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HomeMy WebLinkAbout08-4397LANEE LIGHTY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW VS. CUSTODY RUTH N. CARDOSO and MATTHEW A. SATHER, : NO. 17 c r ,, y fes? Defendants. COMPLAINT FOR CUSTODY 1. Plaintiff is Lanee Lighty, whose address is 522 W. Elmwood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Ruth N. Cardoso, whose current address is believed to be 313 E. Noble Street, Apartment 6A, Nanticoke, Pennsylvania 18634. 3. Co-defendant is Matthew A. Sather, whose address is 522 W. Elmwood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 4. Plaintiff seeks custody of Logan W. Sather, born June 13, 2007. 5. The child was born out of wedlock. The child is presently in the custody of Ruth N. Cardoso. 6. For the past five years, the child has resided with the following persons at the following addresses: Custodian Address Dates Ruth N. Cardoso 313 E. Noble St., Apt. 6A 7/20/2008 - present Nanticoke, PA 18634 Lanee Lighty 522 W. Elmwood Ave. 6/13/2007-7/19/2008 Mechanicsburg, PA 17055 7. The mother of the child is Ruth N. Cardoso whose current address is believed to be 313 E. Noble Street, Apartment 6A, Nanticoke, Pennsylvania 18634. She is single. The father of the child is Matthew A. Sather whose current address is 522 W. Elmwood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. He is single. 8. The plaintiff is the paternal grandmother of Logan W. Sather. The plaintiff currently resides with her fiancee Nevin Yingling, her step-daughter Erica Yingling, and Matthew A. Sather. 9. Ruth N. Cardoso is believed to currently reside with her friend, Erica, whom she met in rehab. It is unknown who else lives in that residence. 10. Matthew A. Sather currently resides with Lanee Lighty, Nevin Yingling, and Erica Yingling. 11. 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. 12. The plaintiff has no information of a custody proceeding concerning the children pending in a court in this Commonwealth or in any other court. 13. 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. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because the child will benefit from being in a stable and nurturing environment. Ms. Cardoso has a long history of substance abuse and it is believed that she is currently abusing drugs. Ms. Cardoso is unemployed and cannot afford to provide food or shelter to her child. 15. Each parent whose parental rights to the child 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 this Court to award her custody of Logan W. Sather. Respectfully submitted, 4 ighty LANEE LIGHTY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW VS. CUSTODY RUTH N. CARDOSO and MATTHEW A. SATHER, NO. Defendants. Verification 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.A. Section 4904 relating to unsworn falsification to authorities. Date: 4d5h U t e_? I Ix- L ee L' ty C? f-3 C 0 -n -01 G T' y '' p t1 LANEE LIGHTY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW VS. CUSTODY RUTH N. CARDOSO and MATTHEW A. SATHER, NO. 3 q G ?? Defendants. EMERGENCY PETITION FOR CUSTODY AND NOW comes Lance Lighty, who respectfully files this Emergency Petition for Custody and avers as follows: 1. Petitioner is Lance Lighty, paternal grandmother of child, Logan W. Sather, and plaintiff in the above captioned matter. 2. Petitioner currently resides at 522 W. Elmwood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Respondents are Ruth N. Cardoso and Matthew A. Sather, natural parents of the child and defendants in the above captioned matter. 4. The mother of the child, Ruth N. Cardoso, is believed to have an address of 313 E. Noble Street, Apartment 6A, Nanticoke, Pennsylvania 18634. 5. The father of the child, Matthew A. Sather, has an address of 522 W. Elmwood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 6. The child, Logan W. Sather, was born on June 13, 2007 and has resided with petitioner, Lance Lighty, at 522 W. Elmwood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055 from birth until Saturday, July 19, 2008 when the mother of the child took the child to Nanticoke, Pennsylvania. 7. The child has resided with petitioner and respondents from birth until Saturday, July 19, 2008. 