarll _ 03/27/2009 15:35 5709250323 ROD VANPELT PAGE 05 HOLIDAYS AND SPECIAL DAYS TEMS E'V'EN YEARS ODD YEARS Easter Da 1 Half From 9 am until 3 Father Mother Easter Da 2 Half From 3 m until 9 Mother Father Memorial Da From 9 am until 6 Father Mother Da From 9 am until 6 Mother Father Labor Da From 9 am until 6 m Father Mother Halloween From one hour before trick or treating to one hour after trick or mother Father Thanksgiving 1 Half From 8 am Thanksgiving Day to 2 on Tbutualcs giving Day Father Mother Thanksgiving 2 half From 2 pm on Thanksgiving Day to noon the day after Thanksmv= My Mother Father Christmas 1 Half From noon on 12/24 to noon on 12125 Mother Father Christmas 2 Half From noon on 12/25 to noon on 12/26 Father Mother New Year's From 6 pm 12/31 until noon January 1" (with the 12/31 year to control the even/odd determination Mother Father Mother's Da From 9 am until 3 pm I Mother Mother Father's Da From 9 am until 3 pm I Father Father qii FI('??_ r _ 20P? 9?. ti{ Ui! i a -)&, 6LlroJ- ? ck # a&- F-346 SY -3 ?l k-# , , ?l? LAURA LAUBACH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-2069 CIVIL ACTION LAW DOUGLASTAYLOR IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, December 03, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, January 07, 2010 at 10:00 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/ john. Man an r. 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 ;'l :fat"+" _ qF TFF ?at'' 1'.sy ?Ytf i? l 3 Dom' 2004 DEC -3 P 2: 59 LJL1 a... ,??, 1 a-4 FEB 16 2010 LAURA LAUBACH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-2069 CIVIL ACTION LA V, Q ` ? DOUGLAS TAYLOR, -rr 71 IN CUSTODY rn rTJ Defendant Co - Z r- m Prior Judge: J. Wesley Oler, Jr., J. ; C,3 5M ORDER OF COURT w fi rv -? AND NOW this t 6 1 day of February 2010, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: The prior Order of Court dated May 20, 2008 is hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, Douglas Taylor, and the Mother, Laura Laubach, shall have shared legal custody of Matteo Taylor, born 11/20/2006. The parties shall have an equal right 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 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. 3. Physical Custody: Mother shall have primary physical custody of the Child subject to Father's partial physical custody on a repeating schedule as follows: a. Commencing Thursday February 11, 2010, Father shall have physical custody of Matteo from Thursday (the exchange time by agreement pursuant to the parties' schedules, in the absence of agreement, at 2:00 pm if Mother does not have school and at 6:00 pm if Mother does have school) until Sunday at 2:00 pm. b. Commencing Sunday February 21, 2010, Father shall have physical custody from Sunday at 2:00 pm until the following Sunday at 2:00 pm. C. The parties shall share the transportation obligations for the exchanges by meeting approximately half way between their respective residences at the designated times. In the absence of agreement, the parties shall meet at the Sheetz in Selingsgrove, PA for the exchanges. d. The parties may alter/expand said times and days as mutually necessary or proper. 4. The transporting parent shall ensure that appropriate child seats/restraints are used in transporting the Child. 5. Holidays: The parties agree to alternate holidays beginning with Father having Memorial Day from 9:00 am until 6:00 pm and Mother having Fourth of July from 9:00 am until 6:00 pm. Father shall have Father's Day from 9:00 am until 3:00 pm. In the absence of agreement otherwise, the parties shall arrange holidays as attached. The transportation obligations for the holiday exchanges shall take place pursuant to sub-paragraph 3 (c) above if the parties can not agree to alternative arrangements. 6. The parties have agreed to, and shall, arrange the summer schedule with Matteo to coordinate with Matteo's other siblings to maximize his time with his siblings. 7. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. The parties shall ensure that any and all communication between the parties be done in a civil and appropriate manner. 8. Neither party may say or do anything nor permit a third party to do or say 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. To the extent possible, both parties shall not allow third parties disparage the other parent in the presence of the Child. 9. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 10. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 11. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 12. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Dom' tribution: ? Jane Adams, Esq. ./K4'ichael Whare, Esq. _-'Toohn J. Mangan, Esq. 6 ezS IYL?Z L By the Court, TIMES EVEN ODD HOLIDAYS AND YEARS YEARS SPECIAL DAYS Easter Day 1St Half From 9 am until 3 m Father Mother Easter Da 2° Half From 3 pm until 9 m Mother Father Memorial Day From 9 am until 6 m Father Mother Independence Day From 9 am until 6 m Mother Father Labor Day From 9 am until 6 m Father Mother Halloween From one hour before trick or Mother Father treating to one hour after trick or treating Thanksgiving 1St From 8 am Thanksgiving Day to 2 Father Mother Half pm on Thanksgiving Da Thanksgiving 2" From 2 pm on Thanksgiving Day to Mother Father half noon the day after Thanksgiving Day Christmas 1St Half From noon on 12/24 to noon on Mother Father 12/25 Christmas 2 Half From noon on 12/25 to noon on Father Mother 12/26 New Year's From 6 pm 12/31 until noon January Mother Father 1St (with the 12/31 year to control the even/odd determination) Mother's Day 11 From 9 am until 3 m Mother Mother Father's Day From 9 am until 3 m Father Father Reeular Phvsical Custodv Schedule Monday Tuesday Wednesday Thursday Friday Saturday Sunday M M M M D D D D M M M M M M M M D D D D D D D D M M M M M M M M LAURA LAUBACH, Plaintiff V. DOUGLAS TAYLOR, Defendant Prior Judge: J. Wesley Oler, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-2069 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Matteo Taylor Date of Birth 11/20/2006 Currently in the Custody of Primary Mother/Partial Father 2. A Conciliation Conference was held with regard to this matter on May 16, 2008, an Order was issued May 20, 2008, a conference was scheduled for January 07, 2010 and continued until February 11, 2010 with the following individuals in attendance: The Mother, Laura Laubach, with her counsel, Jane Adams, Esq. The Father, Douglas Taylor, with his counsel, Michael Whare, Esq. 3. The parties agreed to the entry of an Order in the form as attached. 2 Date Jo angan, Esquire Cus od Conciliator