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HomeMy WebLinkAbout04-0987CHRISTOPHER L. PLITT, Plaintiff V. ANNA J. PLITT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - 9P7 CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the 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, Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A 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. Cumberland County Lawyers Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 CHRISTOPHER L. PLITT, Plaintiff V. ANNA J. PLITT, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - 10 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE AND NOW, COMES, the above-named Plaintiff by and through his attorneys, Law Offices of Peter J. Russo, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is an adult individual residing at 1164 Heron Court, Mechanicsburg, Cumberland County, Pennsylvania and is a citizen of the United States. 2. Defendant is an adult individual residing at 1512 Timber Chase Drive, Mechanicsburg, Cumberland County, Pennsylvania and is a citizen of the United States. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for 24 years and has resided continuously therein for at least six months prior to filing of this Complaint. 4. Defendant has been a resident of the Commonwealth of Pennsylvania for fifteen years and has resided continuously therein for at least six months prior to filing of this Complaint. 5. Plaintiff and Defendant were married on June 22, 1995 in Cumberland County, Pennsylvania. 6. There is one child of the parties under the age of eighteen (18): Zachary L. Plitt COUNT I - DWORCE December 14, 1994 7. Plaintiff hereby incorporates by reference averments 1 through 6 of this Complaint as if each averment were set forth fully hereunder. 8. There has been no prior action for divorce by either party against the other. 9. Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 10. Plaintiff avers that the marriage between the parties is irretrievably broken. 11. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling, but does not request the same. 12. Plaintiff and Defendant have property which will be subject to a property settlement agreement addressing support issues, which will be filed herein at the appropriate time. WHEREFORE, Plaintiff, Christopher L. Plitt, prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: A. That a decree in divorce be entered dissolving the marriage between the two parties. COUNT II: DIVORCE - EOUITABLE DISTRIBUTION 13. Plaintiff hereby incorporates by reference averments 1 through 12 of this Complaint as if each averment were set forth fully hereunder. 14. Plaintiff and Defendant have acquired property, both real and personal, during the course of their marriage. 15. The parties have also acquired home furnishings, motor vehicles, bank accounts, retirement accounts, investments and miscellaneous items of personal property. 16. Thus far plaintiff and defendant have not agreed to an equitable distribution of said property. WHEREFORE, Plaintiff, Christopher L. Plitt, prays that a decree be entered as follows: A. That a decree be entered granting equitable distribution of marital property as agreed upon. COUNT III - CUSTODY 17. Plaintiff hereby incorporates by reference averments 1 through 16 of this Complaint as if each averment were set forth fully hereunder. 18. Plaintiff is Christopher L. Plitt residing at 1164 Heron Court, Mechanicsburg, Cumberland County, Pennsylvania. 19. Defendant is Anna J. Plitt residing at 1512 Timber Chase Drive, Mechanicsburg, Cumberland County, Pennsylvania. 20. Plaintiff seeks joint custody of the following child: Name Present Residence DOB Zachary L. Plitt - 1512 Timber Chase Drive, Mechanicsburg, PA - December 14, 1994 21, The child was bom out of wedlock. 22. The child is presently in the shared custody of both Plaintiff and Defendant, who reside at, 1512 Timber Chase Drive, Mechanicsburg, Cumberland County, Pennsylvania and 1164 Heron Court, Mechanicsburg, Cumberland County, Pennsylvania. 23. In the last five years the child has resided with the following persons and at the following address: Name Address Dates Plaintiff and Defendant - 1512 Timber Chase Drive, Mechanicsburg, PA - April 1998 to present. 24. The Plaintiff, the father of the child, is residing at, 1164 Heron Court Mechanicsburg, Cumberland County, Pennsylvania. He is married. 25. The Plaintiff currently resides with the following persons: Name Rebecca Parker Relationship Mother 26. The Defendant, the mother of the child, is Anna J. Plitt, residing at 1512 Timber Chase Drive, Mechanicsburg, Cumberland County, Pennsylvania. She is married. 27. The Defendant currently resides with the following persons: Name Self Relationship 28. Plaintiff has not participated as a parry or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 29. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 30. 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 right with respect to the child. 31. The best interest and permanent welfare of the child will be served by granting the relief requested because the child will remain in the custody of both parents. 32. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests this Honorable Court to order that the parties share custody arrangements as set forth in a proposed Custody Agreement which has been provided to the Defendant. Respectfully submitted, LAW CES OF PF.TF J. RUSSO, P.C. Peter J. Russo, Esquire Scott A. Stein, Esquire 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Date: 3/6/o / LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 CHRISTOPHER L. PLITT, Plaintiff V. ANNA J. PLITT, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - IN DIVORCE CIVIL TERM CERTIFICATE OF SERVICE I, Debra A. Micklo, hereby certify that I am on this day serving a copy of the foregoing documents upon the person (s) and in the manner indicated below; Service by Certified Mail, Postage Prepaid, and Addressed as Follows: Anna J. Plitt 1512 Timber Chase Drive Mechanicsburg, PA 17055 Debra A. Micklo, Paralegal Date: 3? Y/C) / o ? N cM1. .a i co Cu?i 'n a 1 CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ANNA J. PLITT 04-987 CIVIL ACTION LAW IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, March 18, 2004 , 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 Thursday, April 15, 2004 at 1:00 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. "'n° 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 LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 CHRISTOPHER L. PLITT, Plaintiff V. ANNA J. PLITT, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - 987 CIVIL TERM IN DIVORCE PROOF OF SERVICE OF PLAINTIFF'S COMPLAINT UPON DEFENDANT AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, Christopher L. Plitt, and certifies that on MARCH q , X00 t( , he did serve the Defendant, Anna J. Plitt, with a true and correct copy of the Divorce Complaint filed against her alleging the parties' marriage was irretrievably broken under Section 3301(d) and Section 3301(c) of the Divorce Code. Said complaint was served upon the defendant by placing same in an envelope, return receipt requested and addressed to Anna J. Plitt, at 1512 Timber Chase Drive, Mechanicsburg, Cumberland County, Pennsylvania. [ Service of Plaintiffs Complaint on the Defendant, Anna J. Plitt, was effected on mA R (? H 9 , `x004 . A true and correct copy of the U.S. Postal Service Return Receipt is attached hereto and the original is affixed to the reverse of this document. [ ] Service of Plaintiffs Complaint on the Defendant, Anna J. Plitt, was effected on . A true and correct copy of Defendant's Acknowledgment of Service is attached hereto and the original is affixed to this document. Date: Respectfully submitlede Peter J. Russo?__....... LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 (717)591-1755 CHRISTOPHER L. PLITT, Plaintiff V. ANNA J. PLITT, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - 987 CIVIL TERM IN DIVORCE a 7002 2410 0004 1005 1078 WALINr ?? ij??r+r e, •' Ii ' 1.I! • • 11+41610 15l?fiif,l 1 1 ?A C? CHRISTOPHER L. PLITT Plaintiff vs. ANNA J. PLITT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-987 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ; 7A day of 2004, upon consideration of the attached Custody Conciliation Repo it o and directed as follows: 1. The Father, Christopher L. Plitt, and the Mother, Anna J. Plitt, shall have shared legal custody of Zachary L. Plitt, bom December 14, 1994. Each parent shall have an equal right, to be exercised jointly with the other parent, 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 this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. Pending the Father's move from the paternal grandmother's residence and the additional conciliation conference scheduled in this Order or further agreement of the parties, the parties shall have physical custody of the Child in accordance with the following schedule: A. During alternating weeks, the Father shall have custody of the Child from Tuesday after school / daycare through Wednesday before school / daycare and from Friday after school / daycare through Sunday at 10:00 am. B. During the interim weeks, the Father shall have custody of the Child from Tuesday after school / daycare through Thursday before school / daycare and from Friday after school / daycare through Saturday at 5:00 pm. C. The Mother shall have custody of the Child at all times not otherwise specified for the Father in this provision. D. The custody schedule shall begin with the Father having custody of the Child from Friday, April 16, 2004 through Sunday April 18, 2004 at 10:00 am. I In 2004, the Mother shall have custody of the Child on Mother's Day and the Father shall have custody on Father's Day from the evening before the holiday at 5:00 pm through the following Monday morning before daycare. 