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HomeMy WebLinkAbout08-4220II F:\DOCS\FL\COST\Parthemore.Stephen-complaint.wpd ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF STEPHEN KARL PARTHEMORE, Plaintiff V. MICHELLE E.N. KENDRA PARTHEMORE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY NO. COMPLAINT FOR CUSTODY 1. The plaintiff is STEPHEN KARL PARTHEMORE, an adult individual, residing at 1805 Charles Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. The defendant is MICHELLE E.N. KENDRA PARTHEMORE, an adult individual, currently residing at her parents at 1521 Terrace Road, Harrisburg, Dauphin County, Pennsylvania, 17109. 3. Plaintiff seeks custody of QUENTIN THOMAS PARTHEMORE, born July 5, 2000, age eight (8), LANCE STEPHEN PARTHEMORE, born August 29, 2001, age six (6), GARRISON ANGLIN PARTHEMORE, born May 12, 2003, age five (5), and GWYNETH MICHELLE PARTHEMORE, born July 10, 2005, age -1- three (3), who all resided at 1805 Charles Street, New Cumberland, Cumberland County, Pennsylvania, 17070. The children were not born out of wedlock. The children are presently in the custody of Mother who resides at 1521 Terrace Road, Harrisburg, Dauphin County, Pennsylvania, 17109. During the past five years, the children have resided with the following persons and at the following addresses: NAME Plaintiff and Defendant Defendant ADDRESS DATES 1805 Charles Street birth to New Cumberland, PA Present 1521 Terrace Road 6-3-08 to Harrisburg, PA Present The mother of the children is MICHELLE E.N. KENDRA PARTHEMORE, currently residing at 1521 Terrace Road, Harrisburg, Dauphin County, Pennsylvania, 17109. The father of the children is STEPHEN KARL PARTHEMORE, currently residing at 1805 Charles Street, New Cumberland, PA. The parties are currently husband and wife. 4. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following persons: NAME RELATIONSHIP N/a -2- L 5. The relationship of defendant to the children is that of mother. The defendant currently resides with the following persons: NAME RELATIONSHIP Mr. & Mrs. Tom Kendra Maternal grandparents 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 children pending in a Court of this Commonwealth. 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 because: (a) The children have resided with the father since birth who has provided a continuous living relationship with the child; (b) The father is able to provide a stable home and family type environment for the children allowing the children opportunity to spend time with the children's mother consistent with a schedule the parties have arranged between themselves. (c) The Mother is not stable at this time as she has become increasingly paranoid of other religions, foods, and has become -3- preoccupied and obsessed with her religion to the detriment of the children's health, welfare, and emotional well-being. (d) The Mother has begun to isolate the children from their Father and has now convinced them that the Mass he attends is invalid since it is the Novus Ordo/Post Vatican II Mass. Three of the children, his boys, will not attend. This is the same church, St. Theresa's in New Cumberland, where all four children were baptized and attended for years. (e) The Mother chooses to allow the minor boys to dress in two layers of clothing in 90 degree in apparent attempt to prepare them for the priesthood. All of the boys are under the age of nine (9) years old. (f) The Mother is refusing to allow the children to attend either public or private parochial school and has chosen to "home school" them through a "correspondence" school located in Browerville, Minnesota. This alleged "home-school" program, "Our Lady of Fatima Correspondence Catechism, Sisters of the Society Sain Pius X", is run by nuns who write letters to the children. These letters suggest that the children will suffer in Hell and allow the Devil to do his work if the children do not do their homework during the summer months. Summer is apparently the Devil's favorite time of year to tempt children into sin, especially sins of laziness. Again, these children are 8, almost 7, 5 and 3 years old. -4- (g) The Father is worried that his children are not learning the basic skills that are taught in the schools and instead are given primers, with the sole emphasis on religion. Father would like to enroll the children in the local parochial school. According to the Father, home-schooling was never agreed upon between the parties. (h) The Father is hopeful that with medical attention, perhaps medication and therapy, the Mother will recover and that the custody of their children can then be shared equally between the parents, but until such time, the Father is better suited to raise these children in a safe, healthy, and loving environment. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant primary custody of the children to him and partial physical custody to the Defendant. STONE LaFAVER &.