8. Respondent, Ruth N. Cardoso, has lived with petitioner from May 2007 until Saturday, July 19, 2008. Petitioner gave Ms. Cardoso permission to use petitioner's vehicle to drive Ms. Cardoso to her mother's residence on Saturday, July 19, 2008 to pick up Logan W. Sather who was staying with Ms. Cardoso's mother. Ms. Cardoso then asked if she could spend the night at her mother's residence on Saturday, July 19, 2008 and Sunday, July 20, 2008. Petitioner agreed with the understanding that Ms. Cardoso would leave the morning of Monday, July 21, 2008 in order to be home for Logan's doctor's appointment. Ms. Cardoso and her child have failed to return to petitioner's home. It is believed that respondent and her child, in petitioner's vehicle, drove to Nanticoke, Pennsylvania where respondent is abusing drugs. It is believed that petitioner's vehicle has been stolen. 9. Petitioner fears for the safety and welfare of the child. Petitioner believes that the child is in danger due to Ms. Cardoso's continual pattern of substance abuse, mental illness and neglect for her child. Ms. Cardoso moved in with petitioner in May of 2007 and gave birth to Logan W. Sather on June 13, 2007, who was seven (7) weeks premature. Ms. Cardoso began abusing heroine in August of 2007. Petitioner was able to observe Ms. Cardoso coming home at 5:00 or 6:00 in the morning and being visibly high. In February 2008, Ms. Cardoso overdosed on Xanax and had to be hospitalized at the Holy Spirit Hospital. During that incident, Ms. Cardoso fell down petitioner's stairs and dropped Logan on the hard wood floors. On or about March 1, 2008, Ms. Cardoso called petitioner and told her that she was going to kill herself and asked petitioner to take care of her son. Petitioner then called the Upper Allen Police Department who found Ms. Cardoso sitting in her car at a gas station. In March of 2008, Ms. Cardoso emptied her bank account of $2,450 to buy heroine. She was doing ten (10) to thirteen (13) bags of heroine a day. On May 8, 2008, after being confronted by Mr. Sather about her heroine usage, Ms. Cardoso threatened to kill herself, slit her wrists, destroyed property and stole some of Mr. Sather's belongings. Ms. Cardoso was also fired from her job at Sierra Madre on that day due to stealing money from another girl and overcharging custom . Cove Petitioner forced Ms. Cardoso to go to a rehab program at White Deer Run/ (?br Arge behavioral Health System. Ms. Cardoso remained in treatment from May 11, 2008 through June 4, 2008. However, three days after leaving the rehab program, Ms. Cardoso returned to petitioner's home at 3:00 am severely drunk and/or high and stabbed petitioner's wall with a knife. On June 26, 2008, Ms. Cardoso filled a prescription for Flexeral and within five (5) days, Ms. Cardoso had taken 71 of the 90 pills. On July 19, 2008, petitioner allowed Ms. Cardoso to use her vehicle to pick Logan up from Ms. Cardoso's mother's residence. Ms. Cardoso left her mother's residence with Logan on Sunday, July 20, 2008 and has not returned to petitioner's home. Petitioner believes that Ms. Cardoso traveled to Nanticoke, Pennsylvania to visit a woman named Erica, whom she met in rehab. Ms. Cardoso has bi-polar disorder. However, Ms. Cardoso only took two of her prescriptions along with her; Adderall and Trazedone. It is believed that petitioner's vehicle has since been stolen. 10. The father of the child, Matthew A. Sather, joins herein to consent to custody being vested in petitioner. WHEREFORE, petitioner respectfully requests this Court to grant custody of Logan W. Sather to her. Respectfully submitted, a L Lighty I, Matthew A. Sather, consent to custody being awarded to Lance Lighty. Nla'&-w il It SA?9? Matthew A. Sather LANEE LIGHTY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW VS. CUSTODY RUTH N. CARDOSO and MATTHEW A. SATHER, NO. Defendants. Verification 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.A. Section 4904 relating to unsworn falsification to authorities. 71, Date: L ighty iA- O o o v W ? ty 0 r-.30 C3 jr- -n av °? p { ? o 1 1% JUL 2 3 2008 LANEE LIGHTY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW VS. CUSTODY RUTH N. CARDOSO and MATTHEW A. SATHER, NO. D8 - 4397 tv t Tierra Defendants. ORDER GRANTING TEMPORARY CUSTODY A AND NOW this day of July, 2008, it is hereby ordered and decreed that temporary custody of Logan W. Sather is awarded to Lanee Lighty. By the Court: PV-01 Yr eW A Coe ?ar?o? koo N . Cardoso .led 4° ,? o$ ?? 