4. In the event either party intends to take the Child out of the Commonwealth of Pennsylvania or more than 100 miles from that party's residence, that parent shall provide advance notice to the other parent of the address and telephone number where the Child can be contacted. 5. The parties and their counsel shall attend an additional custody conciliation conference in the office of the conciliator, Dawn S. Sunday, on Tuesday, June 15, 2004 at 10:30 am to review the custody arrangements. 6. 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 mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY J. cc: Peter J. Russo, Esquire - Counsel for Father P. Richard Wagner, Esquire - Counsel for Mother L(-a7-0`- YINVAI,ISNN?d 1 £ -£ Wd LZ Ndti U8Z J,Ftdl aNO 30 CHRISTOPHER L. PLITT Plaintiff VS. ANNA J. PLITT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-987 CIVIL ACTION LAW 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 Zachary L. Plitt December 14, 1994 Mother / Father 2. A Conciliation Conference was held on April 15, 2004, with the following individuals in attendance: The Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire, and the Mother, Anna J. Plitt, with her counsel, P. Richard Wagner, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator JMY2 3 2004 CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 04-987 CIVIL ACTION LAW ANNA J. PLITT Defendant IN CUSTODY ORDER OF COURT AND NOW, this a day of 2004, upon consideration of the attached Custody Conciliation eport, it is ordered and directed as follows: 1. The parties shall engage in a course of co-parenting mediation at InterWorks. If the parties have not reached an agreement as to ongoing custody arrangements prior to the beginning of the 2004-2005 school year, the parties shall obtain recommendations from the counselor for an interim school year schedule pending completion of the mediation. The parties acknowledge that while they have agreed to equally share time with the Child under the temporary schedule set forth in this Order, neither party shall be prejudiced in the mediation process by this temporary agreement to the specific scheduling of each party's time with the Child. 2. Pending completion of the mediation process, receipt of temporary recommendations for the school year, further agreement of the parties or Order of Court, the parties shall have custody of the Child in accordance with the following schedule: A. The Mother shall have custody of the Child in every week from Monday after school through Tuesday after school and from Thursday after school through Friday after school. B. The Father shall have custody of the Child in every week from Tuesday after school through Thursday after school. C. The parties shall alternate having custody of the Child from Friday after school through Monday after school each week. D. During alternating weeks when the Mother has custody of the Child for five consecutive days from Thursday through Tuesday, the Father shall have a period of custody with the Child on Monday from 5:00 p.m. until 7:00 p.m. 3. Counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary to review the custody arrangements after mediation and receipt of the counselor's recommendations, if any, prior to the beginning of the 2004-2005 school year. 4. The prior Order of this Court dated April 27, 2004 is vacated and replaced with this Order. 5. In the event either party intends to take the Child out of the Commonwealth of Pennsylvania or more than 100 miles from that party's residence, that party shall provide advance notice to the other party of the address and telephone number where the Child can be contacted. 6. 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 mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE E. Guido J. cc: Peter J. Russo, Esquire - Counsel for Father - L p 0 y P. Richard Wagner, Esquire - Counsel for Mother I:6? ?! P, ? "[11 YJuoZ 3141 ECO Peter J. Russo, Esquire 3800 Market Street Camp Hill, PA 17011 P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 CHRISTOPHER L. PLITT Plaintiff VS. ANNA J. PLITT Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-987 CIVIL ACTION LAW 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: follows: I. The pertinent information concerning the Child who is the subject of this litigation is as NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Zachary L. Plitt December 14, 1994 Mother/Father 2. A conciliation conference was held on June 15, 2004„ with the following individuals in attendance: The Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire, and the Mother, Anna J. Plitt, with her counsel, P. Richard Wagner, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ?-" '?-00? Date Dawn S. Sunday, Esquire Custody Conciliator CHRISTOPHER L. PLITT, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO: 2004-987 CIVIL ACTION - LAW ANNA J. PLITT, IN DIVORCE Defendant. NOTT O INTENTION TO RFSUMF pRIOR MM NOTICE IS HEREBY GIVEN that the Defendant in the above matter, being a party to a divorce action at the above number filed on March 8, 2004, hereby intends to resume and hereafter use the previous name of ANNA J. GREGOR and gives this written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980, P.L., 23 P.S. Section 702 (effective July 1, 1980). Ana COMMONWEALTH OF PENNSYLVANIA TO BE KNOWN AS: v?2 Anna J. Gregor COUNTY OF Xaup4.,J SS. h ON THE all t-1- day of 2004, before me, a Notary Public, personally aPlitt, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. Notary Public C N O ? m t z , r r co O 7' A' ,p t- N Jm -c dY v Lori K. Serratelli, Esquire Pa. Supreme Court ID No. 27426 Serratelli, Schiffman, Brown and Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney For Plaintiff CHRISTOPHER L. PLITT, Plaintiff v ANNA J. PLITT Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-987 CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR WITHDRAWAL AND ENTRY OF APPEARANCE Please withdraw the appearance of P. Richard Wagner, Esquire, as attorney for the Defendant in the above-captioned matter. Dated: 7 ?0 MANC WA ER & SPREHA 2233 Front Street Harrisburg, PA. 17110 (717) 234-7051 Please enter the appearance of Lori K Serratelli, Esquire, as attorney for the Defendant in the above-captioned matter. Dated: gsloY Lor Ser3atelli, Es SE TELLI, SCHIFFMAN, B OWN & CALHOON, P.C. 2080 Linglest:own Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 re 2 C- T-? `.? ftlr C7, rv) C..7 OCT 0 6 2004 IN THE COURT OF COMMON PLEAS OF CHRISTOPHER L PLITT CUMBERLAND COUNTY, PENNSYLVANIA 04-987 CIVIL ACTION LAW VS. ANNA J. PLITT Defendant IN CUSTODY ORDER OF COURT I I dAn day of O 'l , 2004, upon ?- AND NOW, this consideration of the attached Custody Conciliation Report, ordered and directed as follows: 1. The prior order of this Court dated June 2004 is vacated and replaced with this Order. other individuals deemed 2. The parties shall submit themselves, their minor Child, air any necessary by the evaluator to a custody evaluation to be performed by Arnold Shienvold, Ph.D. The obtain inependent professional recommendations concerning purpose of the evaluation nents wh oh will besa serve the needs of the Child. At such time as deemed ongoing custody arrang es shall opriaYtrecommended by the evaluator. Alla custodial costs o f the evaluation shall be sharednm custodial arrangements equally between the parties. agreem the folwing chedule:Order the 3. parties shall have custody of the Cevaluation hild in a oa dance went of Court, the the p p A. The Mother shall have custody of the Child in every week from Monday after school through Tuesday after school and from Thursday after school through Friday after school. B. The Father shall have custody of the Child in every week from Tuesday after school through Thursday after school. C. The parties shall alternate having custody of the Child from Friday after school through Monday after school each week. D. During alternating weeks when the Mother has custody of the Chld da s from Thursday through Tuesday, the Father shall have a period f of custody with tthe y Child on Monday from 5:00 p.m. until 7:00 p.m. 4. The parties shall share having custody of the Child on holidays as follows: A. Halloween: The Mother shall have custody of the Child for the Mechanicsburg Halloween Parade. Accordingly, during the week of the Halloween Parade, the Father's period of custody shall be adjusted to run from Wednesday after school through Friday after school rather than beginning on Tuesday after school. B. Thanksgivine: The Father shall have custody of the Child on Thanksgiving Day until 3:00 p.m. and the Mother shall have custody of the Child on Thanksgiving Day beginning at 3:00 p.m. C. Christmas: The Mother shall have custody of the Child on Christmas Eve from 4:30 p.m. until 9:00 p.m., the Father shall have custody from Christmas Eve at 9:00 p.m. through Christmas Day at 3:00 p.m., and the Mother shall have custody from Christmas Day at 3:00 p.m. until December 26 at 3:00 p.m. D. New Year's: The Mother shall have custody of the Child from New Year's Eve at 4:00 p.m. through New Year's Day at 3:00 p.m. and the Father shall have custody from New Year's Day at 3:00 p.m. through January 2°d at 3:00 p.m. E. Parents' Birthdays: The Mother shall have custody of the Child on her birthday (December 4) and the Father shall have custody of the Child on his birthday (November 20) from 9:00 a.m. until 9:00 p.m. F. Childay: The Mother shall have custody of the Child on the Child's birthday (December 14) from 4:30 p.m. until 7:00 p.m. and the Father shall have custody of the Child for his regularly scheduled period of custody on the Child's birthday with the exception of the time reserved for the Mother in this provision. G. The holiday custody schedule shall supercede and take precedence over the regular custody schedule. 5. The parties shall have shared legal custody of the Child. Each parent shall have an equal right, to be exercised jointly with the other parent, 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 terns of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. Pending completion of the custody evaluation and further Order of Court, the Mother shall be temporarily responsible for arranging all medical appointments for the Child. The Mother shall notify the Father of the scheduling or cancellation of any appointments within 24 hours and shall provide all information and documents from each appointment to the Father within five days. Each party shall notify the other of any emergencies involving the Child which arise during that party's period of custody. The custodial parent shall provide all school papers and information concerning school and extracurricular activities for the Child to the other parent within two days of receipt. The parties shall consult with each other in enrolling the Child in any sports or other activities. 6. In the event either party intends to remove the Child from the Commonwealth of Pennsylvania or more than 100 miles from that party's residence, that part y shall provide advance notice to the other party of the address and telephone number where the Child can be contacted. 7. The parties shall strictly adhere to the custody schedule set forth in this Order unless otherwise mutually agreed in writing. 8. The party receiving custody shall be responsible to provide transportation for the exchange of custody unless otherwise agreed. 9. Neither party 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. Both parties shall ensure that third parties having contact with the Child comply with this provision. 10. Within 60 days of receipt of the evaluator's written custody recommendations, counsel for either party may contact the conciliator to schedule an additional custody conciliation necessary. conference, if . 11. 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 written mutual consent only. In the absence of mutual written consent, the terms of this Order shall control. BY Tl Edward E. Guido J. cc: vPeter J. Russo, Esquire - Counsel for Father Aori K. Serratelli, Esquire - Counsel for Mother A9-1a-oy OS :Z t!d i 1 DO UR CHRISTOPHER L. PLITT Plaintiff vs. ANNA J. PLITT Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-987 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLA VD COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: follows: 1. The pertinent information concerning the Child who is the subject of this litigation is as NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Zachary L. Plitt December 14, 1994 Mother/Father 2. A conciliation conference was held on September 29, 2004, with the following individuals in attendance: The Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire, and the Mother, Anna J. Plitt, with her counsel, Lori K. Serratelli, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator CHRISTOPHER L. PLITT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2004-987 CIVIL TERM CIVIL ACTION - LAW ANNA J. PLITT, Defendant IN DIVORCE NOTICE TO THE PLAINTIFF If you wish to deny any of the statements set forth in this Affidavit, you must file a counter affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. DEFENDANT'S AFFIDAVIT UNDER SECTION 3301(D) OF THE DIVORCE CODE 1. The parties to this action separated on or about July 2003 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning spousal support, alimony, division of marital property, attorney's fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. 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. Dated: ?e D .- J" Anna Plitt. J rJ C? Y c Y J r RECEIVFO AIIG 02 700 CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 04-987 CIVIL ACTION LAW ANNA J. PLITT Defendant IN CUSTODY ORDER OF COURT AND NOW, this J? day of ?, 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated October 11, 2004 is vacated and replaced with this Order. 2. The Father, Christopher L. Plitt, and the Mother, Anna J. Plitt, shall have shared legal custody of Zachary L. Plitt, born December 14, 1994. Each parent shall have an equal right, to be exercised jointly with the other parent, 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 this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. Each party shall notify the other of any emergencies involving the Child which arise during that party's period of custody. The custodial parent shall provide all school papers and information concerning school and extracurricular activities for the Child to the other parent within two days of receipt. The parties shall consult with each other in enrolling the Child in any sports or other activities and enrollment in such activities shall require the signatures of both parties on the appropriate forms unless one party provides written consent to the other parent to complete the signup procedures. Each party shall notify the other party in writing of an impending sign-up for an activity 72 hours in advance and that party shall respond within 24 hours of notification. In order to ensure the sharing of all information pertaining to the Child, the parties shall notify each other by e-mail every Sunday evening of all appointments, activities, enrollments or any other significant developments concerning the Child. The parties acknowledge that strict compliance with this requirement is essential to a continued sharing of legal custody. Counsel for either party may contact the conciliator to schedule an additional custody conciliation conference if necessary to address the inability or unwillingness of either party to strictly comply with this notice requirement. The parties agree to consult with each other before placing the Child in the care of unrelated third parties for extended activities during which the custodial parent will not be present. 3. The parties shall have physical custody of the Child in accordance with the following schedule: A. The Mother shall have custody of the Child every week from Monday after school through Tuesday after school and from Thursday after school through Friday after school. B. The Father shall have custody of the Child in every week from Tuesday after school through Thursday after school. C. The parties shall alternate having custody of the Child from Friday after school through Monday after school each week. D. Unless otherwise agreed between the parties, the specific time for exchanges of custody under this provision shall be 4:30 p.m. or after work, whichever is later. E. The Mother shall have custody of the Child during the summer school break when the Father is working. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. Halloween Trick or Treat Night: The Mother shall have custody of the Child for the Mechanicsburg Halloween Trick or Treat night each year. B. Thanks 'vine: In every year, the Father shall have custody of the Child on Thanksgiving Day from 9:00 a.m. until 3:00 p.m. and the Mother shall have custody on Thanksgiving Day from 3:00 p.m. until 9:00 p.m. C. Christmas: In every year, the Mother shall have custody of the Child on Christmas Eve from 3:00 p.m. until 9:00 p.m., the Father shall have custody from Christmas Eve at 9:00 p.m. through Christmas Day at 3:00 p.m., and the Mother shall have custody from Christmas Day at 3:00 p.m. until December 26 at 3:00 p.m. D. New Year's: In every year, the Mother shall have custody of the Child from New Year's Eve at 3:00 p.m. through New Year's Day at 3:00 p.m., and the Father shall have custody from New Year's Day at 3:00 p.m. through January 2 at 3:00 p.m. E. Memorial Da/Labor Day: In every year, the Father shall have custody of the Child on Memorial Day from 9:00 a.m. until 9:00 p.m. and the Mother shall have custody on Labor Day from 9:00 a.m. until 9:00 p.m. F. Independence Day: The parties shall alternate having custody of the Child on July 4th from 9:00 a.m. until after the fireworks. The Mother shall have custody of the Child on the holiday in odd numbered years and the Father shall have custody in even numbered years. G. Easter: hi every year, the Father shall have custody of the Child on Easter Sunday from 9:00 a.m. until 3:00 p.m. and the Mother shall have custody from 3:00 p.m. until 9:00 p.m. H. Mother's Day/Father's Day: In every year, the Mother shall have custody of the Child over the Mother's Day weekend from Sunday at 9:00 a.m. through Monday at 9:00 a.m., and the Father shall have custody of the Child over the Father's Day weekend from Sunday at 9:00 a.m. through Monday at 9:00 a.m. 1. Parents' Birthdays: The Mother shall have custody of the Child on her birthday (December 4) and the Father shall have custody of the Child on his birthday (November 20) from 9:00 a.m. until 9:00 p.m. J. Child's Birthday: In every year, the Father shall have custody of the Child from December 13 at 3:00 p.m. through December 14 at 3:00 p.m., and the Mother shall have custody from December 14 at 3:00 p.m. through December 15 at 3:00 p.m. K. The holiday schedule shall supercede and take precedence over the regular custody schedule. 5. In the event either party intends to remove the Child from the Commonwealth of Pennsylvania or more than 100 miles from that party's residence, that party shall provide advance notice to the other party of the address and telephone number where the Child can be contacted. 6. The custodial parent shall ensure that the Child returns all telephone calls to the non- custodial parent within 24 hours. 7. Each party shall be entitled to have custody of the Child during the summer school break each year for two non-consecutive weeks upon providing at least 30 days advance notice to the other party. Each party shall schedule his or her periods of vacation custody under this provision to include his or her regular weekend periods of custody. A party providing notice first under this provision shall be entitled to preference on his or her selection of vacation dates. In 2005, the Mother shall have custody of the Child for vacation from August 23 through August 30. As the parties acknowledge this period of vacation custody falls over the Father's regular alternating weekend, the Father shall have a make-up periods of custody with the Child on August 15, 2005 until 4:30 p.m. and from September 8, 2005 after school through his regularly alternating weekend period of custody ending on Monday, September 12. If the Father obtains an excused absence from the Child's school the Father may keep the Child out of school on Friday, September 9, to travel to a family wedding. If the Father is unable to obtain an excused absence from school, the Father may pick up the Child directly at school on September 9 to travel to the wedding. 8. The parties shall obtain counseling for the Child with a child psychologist as recommended by Dr. Shienvold. The parties shall select the professional by agreement, with the assistance of Dr. Shienvold, if appropriate. The parties shall select a child psychologist under this provision whose services will be covered by the Father's insurance, unless the parties agree to equally share the costs of the sessions. 9. The parties shall participate in a minimum of two mediation sessions with Deborah Salem, LPC to address difficulties in communication. For the two initial sessions, the parties shall equally share all costs. Thereafter, payment of the costs shall be as arranged by agreement between the parties. 10. The party receiving custody shall be responsible to provide transportation for the exchange of custody unless otherwise agreed. 11. Neither party 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. Both parties shall ensure that third parties having contact with the Child comply with this provision. 12. The parties may modify the provisions of this Order by written mutual consent only. In the absence of mutual written consent, the terms of this Order shall control. BY THE Edward E. Guido J. cc: &P'eter J. Russo, Esquire - Counsel for Father ,Xori K. Serratelli, Esquire - Counsel for Mother J oa. o? SS !:I h- V SDOI hu l i EHl ,i0 CHRISTOPHER L. PLITT Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-987 CIVIL ACTION LAW ANNA J. PLITT Defendant IN CUSTODY Prior Judge: Edward E. Guido 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 Zachary L. Plitt December 14, 1994 Mother/Father 2. A conciliation conference was held on July 18, 2005, with the following individuals in attendance: The Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire, and the Mother, Anna J. Plitt, with her counsel, Lori K. Serratelli, Esquire. 3. The parties agreed to entry of an Order in the form as attached, with the exception of the pick-up times for the Father's periods of custody which are the recommendations of the conciliator as the parties' positions differed on this issue by one-half hour. The make-up dates for the weekend period of custody missed by the Father due to the Mother's vacation are also recommended by the conciliator. In future years, in accordance with the proposed Order, the parties will schedule vacation dates to include his or her regular weekend periods of custody. c u.a E I 1? oc? SS D611()L?L=?z ate Dawn S. Sunday, Esquire Custody Conciliator Lori K. Serratelli, Esquire Pa. Supreme Court ID No. 27426 Serratelli, Schiffman, Brown and Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney For Defendant CHRISTOPHER L. PLITT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2004-987 CIVIL TERM CIVIL ACTION - LAW ANNA J. PLITT, Defendant IN DIVORCE 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: 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail, restricted delivery on March 10, 2004 3. a. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff N/A by Defendant N/A b. (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: 7/18/05 ; (2) Date of filing and service of the Defendant's affidavit upon the Plaintiff: Filed 7/21/05 Served 7/26/05 4. Related claims pending: None. 5. a. Date plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: N/A Date defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: N/A b. Date and manner of service of the Notice of Intention to file Praecipe a copy of which is attached: certified mail to Plaintiff's counsel, service - 8/16/05. Dated: " - L i K. Serratelli, Esquire RRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant CERTIFICATE OF SERVICE I, Lori K. Serratelli, Esquire, do hereby certify that on this Ij. day of , 2005, I served a copy of the foregoing document by United States Mail, First Class, postage pre-paid, to the following person(s): Peter J. Russo, Esquire The Chelsea Building 3800 Market Street Camp Hill, PA 17011 Lo/ ?. erratelli, Esquire SERRRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant ?- ?, ;,,; '=: ?,> '_ c ,?, -? __ JECEIV-- CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 04-987 CIVIL ACTION LAW ANNA J. PLITT Defendant IN CUSTODY ORDER OF COURT AND NOW, this lD day of 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court are vacated and replaced with this Order. 2. The Father, Christopher L. Plitt, and the Mother, Anna J. Plitt, shall have shared legal custody of Zachary L. Plitt, born December 14, 1994. Each parent. shall have an equal right, to be exercised jointly with the other parent, 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 this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. Each party shall notify the other of any emergencies involving the Child which arise during that party's period of custody. The custodial parent shall provide all school papers and information concerning school and extracurricular activities for the Child to the other parent within two days of receipt. The parties shall consult with each other in enrolling the Child in any sports or other activities and enrollment in such activities shall require the signatures of both parties on the appropriate forms unless one party provides written consent to the other parent to complete the signup procedures. Each party shall notify the other party in writing of an impending sign-up for an activity 72 hours in advance and that party shall respond within 24 hours of notification. In order to ensure the sharing of all information pertaining to the Child, the parties shall notify each other by e-mail every Sunday evening of all appointments, activities, enrollments or any other significant developments concerning the Child. The parties acknowledge that strict compliance with this requirement is essential to a continued sharing of legal custody. Counsel for either party may contact the conciliator to schedule an additional custody conciliation conference if necessary to address the inability or unwillingness of either party to strictly comply with this notice requirement. The parties agree to consult with each other before placing the Child in the care of unrelated third parties for extended activities during which the custodial parent will not be present. 