-SI,ETSKI ELIZA Sup 4 dge w umber Telephon . Attor s -5- STO , ESQUIRE .D. #60251 eet, P.O. Box E nd, , PA 17070 (717) 774-7435 for Plaintiff k V E R I F I C A T I O N Stephen Karl Parthemore states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. STEPHEN KARL PARTHEMORE Date : ZIu1y 101 ZbUg fl\cus\lservice CERTIFICATE OF SERVICE I, Elizabeth B. Stone, of the law firm of Stone LaFaver & Shekletski, attorneys for Plaintiff, Stephen Karl Parthemore, do certify that on this date I served the Respondent the within Complaint for Custody by first class mail and certified mail via the United States Postal Service at below address: Ms. Michelle E. N. Kendra Parthemore c/o Mr. And Mrs. Tom Kendra 1521 Terrace Road Harrisburg, PA 17109 DATE : ?j 171 M cn e STEPHEN KARL PARTHEMORE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHELLE E.N. KENDRA PARTHEMORE DEFENDANT 2008-4220 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, July 23, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, August 20, 2008 at 12:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunday, 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 H p Ir 8,00Z F:\DOCS\FL\CUST\Parthemore.Stephen-affidavit of service.wpd ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF STEPHEN KARL PARTHEMORE, Plaintiff V. MICHELLE E.N. KENDRA PARTHEMORE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - CUSTODY NO. 08-4220 AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF CUMBERLAND I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint for Custody in the above captioned matter on the defendant, Michelle E.N. Kendra Parthemore, c/o Mr. and Mrs. Tom Kendra at 1521 Terrill Road, Harrisburg, Pennsylvania 17109, by First Class U.S. Mail and U. S. Certified Mail, on July 16, 200 United States Postal Service green return receipt. SWORN TO AND SUBSCRIBED before me this r? day of 2008. Notary Public evidenced by the attached CAROL L. TRO New Cumberland My Commission ¦ 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. a Attach this card to the hack of the maiipW*,"' or on the front If space permits. 1. Article Addressed to. Mss. M;c1?e?te. O"Aq C/o V4 f • * Mr's. T"o 16&,C (q 0 -.A A. Signature X Adddreaeee 8. Received by (PRWW Name) C. to of DOW- D. Is delivery address different from Item H YES, enter delivery address below. -D I -H-7 I QX a servimil" i : S ?/5, ` A 1 iol ¦ Certmed ma 0 13 Express t?Aait D Rsgisterert ¦ Return Receipt for Merchandise 0 insured and 0 C.O.D. 4. Reatriated Delivery? OWM Fee) f] Yes 2. Article from e?; ?008 0150 0002 5290 0573 (Trarrs}i9r ssrvke Leber) PS Form 3811, February 2004 Domestic Return Receipt 10258b-024A-1840 r."-? : ?°.: .. = .... t .._ ; _.. _. ?_ .. ? .-,-- .;???=w :?? __ ??? ?. , i '• Stephen Karl Parthemore, Plaintiff V. Michelle E.N. Kendra Parthemore, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-4220 CIVIL ACTION -LAW IN CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF SAID COURT: Please enter my appearance on behalf of the Defendant, Michelle Kendra Parthemore, in the above-captioned matter. Respectfully submitted, /,lil V&- - , / - t erine A. Boyle, Esquire Attorney I.D. 76328 Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. BOX 1062 Harrisburg, PA 17108 (717)236-9428 Attorney for Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET - P.O. BOX 1062 - HARRISBURG, PA 17108 (717) 236-9428 - FAX (717) 236-2817 r " _% Stephen Karl Parthemore, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-4220 Michelle E.N. Kendra Parthemore, CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this)Co " day of 1?? , 2008, a copy of the attached Praecipe to Enter Appearance was hand-delivered to: Stephen K. Parthemore Parthemore Funeral Home 1303 Bridge Street New Cumberland, PA 17070 and Sent via first class mail, postage prepaid, to: Stephen K. Parthemore c/o Elizabeth B. Stone, Esquire Stone LaFaver & Shekletski 414 Bridge Street P.O. Box E New Cumberland, PA 17070 Catherine A. Boyle, Esquire Attorney for Petitioner MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 C} ? CD r r y: ? ? rirt It " s trt AUG 2 6 2008 STEPHEN KARL PARTHEMORE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. MICHELLE E.N. KENDRA PARTHEMORE Defendant 2008-4220 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ?. day of A 04, , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Stephen Parthemore, and the Mother, Michelle Parthemore, shall have shared legal custody of Quentin Parthemore, born July 5, 2000, Lance Parthemore, born August 29, 2001, Garrison Parthemore, born May 12, 2003, and Gwyneth Parthemore, born July 10, 2005. Major decisions concerning the Children, including but not necessarily limited to, their health, welfare, education, religious upbringing and training shall be made jointly by the parties after discussion and