1'00 z,,.... ^^aa -- L""' ^"t'% r..... rt't.C_`: ? ??" i w;i> 1 r `??..1 LANEE LIGHTY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-4397 CIVIL ACTION LAW RUTH N. CARDOSO AND MATTHEW A. IN CUSTODY BATHER DEFENDANT ORDER OF COURT AND NOW, Wednesday, July 30, 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 Tuesday, September 02, 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/ Dawn S. Sunda Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 AN LANEE LIGHTY Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. RUTH N. CARDOSO and MATTHEW A. SATHER Defendant 2008-4397 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this day of S Q, N-V, rX ? tf , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The paternal Grandmother, Lanee Lighty, the Father, Matthew Sather, and the Mother, Ruth Cardoso, shall have shared legal custody of Logan W. Sather, born June 13, 2007. Major decisions concerning the Child including, but not necessarily limited to, his health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. No party shall impair the other parties' rights to shared legal custody of the Child. No party shall attempt to alienate the affections of the Child from the other parties. Each party shall notify the others of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the others. Day to day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which 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 party shall inform the other parties of the emergency and consult with them as soon as possible. In accordance with 23 Pa.C.S.A. §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 any party as authorized by statute. The parties agree that the paternal Grandmother shall have primary responsibility for making arrangements for medical care for the Child and the Father shall be primarily responsible for making arrangements for participation in the WIC Program. 2. Pending the additional custody conciliation conference scheduled in this Order and further Order of Court or agreement of the parties, the paternal Grandmother shall have primary physical custody of the Child. The Mother shall have partial physical custody of the Child every week from Monday at 7:00 p.m. through Wednesday at 7:00 p.m. beginning Monday, September 8, 2008. The Mother shall provide transportation for all exchanges of custody during these periods. The Mother's overnight periods of custody with the Child shall take place at the maternal Grandmother's residence and the Mother shall remain in the local area of the maternal Grandmother's residence during her periods of custody. The Father shall have partial physical custody of the Child as arranged by agreement between the Father and the paternal Grandmother. S 3. The Mother shall participate in a course of parenting classes for which the Mother shall provide documentation of completion to the paternal Grandmother or her counsel. 4. The Father shall attend the Seminar for Separating parents in Dauphin County and shall provide documentation of attendance if requested by the Mother. 5. The parties and their respective legal counsel shall appear for a custody conciliation conference on Tuesday, November 11, 2008 at 10:30 a.m. in the office of the conciliator, Dawn S. Sunday, for the purpose of reviewing the custodial arrangements. 6. None of the parties shall do or say anything which may estrange the Child from the other parties, injure the opinion of the Child as to the other parties, or hamper the free and natural development of the Child's love and respect for the other parties. All parties shall ensure that third parties having contact with the Child comply with this provision. 7. Each party shall refrain from using controlled substances or alcohol to the point of excess during periods of custody with the Child. 8. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by consent of all parties. In the absence of consent, the terms of this Order shall control. BY THE COURT, ?*, -V,- ?A A M. L. Ebert, Jr. cc: 16hanna H. Rehkam p, Esquire -Counsel for paternal Grandmother i3,dth N. Cardoso - Mother /Matthew A. Sather - Father 0-6 1? S at, LSJ- Q?ia/oF3 v q I ij 17 ?i :2 N1 0 1 BUIR :,.-" J J 'OHi JC, 76 LANEE LIGHTY VS. RUTH N. CARDOSO and MATTHEW A. SATHER Defendant Prior Judge: M. L. Ebert, Jr. IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: Plaintiff CUSTODY CONCILIATION SUMMARY REPORT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-4397 CIVIL ACTION LAW IN CUSTODY 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Logan W. Sather June 13, 2007 Paternal Grandmother 2. A custody conciliation conference was held on September 2, 2008, with the following individuals in attendance: the paternal Grandmother, Lanee Lighty, with her counsel, Johanna H. Rehkamp, Esquire, the Father, Matthew Sather, pro se, and the Mother, Ruth N. Cardoso, pro se. The Mother's uncle, Richard Davis, also attended the conference with the consent of the other parties. 