3. The parties shall have physical custody of the Child in accordance with the following schedule: A. The Mother shall have custody of the Child every week from Monday after school through Tuesday after school and from Thursday after school through Friday after school. B. The Father shall have custody of the Child in every week from Tuesday after school through Thursday after school. C. The parties shall alternate having custody of the Child from Friday after school through Monday after school each week. D. Unless otherwise agreed between the parties, the specific time for exchanges of custody under this provision shall be 4:30 p.m. if the party receiving custody is not working or 5:30 p.m. if the party receiving custody is working later than 4:30 p.m. E. The Mother shall have custody of the Child during the summer school break when the Father is working. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. Halloween Trick or Treat Night: The Mother shall have custody of the Child for the Mechanicsburg Halloween Trick or Treat night each year. B. Thanksgiving: In every year, the Father shall have custody of the Child on Thanksgiving Day from 9:00 a.m. until 3:00 p.m. and the Mother shall have custody on Thanksgiving Day from 3:00 p.m. until 9:00 p.m. C. Christmas: In every year, the Mother shall have custody of the Child on Christmas Eve from 3:00 p.m. until 9:00 p.m., the Father shall have custody from Christmas Eve at 9:00 p.m. through Christmas Day at 3:00 p.m., and the Mother shall have custody from Christmas Day at 3:00 p.m. until December 26 at 3:00 p.m. D. New Year's: In every year, the Mother shall have custody of the Child from New Year's Eve at 3:00 p.m. through New Year's Day at 3:00 p.m., and the Father shall have custody from New Year's Day at 3:00 p.m. through January 2 at 3:00 p.m. E. Memorial Day/Labor DU: In every year, the Father shall have custody of the Child on Memorial Day from 9:00 a.m. until 9:00 p.m. and the Mother shall have custody on Labor Day from 9:00 a.m. until 9:00 p.m. F. Independence Day: The parties shall alternate having custody of the Child on July 4m from 9:00 a.m. until after the fireworks. The Mother shall have custody of the Child on the holiday in odd numbered years and the Father shall have custody in even numbered years. G. Easter: In every year, the Father shall have custody of the Child on Easter Sunday from 9:00 a.m. until 3:00 p.m. and the Mother shall have custody from 3:00 p.m. until 9:00 p.m. H. Mother's Day/Father's Day: In every year, the Mother shall have custody of the Child over the Mother's Day weekend from Sunday at 9:00 a.m. through Monday at 9:00 a.m., and the Father shall have custody of the Child over the Father's Day weekend from Sunday at 9:00 a.m. through Monday at 9:00 a.m. I. Parents' Birthdays: The Mother shall have custody of the Child on her birthday (December 4) and the Father shall have custody of the Child on his birthday (November 20) from 9:00 a.m. until 9:00 p.m. J. Child's Birthday: In every year, the Father shall have custody of the Child from December 13 at 3:00 p.m. through December 14 at 3:00 p.m., and the Mother shall have custody from December 14 at 3:00 p.m. through December 15 at 3:00 p.m. K. The holiday schedule shall supercede and take precedence over the regular custody schedule. 5. In the event either party intends to remove the Child from the Commonwealth of Pennsylvania or more than 100 miles from that party's residence, that party shall provide advance notice to the other party of the address and telephone number where the Child can be contacted. 6. The custodial parent shall ensure that the Child returns all telephone calls to the non- custodial parent within 24 hours. 7. Each party shall be entitled to have custody of the Child during the summer school break each year for two non-consecutive weeks upon providing at least 30 days advance notice to the other party. Each party shall schedule his or her periods of vacation custody under this provision to include his or her regular weekend periods of custody. A party providing notice first under this provision shall be entitled to preference on his or her selection of vacation dates. In 2005, the Mother shall have custody of the Child for vacation from August 23 through August 30. As the parties acknowledge this period of vacation custody falls over the Father's regular alternating weekend, the Father shall have make-up periods of custody with the Child on August 15, 2005 and from September 8, 2005 at 4:30 p.m. through his regular alternating weekend period of custody ending on Monday, September 12 before school. If the Father obtains an excused absence from the Child's school the Father may keep the Child out of school on Friday, September 9, to travel to a family wedding. 8. The parties shall obtain counseling for the Child with a child psychologist as recommended by Dr. Shienvold. The parties shall select the professional by agreement, with the assistance of Dr. Shienvold, if appropriate. The parties shall select a child psychologist under this provision whose services will be covered by the Father's insurance, unless the parties agree to equally share the costs of the sessions. 9. The parties shall participate in a minimum of two mediation sessions with Deborah Salem, LPC to address difficulties in communication. For the two initial sessions, the parties shall equally share all costs. Thereafter, payment of the costs shall be as arranged by agreement between the parties. 10. The party receiving custody shall be responsible to provide transportation for the exchange of custody unless otherwise agreed. 11. Neither party 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. Both parties shall ensure that third parties having contact with the Child comply with this provision. 12. The parties may modify the provisions of this Order by written mutual consent only. In the absence of mutual written consent, the terms of this Order shall control. cc: VPeter J. Russo, Esquire - Counsel for Father V66 K. Serratelli, Esquire - Counsel for Mother 0?"0 1 Edward E. Guido J. 91 :6 PV L- 4.1S SOOZ CHRISTOPHER L. PLITT Plaintiff VS. ANNA J. PLITT Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-987 CIVIL ACTION LAW 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 Zachary L. Plitt December 14, 1994 Mother/Father 2. A conciliation conference was held on July 18, 2005, with the following individuals in attendance: The Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire, and the Mother, Anna J. Plitt, with her counsel, Lori K. Serratelli, Esquire. Although a Report and proposed Order were forwarded to the Court following that conference, the recommendations as to custody exchange times and make up periods of custody were not sufficiently specific to prevent further conflict and scheduling issues between the parties. The present revised Report and Proposed Order reflects amendments, with input from counsel to resolve those issues. 3. The parties agreed to entry of an Order in the form as attached, with the exception of the pick-up times for the Father's periods of custody which are the recommendations of the conciliator as the parties' positions differed on this issue by one-half hour. The make-up dates for the weekend period of custody missed by the Father due to the Mother's vacation are also recommended by the conciliator. In future years, in accordance with the proposed Order, the parties will schedule vacation dates to include his or her regular weekend periods of custody. A g3,L,,?x 30, aoo5 Dat- eC) Dawn S. Sunday, Esquire Custody Conciliator CHRISTOPHER L. PLITT, Plaintiff vs. ANNA J. PLITT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-987 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Lori K. Serratelli, being duly sworn according to law, depose and say that the Notice of Intention to Request Entry of Divorce Decree with attached proposed Praecipe to Transmit Record under Section 3301(d) of the Divorce Code were served upon the Plaintiff by depositing them in the United States mail, certified mail, return receipt requested on August 15, 2005, addressed as follows: Peter J. Russo, Esquire The Chelsea Building 3800 Market Street Camp Hill, PA 17011 Attorney for Plaintiff The Return Receipt card was signed on August 2005 and is? attached hereto. L K erratelli, Esq. RRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. Sworn and Subscribed to before me this J-74day of?22005. OT?BLld 2080 Linglestown Rd., Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant NOTARIAL SEAL DEBRA A EVANGEM Notary Public SU90UENANNA 7WRDAUPHN CO(W My COMMUM Expir t May 7.2005 c> ? a __ Gry "C1 -1 fll ?