consultation with a view toward following a harmonious policy in the Children's best interests. Neither party shall impair the affections of the Children from the other party. Each party shall notify the other of any activity or circumstance concerning the Children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, as soon as possible, that parent shall inform the other of the emergency and consult with him or her. In accordance with 23 Pa.C.S.A. Section 5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children on alternating weekends from Friday through Sunday and on one weekday each week, with the specific days and times for exchange to be arranged by agreement between the parties. The Father's weekend periods of custody shall be adjusted if necessary to correspond to the Father's weekends off work. 4. The parties shall enroll their school aged Children in St. Theresa's School in New Cumberland for the 2008-2009 school year. 5. In the event the Father elects to initiate a custody evaluation for the purpose of obtaining independent professional recommendations concerning ongoing custody arrangements which will best 0 S '6 WV L Z SnV OOOZ meet the needs of the Children, the Mother shall cooperate in scheduling all of her appointments individually and with the Children on a timely basis. The Father shall be responsible to pay all costs of the evaluation. 6. Within 60 days of the date of this Order, counsel for either party may contact the conciliator to request the scheduling of an additional conciliation conference or a hearing. 7. 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. BY THE COURT, ,//L- J. ff esley Oler, cczabeth B. Stone, Esquire -Counsel for Father P. erine Boyle, Esquire - Counsel for Mother v STEPHEN KARL PARTHEMORE IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2008 - 4220 CIVIL ACTION LAW MICHELLE E.N. KENDRA PARTHEMORE Defendant IN CUSTODY Prior Judge: J. Oler 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 subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Quentin Parthemore Lance Parthemore Garrison Parthemore Gwyneth Parthemore July 5, 2000 August 29, 2001 May 12, 2003 July 10, 2005 Mother Mother Mother Mother 2. A custody conciliation conference was held on August 21, 2008 with the following individuals in attendance: The Father, Stephen Parthemore, with his counsel, Elizabeth B. Stone, Esquire, and the Mother, Michelle Parthemore, with her counsel, Catherine Boyle, Esquire. 3. The Father filed this Complaint for Custody. The parties were unable to agree at the time of the conference as to a choice of schooling for the three school aged Children or as to physical custody arrangements for the Children as the Mother had relocated from the marital residence just prior to the conference. As agreed, the conciliator contacted the Court to obtain guidance as to interim arrangements, including possibly an expedited hearing or conference call to resolve the interim issues pending a hearing. Upon subsequently contacting counsel for the parties, the conciliator was advised that the parties had reached an understanding as to the school issue. The Father's counsel also advised that the Father was willing to accept the partial custody arrangements proposed by the Mother at the conference. 4. Based upon discussions at the conference, consultation with the Court following the conference and subsequent discussions with counsel, the conciliator recommends an Order in the form as attached. 'yg? ave Date Dawn S. Sunday, Esquire Custody Conciliator 1 F:\DOCS\FL\D1S\Parthemore.Stephen-Motion to Consolidate.wpd ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF STEPHEN KARL PARTHEMORE, Plaintiff V. MICHELLE E.N. KENDRA PARTHEMORE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -DIVORCE NO. 2008-4220 Nb. Z.no6-1 qT p PLAINTIFF'S MOTION TO CONSOLIDATE AND NOW COMES, the Plaintiff, STEPHEN KARL PARTHEMORE(hereinafter "Plaintiff'), by and through his attorney, Elizabeth B. Stone, Esquire, who files the following Motion to Consolidate and avers in support as follows: 1. The above action commenced when Plaintiff/Husband filed his Complaint for Custody on July 16, 2008. This first matter was assigned as Docket No. 2008-4220. 2. The Defendant/Wife filed her Complaint in Divorce Under Section 3301(c) of the Divorce Code on August 20, 2008. This second matter was assigned to a new Docket No. 2008-4998 and the Defendant/Wife in this matter was then listed as the Plaintiff/Wife. Further confusion now arises as Plaintiff/Husband in the Custody action is now Defendant/Husband in the Divorce. 3. Docket Nos. 2008-4220 and 2008-4998 involve identical parties and identical issues involved with custody and divorce. -1- f 4. The first Court Order signed by The Honorable Judge J. Wesley Oler, Jr., on August 26, 2008, arose out of a conciliation hearing on Docket No.#2008-4220, in custody. 