3. This Court previously entered a Temporary Custody Order on the paternal Grandmother's Emergency Petition on July 23, 2008 giving the paternal Grandmother temporary custody of the Child pending the conciliation conference. 4. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator 5 NOV 17 2008 LANEE LIGHTY Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. RUTH N. CARDOSO and MATTHEW A. SATHER Defendant 2008-4397 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this / day of Y) 0 tter? , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated September 9, 2008 is vacated and replaced with this Order. 2. The paternal Grandmother, Lanee Lighty, the Father, Matthew Sather, and the Mother, Ruth Cardoso, shall have shared legal custody of Logan W. Sather, born June 13, 2007. Major decisions concerning the Child including, but not necessarily limited to, (his/her) health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning the Child 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 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 possible. In accordance with 23 Pa.C.S.A. §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. 3. The paternal Grandmother, Lanee Lighty, shall have primary physical custody of the Child. 4. The Mother shall have partial physical custody of the Child every week from Sunday, at a time to be arranged by agreement, through Wednesday evening, at a time to be arranged by agreement. 5. The Father shall have partial physical custody of the Child as arranged by agreement between the Father and the paternal Grandmother. y 6. The parties shall share or alternate having custody of the Child on holidays as arranged by agreement. 7. None of the parties shall do or say anything which may estrange the Child from the other parties, injure the opinion of the Child as to the other parties, or hamper the free and natural development of the Child's love and respect for the other parties. All parties shall ensure that third parties having contact with the Child comply with this provision. 8. Each party shall refrain from using controlled substances or alcohol to the point of excess during periods of custody with the Child. 9. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by consent of all parties. In the absence of consent, the terms of this Order shall control. BY THE COURT, N -1 ? M. L. ert, r. cc: vl anna H. Rehkamp, Esquire - Counsel for paternal Grandmother u h N. Cardoso - Mother Iatthew A. Sather - Father CC? L-L 4?0? «/ It ION' AIASNN32 10 =8 WV 61 RQN 8001 kWlON0H1 °° ?Hl 30 LANEE LIGHTY vs. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-4397 CIVIL ACTION LAW RUTH N. CARDOSO and MATTHEW A. SATHER Defendant Prior Judge: M. L. Ebert, Jr. IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Logan W. Sather June 13, 2007 Paternal Grandmother 2. A custody conciliation conference was held on November 11, 2008, with the following individuals in attendance: the Paternal Grandmother, Lanee Lighty, with her counsel, Johanna H. Rehkamp, Esquire, the Mother, Ruth N. Cardoso, pro se, with her mother, and the Father, Matthew A. Sather, pro se. 3. The parties agreed to entry of an Order in the form as attached. llkiuQ?? /(.?? Date Dawn S. Sunday, Esquire Custody Conciliator LANEE LIGHTY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA +/35 -7 VS. NO. 2008-43.8-7' RUTH N. CARDOSO and CIVIL ACTION -LAW MATTHEW A. SATHER, Defendants IN DIVORCE MOTION FOR ENTRY OF CUSTODY ORDER AND NOW comes the plaintiff, Lanee Lighty, who, through her attorney, Johanna H. Rehkamp, Esquire, respectfully submits as follows: 1. On July 23, 2008, the plaintiff, Lanee Lighty, filed a custody complaint seeking primary custody of the defendants' son, Logan W. Sather, born June 13, 2007. 2. An Order of Court was entered November 18, 2008, granting shared legal custody of the child to plaintiff and defendants, and further granting primary physical custody to plaintiff with periods of partial custody in defendants. 