- ? s7 G co '-?'? t17 (.. -'r1 cn Q CHRISTOPHER L. PLITT, Plaintiff vs. ANNA J. PLITT, Defendant : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-987 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Lori K. Serratelli, being duly sworn according to law, depose and say that the Notice to the Plaintiff/Defendant's Affidavit under Section 3301(d) of the Divorce Code was served upon the Plaintiff by depositing it in the United States mail, certified mail, return receipt requested on July 25, 2005, addressed as follows: Peter J. Russo, Esquire The Chelsea Building 3800 Market Street Camp Hill, PA 17011 Attorney for Plaintiff The Return Receipt card was sighed on July 26, 2 905 and is attached hereto Lor' erratelli, Esq. SE TELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Rd., Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant Sworn and Subscribed to befor me this J7aday of 2005. SEAL NGEL)" ublIc [m:y::: AUPNIN COUNTY N TARY PUBLI res May 7, 2008 ¦ Complete Items 1, 2, and 3. Also complete c9J natur Item 4 if Restricted Delivery is desired. X 0 Agent ¦ Print your name and address on the reverse 0 Addre so that we can return the card to you. a, b (FNnted N me) D of D ¦ Attach this card to the back of the mailpiece, or on the front if space permits. t D. delivery addn different from item 1? 0 Y 1. Article Addressed to: It YES, enter delivery address below: 0 No ?? J . Rvsso , E5 ?,rr 3%c>0 w-c'-Y\"E? C-I P P O ?1ot 1 3. ke Type Certified Maul 0 Express Mail 0 Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extre Fee) 0 yes 2. Article u (iransferns/er from om service IebeD 7004 2890 0000 0991 5446 Ps Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1035 N C o ? _" cn _- to m . -V3 Tr ' ` f - ` tom.) ID cn Q '? Lori K. Serratelli, Esquire Pa. Supreme Court ID No. 27426 Serratelli, Schiffman, Brown and Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney For Defendant CHRISTOPHER L. PLITT, Plaintiff VS. ANNA J. PLITT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-987 CIVIL CIVIL ACTION - LAW . IN DIVORCE 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. Grounds for divorce: 3301(1) of the Divorce Code. 2. Date and manner of service of the! Complaint: Certified Mail, restricted delivery on Max-ch 10, 2004. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by section 3301(c) of the Divorce Code: by Plaintiff N/A ; by Defendant NIA (b) (1) Date of execution of the Defendant's Affidavit required by Section 3301(d) of the Divorce Code: 7/18/05; (2) date of service of the Defendant's Affidavit upon the Plaintiff: Certified mail, return receipt requested to Plaintiff's counsel on 7/25/05. Affidavit of Service filed with the Court simultaneously herewith. 4. Related claims pending: Equitable Distribution 5. a. Date Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: N/A Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: N/A b. Date and manner of service of the Notice of Intention to file Praecipe a copy of which is attached: Certified Mail, return receipt requested to Plaintiff's counsel on August 15, 2005. Affidavit of Service filed with the Court simultaneously herewith. 7 Dated: 12-7-Z-005? Q Lo . Serratelli, Esquire SE RAtELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant CHRISTOPHER L. PLITT, Plaintiff VS. ANNA J. PLITT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-987 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE Defendant intends to file with the court the attached Praecipe to Transmit Record on or after September 6, 2005 requesting that a final decree in divorce be entered. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Dauphin County Lawyer Referral Service 213 N. Front Street Harrisburg, PA 17101- (717) 232-7536 CHRISTOPHER L. PLITT, Plaintiff VS. ANNA J. PLITT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-987 CIVIL TERM CIVIL ACTICN - LAW IN DIVORCE PLAINTIFF'S COUNTERAFFIDAVIT UNDER SECTION 3301(D) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least. two years. (ii) The marriage is not irretrievably broken. (2) Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights: concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counteraffidavit 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. Dated: Christopher L. Plitt NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTERAFFIDAVIT. Lori K. Serratelli, Esquire Pa. Supreme Court ID No. 27426 Serratelli, Schiffman, Brown and Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney For Defendant CHRISTOPHER L. PLITT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2004-987 CIVIL TERM : CIVIL ACTION - LAW ANNA J. PLITT, Defendant IN DIVORCE 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: 3301(d) of the Divorce,Code. 2. Date and manner of service of the complaint: Certified mail, restricted delivery on March 10, 2004. 3. a. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff N/A by Defendant N/A b. (1) Date of execution of the affidavit required by 93301(d) of the Divorce Code:: 7/18/05 ; (2) Date of filing and service of the Defendant's affidavit upon the Plaintiff: Filed 7/21/05; Served 7/26/05 4. Related claims pending: None. 5. a. Date plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: N/A ; Date defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: N/A b. Date and manner of service of the Notice of Intention to file Praecipe a copy of which is attached: Dated: Loki?K. Serratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant c- ? n C! .y UJ CJ ??rn f?i ?7 CHRISTOPHER L. PLITT, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-987 CIVIL ANNA J. PLITT, Defendant ORDER AND NOW, this a? day of September, 2005, after review of the file, we could find no indication that the Notice of Intention to Request Entry of Divorce Decree in the form required by Rule 1920.73 was served upon plaintiff's counsel as required by Rule 1920.42(d)(1). The defendant's request for the entry of a Final Divorce Decree is Denied without prejudice. Edward E. Guido, J. eter J. Russo, Esquire For the Plaintiff on K. Serratelli, Esquire For the Defendant AM a ViNVA-I'k ?I -c{ 00 :h Wd ZZ d3S SOOZ AHVIONVHIWWd 1RL:10 CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ANNA J. PLITT : NO. 2004 - 0987 CIVIL TERM ORDER OF COURT AND NOW, this I OTH day of OCTOBER, 2005, it appearing to the Court that a claim for equitable distribution is pending, and no petition for bifurcation has been filed by either party, the Defendant's request for the entry of a divorce decree is DENIED without prejudice. the Court, Edward E. Guido, J. after J. Russo, Esquire ,,L'bri K. Serratelli, Esquire :sld y?? J6. 60 :6 11 110 SOOZ AbVif p . !..: i 'DA d0 CHRISTOPHER L. PLITT, Plaintiff vs. ANNA J. PLITT, Defendant, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004-987 CIVIL TERM CIVIL ACTION - T vu .UtA IN DIVORCE PRAECIPE TO WITHDRAW COUNT TO THE PROTHONOTARY: Please withdraw Count II, Equitable Distribution, of Plaintiff's Complaint in Divorce. Respectfully submitted, Peter J. Russo, Esquire The Chelsea Building 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Attorney for Plaintiff r? - T.. aJ Lori K. Serratelli, Esquire Pa. Supreme Court ID No. 27426 Serratelli, Schiffman, Brown and Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney For Defendant CHRISTOPHER L. PLITT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 04-987 CIVIL CIVIL ACTION - LAW ANNA J. PLITT, Defendant IN DIVORCE 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. Grounds for divorce: 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail, restricted delivery on March 10, 2004 3. (Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff N/A ; by Defendant N/A I (b) (1) Date of execution of the Defendant's Affidavit required by Section 3301(d) of the Divorce Code: 7/18/05; (2) date of service of the Defendant's Affidavit upon the Plaintiff: Certified mail, return receipt requested to Plaintiff's counsel on 7/25/05. Affidavit of Service filed with the Court 7/28/05. 4. Related claims pending: None 5. a. Date Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: _ N/A Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: N/A b. Date and manner of service of the Notice of Intention to file Praecipe a copy of which is attached: Certified Mail, return receipt requested to Plaintiff's counsel on August 15, 2005 Affidavit of Service filed with the Court September 28, 2005. Dated: /,z } Lor4i. Serratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant n? C.") c =. _ c ? ; C -ri -- ? ?i? tom.: ,-- _ -- ---° ?- ? - - ?? :; ?