5. The Honorable Judge Edward E. Guido was later assigned to Docket No. #2008-4998, in divorce. 6. To avoid unnecessary cost, delay, and confusion, Plaintiff asks these two cases be consolidated and assigned to the Honorable Judge, as he was the original Judge assigned to this matter in time. 7. Plaintiff respectfully requests that this Honorable Court to consolidate the two actions under Docket No. 2008-4220 and to discontinue Docket No. 2008-4998, and assign all matters in divorce and custody to Judge Oler. 8. No prejudice would result to the Wife by the granting of this Motion as the consolidation would be in the best interest and use of the Court's judicial time and economy, and further provide the parties with one venue within which to hear all matters in an efficient and timely manner. 9. Opposing counsel was not available to either agree or disagree with this motion when contacted with this motion. -2- f i WHEREFORE, Plaintiff, STEPHEN KARL PARTHEMORE, respectfully requests that this Honorable Court grant its Motion to Consolidate. Respectfully Submitted, STONE LaFAVER & SHEKLETSKI UIRE I.D. #60251 414 Bridge t--$; .O. Box E New Cum nd, PA 17070 Teleph : (717) 774-7435 A evs for Plaintiff Dated: 163/o2 -3- ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF STEPHEN KARL PARTHEMORE, Plaintiff V. MICHELLE E.N. KENDRA PARTHEMORE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -DIVORCE NO. 2008-4220 CERTIFICATE OF SERVICE I, Elizabeth B. Stone, Esquire, attorney for the Plaintiff, STEPHEN KARL PARTHEMORE, in the above-styled matter, certify that I this day served a copy of the foregoing PLAINTIFF'S MOTION TO CONSOLIDATE upon the person(s) indicated below by depositing a copy of the same in the United States Mail, first class, postage prepared, to the addressed as follows: Catherine A. Boyle, Esquire Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street Harrisburg, PA 17108 STONE LaFAVER FT?] STONE, ESQUIRE A Supr D. #60251 414 Bri / ,P.O. Box E New C , PA 17070 Tele 774-7435 Dated: O WO Z ',Attorneys for Plaintiff/Husband Y NOV 0 7 2008 6 STEPHEN KARL PARTHEMORE Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-4220 CIVIL ACTION LAW MICHELLE E.N. KENDRA PARTHEMORE : Defendant IN CUSTODY ORDER OF COURT AND NOW, this --- 1 day of v _ 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The Prior Order of this Court dated August 26, 2008 shall continue in effect as modified by this Order. 2. The Father shall have partial physical custody of the Children on two (2) weekends per month when the Father is not on call for work from Friday after school through Sunday at 7:00 p.m., which shall be extended to 7:30 p.m. if the Father has taken the Children out of the local area to visit relatives or otherwise and is traveling at the end of the period of custody. The Father shall ensure that all of the Children's homework is done by the end of his weekend period of custody. The Father's weekend periods of custody shall take place on the first two (2) full (Friday through Sunday) available weekends of each month, and shall be scheduled non-consecutively if possible. The Father's weekend periods of custody with the Children shall begin on Friday November 7, 2008. The Father shall provide his on-call schedule to the Mother at least thirty (30) days in advance. In addition, the Father shall have custody on two (2) evenings each week which shall take place on Tuesdays and Thursdays from after school until 7:30 p.m. In the event the Father is on call during a weekday evening period of custody, the parties shall adjust the custodial period to the day immediately preceding or immediately following. 3. The parties shall share or alternate having custody of the Children on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall run from Christmas Day at 12:00 noon through December 26 at 12:00 noon. In even-numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. In odd-numbered years, the Mother shall have custody of the Children during Segment A and the Father shall have custody during Segment B. For the remainder of the Children's holiday school break, the parties shall follow the regular custody schedule with the addition that the Father's weekday evening periods of custody shall be extended overnight to a time the following day to be arranged by agreement between the parties. The parties intend that their holiday 03 arrangements for the Christmas school break are to equally share having custody of the Children as much as possible to the extent permitted by the Father's work schedule. B. THANKSGIVING: The parties shall equally share having custody of the Children on Thanksgiving Day as arranged by agreement. The Children's holiday school break shall be shared equally with the parties exchanging custody of the Children halfway through the remaining school holiday. In 2008, the Father shall have custody of the