3. The parties have entered into a stipulation for the entry of an agreed custody order which is attached hereto. WHEREFORE, plaintiff requests that the court adopt the stipulation and the order of this court. Respectfully submitted, J anna H. Rehkamp, Esquire RNER AND O'CONNELL 1 North Front Street Harrisburg, PA 17110 (717) 232-4551 Attorney for plaintiff LANEE LIGHTY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA y3?t'7 vs. : NO. 2008439-7- RUTH N. CARDOSO and CIVIL ACTION - LAW MATTHEW A. SATHER, Defendants CUSTODY CUSTODY STIPULATION AND NOW, this day of ji?? '2009, Lanee Lighty (hereinafter referred to as "Grandmother"), Ruth N. Cardoso (hereinafter referred to as "Mother) and Matthew A. Sather (hereinafter referred to as "Father") hereby stipulate and agree to the following regarding custody of the minor child, Logan W. Sather, born June 13, 2007: 1. Legal Custody: Grandmother, Mother, and Father shall have shared legal custody of Logan W. Sather. The parties agree that major decisions concerning the child, including, but not 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 party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which 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 party shall inform the other of the emergency and consult with him or her as soon as possible. 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 given to either party pursuant to 23 Pa.C.S. 5309. 2. Physical Custody: Grandmother shall have primary physical custody of Logan W. Sather. Mother shall have supervised visitation with the child every Friday at Grandmother's residence. Father shall have liberal periods of physical custody as mutually agreed on by Grandmother and Father. 3. Holiday Schedule: Grandmother, Mother, and Father shall share or alternate holidays as mutually agreed upon. 4. Transportation: Transportation shall be shared as mutually agreed upon. 5. During any period of custody or visitation, the parties shall not possess or use controlled substances or consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or houseguests comply with this prohibition. 6. Each party shall be entitled to reasonable telephone or e-mail contact with the child when she is in the custody of the other party. The parties shall provide to one another an emergency contact telephone number, e-mail address or contact person. 7. The parties shall refrain from making derogatory comments about the other party in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child (whether the child is sleeping or awake) or otherwise harass or interfere with the parties' periods of partial custody. 8. The parties shall agree to refrain from encouraging the child to provide reports about the other party. Communication should always take place directly between the parties, without using the child as an intermediary. 2 9. It is the intention of the parties that the child be protected from individuals with poor character (including, but not limited to, individuals involved with illegal activity, immoral or intemperate behavior, or violent propensities). The parties shall, to the extent possible, avoid contact with such individuals of poor character. Violation of the provisions set forth in this paragraph may be considered as contempt. 10. Parties shall permit and support child's access to family relationships and events (funerals, reunions, graduations, etc.). Events will be accommodated by all parties with routine periods of custody resuming immediately thereafter. Each party shall have the option of proposing time or date variations to the other parties when special recreational options or other unexpected opportunities arise. 11. Should any party's medical and/or mental health condition(s) become acute to the point that it does or could jeopardize the child's safety, he/she shall notify the other parties immediately. IN WITNESS WHEREOF, the parties, intending to be legally bound hereby, have set their hands and seals the day and year written below. Witness: e'? X44?% _16,&t0_7 ' 4Le i ty Date V I?Gtfi'N. Card so Date ?..? ?W/0/07 A? A 14A A 1?a/z a5 Ma ew A. Sather Date "E OF THE PRC7 ;1.,'1»0VTY 2609 AUG 21 Fl 2: 5 2 f4 ?Yr? ? -c} LANEE LIGHTY, Plaintiff vs. RUTH N. CARDOSO and MATTHEW A. SATHER, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ?-7 NO. 2008-4Y8'- CIVIL ACTION -LAW IN DIVORCE ORDER AND NOW, this '14 day of August, 2009, an order of custody is hereby entered pursuant to the parties' stipulation dated June 12, 2009. By the Court: OF THEucL !. ?Y 2009 AUU 2'E'' 2 4.1 mat LL -k) 2 . C'?a