-: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. CHRISTOPHER L. PLITT, Plaintiff No. 04-987-CIVIL TERM VERSUS ANNA J. PLITT, Defendant DECREE IN DIVORCE AND NOW, o0 IT 15 ORDERED AND DECREED THAT Christopher L. Plitt PLAINTIFF, AND Anna J. Plitt DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; No issues remain. HONOTARY ?,?rr ,.?? ? ? p/ off' '? ? V? ?P ?? ?? ?? . i????? > >. . • -: .. CHRISTOPHER L. PLITT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04-987 ANNA J. GREGOR (PLITT), Defendant CIVIL ACTION -CUSTODY TO THE HONORABLE, THE JUDGES OF SAID COURT AND NOW, comes the Defendant, Anna J. Gregor, by and through her attorney, Gary L. Kelley, and files this Petition For Emergency Relief and in support thereof respectfully avers as follows: PETITION FOR EMERGENCY RELIEF 1. Plaintiff is Christopher L. Plitt who resides at 1164 Heron Court, Mechanicsburg, Pennsylvania 17050. 2. Defendant is Anna J. Gregor who resides at 88 Margaret Drive, Mechanicsburg, Pennsylvania 17050. 3. The parties are the parents of one (1) minor child, Zachory L, Plitt, date of birth December 14, 1994. 4. Pursuant to an Order dated September 6, 2005, the parties share legal custody, alternate holidays, and share physical custody of the child in accordance with the following schedule during the school year: 3. ... A. The Mother shall have custody of the Child every week from Monday after school through Tuesday after school and from Thursday after school through Friday after school. B. The Father shall have custody of the Child in every week from Tuesday after school through Thursday after school. C. The parties shall alternate having custody of the Child from Friday after school through Monday after school each week. A true and correct copy of this Order is attached hereto as Exhibit "A" and is incorporated herein 5. Defendant is engaged and plans to be married on May 7, 2006. According to the schedule which the parties are presently following, the minor child is to be with Plaintiff this weekend, Friday, May 5, 2006 through Monday, May 8, 2006. 6. Defendant would like to have the parties' son, Zachary, attend and be part of the ceremony. 7. Zachary has indicated his desire to attend and participate in the ceremony. 8. Defendant has made requests of Plaintiff for the child to attend her wedding. 9. Defendant has not responded. 10. On April 11, 2006, the undersigned sent a letter to Peter J. Russo, Esquire, counsel for Plaintiff and requested an accomodation for the weekend so that Zachary could attend and participate in the ceremony. A true and correct copy of the letter dated April 11, 2006 is attached hereto as Exhibit "B" and incorporated herein. 11. Defendant's counsel received a telephone call from Mr. Russo on or about April 13, 2006. related that his client declined to exchange weekends. 13. Since this conversation, the undersigned has not had any additional contact with Mr. Russo. 14. It is in the best interest of the minor child that he be permitted to attend and participate in his mother's wedding. 15. The Plaintiff will not be prejudiced by exchanging weekends or receiving some other compensatory time in order for the child to attend his mother's wedding. 16. Without the intervention of this Honorable Court, the child will be denied an irreplaceable opportunity to participate in his mother's wedding. WHEREFORE, the Defendant respectfully requests that this Honorable Court grant her request and issue an Order providing for her son to be in her custody for May 5, 2006 through May 8, 2006 and Order such compensatory time as this Honorable Court deems fair and equitable. Respectfully submitted, L. IDNo-. 46801 1114 Front Strut, SujU Harrisburg, PA l b2 (717) 238-1484 Attorney for Defendant 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. Section 4904, relating to unsworn falsification to authorities. L' ' CHRISTOPHER L. PLITT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 04-987 ANNA J. GREGOR (PLITT), Defendant CIVIL ACTION -CUSTODY CERTIFICATE OF SERVICE I, Gary L. Kelley, counsel for the Defendant, do hereby certify that I served a true and correct copy of Defendant's Petition For Emergency Relief upon counsel for Plaintiff on the 21st day of April, 2006 by First Class US Mail, postage prepaid, addressed as follows: Peter J. Russo, Esq. The Chelsea Building 3800 Market Street Camp Hill, PA 17011 Gary, L. K lley i ID ? O1 1119 Front Street Harrisburg, PA 17102 (717) 238-1484 Attorney for Defendant EXHIBIT "A" CHRISTOPHER L. PLITT Plaintiff vs. ANNA J. PLITT Defendant J t E C E i' 0 1 20a? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-987 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this W d v1 day of , 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court are vacated and replaced with this Order. 2. The Father, Christopher L. Plitt, and the Mother, Anna J. Plitt, shall have shared legal custody of Zachary L. Plitt, born December 14, 1994. Each parent shall have an equal right, to be exercised jointly with the other parent, 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 this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. Each party shall notify the other of any emergencies involving the Child which arise during that party's period of custody. The custodial parent shall provide all school papers and information concerning school and extracurricular activities for the Child to the other parent within two days of receipt. The parties shall consult with each other in enrolling the Child in any sports or other activities and enrollment in such activities shall require the signatures of both parties on the appropriate forms unless one party provides written consent to the other parent to complete the signup procedures. Each party shall notify the other party in writing of an impending sign-up for an activity 72 hours in advance and that party shall respond within 24 hours of notification. In order to ensure the sharing of all information pertaining to the Child, the parties shall notify each other''oy e-mail every Sunday evening of all appointments, activities, enrollments or any other significant developments concerning the Child. The parties acknowledge that strict compliance with this requirement is essential to a continued sharing of legal custody. Counsel for either party may contact the conciliator to schedule an additional custody conciliation conference if necessary to address the inability or unwillingness of either party to strictly comply with this notice requirement. The parties agree to consult with each other before placing the Child in the care of unrelated third parties for extended activities during which the custodial parent will not be present. 3. The parties shall have physical custody of the Child in accordance with the following schedule: A. The Mother shall have custody of the Child every week from Monday after school through Tuesday after school and from Thursday after school through Friday after school. B. The Father shall have custody of the Child in every week from Tuesday after school through Thursday after school. C. The parties shall alternate having custody of the Child from Friday after school through Monday after school each week. D. Unless otherwise agreed between the parties, the specific time for exchanges of custody under this provision shall be 4:30 p.m. if the party receiving custody is not working or 5:30 p.m. if the party receiving custody is working later than 4:30 p.m. E. The Mother shall have custody of the Child during the summer school break when the Father is working. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. Halloween Trick or Treat Night: The Mother shall have custody of the Child for the Mechanicsburg Halloween Trick or Treat night each year. B. Thanksgiving: In every year, the Father shall have custody of the Child on Thanksgiving Day from 9:00 a.m. until 3:00 p.m. and the Mother shall have custody on Thanksgiving Day from 3:00 p.m. until 9:00 p.m. C. Christmas: In every year, the Mother shall have custody of the Child on Christmas Eve from 3:00 p.m. until 9:00 p.m., the Father shall have custody from Christmas Eve at 9:00 p.m. through Christmas Day at 3:00 p.m., and the Mother shall liave custody from Christmas Day at 3:00 p.m. until December 26 at 3:00 p.m. D. New Year's: In every year, the Mother shall have custody of the Child from New Year's Eve at 3:00 p.m. through New Year's Day at 3:00 p.m., and the Father shall have custody from New Year's Day at 3:00 p.m. through January 2 at 3:00 p.m. E. Memorial Dav/Labor Day: In every year, the Father shall have custody of the Child on Memorial Day from 9:00 a.m. until 9:00 p.m, and the Mother shall have custody on Labor Day from 9:00 a.m. until 9:00 p.m. F. Independence Day: The parties shall alternate having custody of the Child on July 4`h from 9:00 a.m. until after the fireworks. The Mother shall have custody of the Child on I , the holiday in odd numbered years and the Father shall have custody in even numbered years. G. Easter: In every year, the Father shall have custody of the Child on Easter Sunday from 9:00 a.m. until 3:00 p.m. and the Mother shall have custody from 3:00 p.m. until 9:00 p.m. H. Mother's DayjAther's Day: In every year, the Mother shall have custody of the Child over the Mother's Day weekend from Sunday at 9:00 a.m. through Monday at 9:00 a.m., and the Father shall have custody of the Child over the Father's Day weekend from Sunday at 9:00 a.m. through Monday at 9:00 a.m. 1. Parents' Birthdays: The Mother shall have custody of the Child on her birthday (December 4) and the Father shall have custody of the Child on his birthday (November 20) from 9:00 a.m. until 9:00 p.m. J. Child's Birthday: In every year, the Father shall have custody of the Child from December 13 at 3:00 p.m. through December 14 at 3:00 p.m., and the Mother shall have custody from December 14 at 3:00 p.m. through December 15 at 3:00 p.m. K. The holiday schedule shall supercede and take precedence over the regular custody schedule. 