Children on Thanksgiving Day from 9:00 a.m. until 3:30 p.m., the Mother shall have custody from Thanksgiving Day at 3:30 p.m. through Friday at 9:00 a.m., the Father shall have custody from Friday at 9:00 a.m. through Sunday at 9:00 a.m. and the Mother shall have custody thereafter until school resumes. C. ALTERNATING HOLIDAYS: The parties shall alternate having custody of the Children every year on Easter, Memorial Day, July Fourth and Labor Day from 9:00 a.m. until 8:00 p.m. on the day of the holiday. In even-numbered years, the Mother shall have custody of the Children for Easter and July Fourth and the Father shall have custody for Memorial Day and Labor Day. In odd-numbered years, the Father shall have custody of the Children for Easter and July Fourth and the Mother shall have custody for Memorial Day and Labor Day. D. MOTHER'S DAY/FATHER'S DAY: In every year, the Mother shall have custody of the Children on Mother's Day and the Father shall have custody on Father's Day from 9:00 a.m. until 8:00 p.m. E. The holiday custody schedule shall supersede and take precedence over the regular custody schedule and the vacation custody schedule. 4. Each parent shall be entitled to have custody of the Children for up to three (3) weeks each year, to be scheduled either consecutively or non-consecutively, upon providing at least 30 days advance notice to the other party. Periods of custody under this provision shall be scheduled in blocks of one (1) week unless otherwise agreed. The parent providing notice first of her or his intention to exercise a period vacation custody shall be given preference on his or her selection of vacation dates. Each party shall provide advance notice to the other party of the address and telephone number where the Children can be contacted during vacation. 5. Both parties shall ensure that all of the Children are present for each party's periods of custody unless otherwise agreed between the parties in advance. 6. The parties shall share school information concerning the Children's participation in special events and other developments so that the Children can be supported by both parents in their school activities to the extent possible. 7. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 11 8. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provision of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THS?-CDURT, cc: lizabeth B. Stone, Esquire - Counsel for Father atherine Boyle, Esquire - Counsel for Mother 6 Q -11 WV h 1 AQN BQOZ AWILONv,.LO":d 3Hl J4 STEPHEN KARL PARTHEMORE Plaintiff vs. MICHELLE E.N. KENDRA PARTHEMORE Defendant Prior Judge: J. Wesley Oler, Jr. IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: CUSTODY CONCILIATION SUMMARY REPORT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-4220 CIVIL ACTION LAW IN CUSTODY 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Quentin Parthemore Lance Parthemore Garrison Parthemore Gwyneth Parthemore July 5, 2000 August 29, 2001 May 12, 2003 July 10, 2005 Mother Mother Mother Mother 2. A custody conciliation conference was held on November 5, 2008, with the following individuals in attendance: the Father, Stephen Parthemore, with his counsel, Elizabeth B. Stone, Esquire, and the Mother, Michelle Parthemore, with her counsel, Catherine Boyle, Esquire. 3. The parties agreed to entry of an Order in the form as attached. C9 C)o Date Dawn S. Sunday, Esquire Custody Conciliator STEPHEN K. PARTHEMORE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHELLE PARTHEMORE NO. 2008-4220 CIVIL TERM MICHELLE PARTHEMORE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. STEPHEN K. PARTHEMORE : NO. 2008-4998 CIVIL TERM ORDER OF COURT AND NOW, this 17TH day of NOVEMBER, 2008, it appearing that the "Motion to Consolidate" is opposed we will address the matter at the hearing previously scheduled for THURSDAY, DECEMBER 4, 2008, at 1:00 p.m. in Courtroom # 3. , e Co Edward E. Guido, J. Elizabeth B. Stone, Esquire Catherine A. Boyle, Esquire :sld ?? z O `?, "? u ti MICHELLE K. PARTHEMORE Plaintiff V. STEPHEN K. PARTHEMORE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-4998 CIVIL TERM IN DIVORCE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - STEPHEN K. PARTHEMORE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-4220 CIVIL TERM MICHELLE K. PARTHEMORE, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 4th day of December, 2008, by agreement of the parties, the custody action will be incorporated into the divorce action at 4998 Civil 2008. No further filings will be made to 4220 Civil 2008. All future filings, including custody matters, shall be filed to 4998 Civil 2008. The undersigned will deal with all matters pertaining to this case. Edward E. Guido, J. Catherine A. Boyle, Esquire Attorney for Michelle K. Parthemore ? Elizabeth B. Stone, Esquire Attorney for Stephen K. Parthemore srs ...;r Yt IJ t8 6 - Jo