5. In the event either party intends to remove the Child from the Commonwealth of Pennsylvania or more than 100 miles from that party's residence, that party shall provide advance notice to the other party of the address and telephone number where the Child can be contacted. 6. The custodial parent shall ensure that the Child returns all telephone calls to the non- custodial parent within 24 hours. 7. Each party shall be entitled to have custody of the Child during the summer school break each year for two non-consecutive weeks upon providing at least 30 days advance notice to the other party. Each party shall schedule his or her periods of vacation custody under this provision to include his or her regular weekend periods of custody. A party providing notice first under this provision shall be entitled to preference on his or her selection of vacation dates. In 2005, the Mother shall have custody of the Child for vacation from August 23 through August 30. As the parties acknowledge this period of vacation custody falls over the Father's regular alternating weekend, the Father shall have make-up periods of custody with the Child on August 15, 2005 and from September 8, 2005 at 4:30 p.m. through his regular alternating weekend period of custody ending on Monday, September 12 before school. If the Father obtains an excused absence from the Child's school the Father may keep the Child out of school on Friday, September 9, to travel to a family wedding. 8. Tlic patties shall obtain counseling for the Child with a child psychologist as recommended by Dr. 5hienvold. The patties shall select the professional by agreement, with the assistance of Dr. Shienvold, if appropriate. The parties shall select a child psychologist under this provision whose services wilt be covered by the Father's insurance, unless the parties agree to equally share the costs of the sessions. 9. The parties shall participate in a minimum of two mediation sessions with Deborah Salem, LPC to address difficulties in communication. For the two initial sessions, the parties shall equally share all costs. Thereafter, payment of the costs shall be as arranged by agreement between the parties. 10. The party receiving custody shall be responsible to provide transportation for the exchange of custody unless otherwise agreed. t 1. Neither party 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. Both parties shall ensure that third patties having contact with the Child comply with this provision. 12. The parties may modify the provisions of this Order by written mutual consent only. In the absence of mutual written consent, the terms ofthis Order shall control. BY Edward E. Guido J. ca Peter J. Russo, Esquire - Counsel for Father Lori K. Serratelli, Esquire - Counsel for Mother 7 . lk6 EXHIBIT "B" , .w Law Offices Of GARY L. KELLEY 1119 North Front Street, Suite B Harrisburg, PA 17102 (717) 238-1484 Facsimile (717) 238-1761 April 11, 2006 Peter J. Russo, Esq. The Chelsea Building 3800 Market Street Camp Hill, PA 17011 Re: Plitt v. Gregor (Plitt) Dear Mr. Russo: I have been contacted by Ms. Gregor regarding custody. Ms. Gregor is planning to be married on May 7, 2006. She would like to have her son, Zachary, attend the wedding and be part of the ceremony. Unfortunately, the parties have been unable to agree to any changes in the present schedule as your client is scheduled to have custody of Zachary during this weekend. Accordingly, I am respectfully requesting that Ms. Gregor have custody of Zachary from May 6, 2006 at 9:00 AM through Monday, May 8, 2006. Ms. Gregor would be happy to exchange two days or a weekend for this accommodation for a special event. Please let me know at your earliest convenience if we are able to reach a mutual accommodation. Thank you for your attention to this matter. Very truly yours, 'i Gary L. Kelley cc: Anna Gregor y?? ) . -,.. ?" ? ? 0 ?, I' ?''? ? cl' C APR 2 1 2006 CHRISTOPHER L. PLITT, IN THE COURT OF COMMON PLEAS Plaintiff ; CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04-987 ANNA J. GREGOR (PLITT), Defendant CIVIL ACTION -CUSTODY ORDER OF COURT AND NOW, 20C7 upon consideration of Defendant's Petition For Emergency Relief, it is hereby ORDERED and DECREED that a conference is scheduled with this Court on , 2006, at .'00 AM/Af in Courtroom No. 3 to address Defendant's Petition. The parties areArlA¢br .dKac d to attend this conference. THE Edward E. Guido, JUDGE b Oil P ? ?• ? ? ? ? 1 r, _ „ J CHRISTOPHER L. PLITT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 04-987 ANNA J. GREGOR (PLITT), Defendant CIVIL ACTION -CUSTODY ORDER OF COURT AND NOW, _ a 2006, upon agreement of the parties, it is hereby ORDERED and DECREED that the Petition For Emergency Relief filed By Defendant is resolved and the hearing scheduled for Thursday, April 27, 2006 at 9:00 AM is cancelled. It is further ORDERED and DECREED that by agreement of the parties Defendant shall have custody of the minor child, Zachary, from Friday, May 5, 2006 after school through Monday, May 8, 2006. In exchange, Plaintiff shall have custody of the minor child, Zachary, from Friday, July 21, 2006 through Monday, July 24, 2006 at 4:30 PM. The parties are aware that Plaintiff will be exercising his vacation for the week of July 14, 2006 through July 21, 2006 in conjunction with the above modification. All other aspects of the Court's Order dated September 6, 2005 shall remain in full force and effect. BY THE CO13RT: i f Edward E. Guido, JUDGE ?'?? 04/25/2006 16:67 F.-Y 8601 FAX TRANSMITTAL FORM PETER J. Russo, ESQUIRE Law Offices of Peter J. Russo, P. C. The Chelsea Building 3800 Market Street Camp Hill, PA 17011 OFFICE (717) 591-1755 FAX (717) 591-1756 FAX NUMBER: (717) 238-1761 RECEIVER'S NAME: Gary Kelley, Eso TODAY'S DATE: Tuesday, April 25, 2006 NO. OF PAGES INCLUDING THIS PAGE: 1 Gary - In response to your fax, my client proposes: Anna has Zachary on Friday, May 5th until Monday, May 8th. In exchange Chris has Zachary for Friday, July 2151 at 4:30 pm to Monday, July 24th at 4:30pm. Again, Chris has exercised his vacation rights for the week of July 14th to the 21st. In the alternative, see you Thursday morning. Pete / V ?k Z4?? CHRISTOPHER L. PLITT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04-987 ANNA J. GREGOR (PLITT), Defendant CIVIL ACTION - CUSTODY TO THE HONORABLE, THE JUDGES OF SAID COURT AND NOW, comes the Defendant, Anna J. Gregor, by and through her attorney, Gary L. Kelley, and files this Petition To Modify Custody and in support thereof respectfully avers as follows: PETITION TO MODIFY CUSTODY 1. Plaintiff is Christopher L. Plitt who resides at 1164 Heron Court, Mechanicsburg, Pennsylvania 17050. 2. Defendant is Anna J. Gregor who resides at 88 Margaret Drive, Mechanicsburg, Pennsylvania 17050. 3. The parties are the parents of one (1) minor child, Zachary L. Plitt, date of birth December 14, 1994. 4. Pursuant to an Order dated September 6, 2005, the parties share legal custody, alternate holidays, and share physical custody of the child in accordance with the following schedule during the school year: 3. ... A. The Mother shall have custody of the Child every week from Monday after school through Tuesday after school and from Thursday after school through Friday after school. 1 0% B. The Father shall have custody of the Child in every week from Tuesday after school through Thursday after school. C. The parties shall alternate having custody of the Child from Friday after school through Monday after school each week. 5. Defendant seeks primary custody of the following child: Name Present residence Age Zachary L. Plitt As above DOB 12/14/94 5. The child was born during the course of marriage. The child is presently in the shared custody of the parties. 7. Since November 2005) the child has resided with the following persons and at the following addresses: Plaintiff Persons Jeffrey Bender Addresses 41 Morris Road Duncannon Dates November 2005 to present Defendant Percang Addresses Dates Crystal Bender 103 Timber Lane November 2005 to present Alauria Christy Shippensburg Janay Christy During the time in question, the parties have essentially shared custody of the minor child on an equal basis. 8. The mother of the child is Defendant. She was married to the father of the child, Plaintiff. The parties are divorced. 9. The relationship of Plaintiff to the child is that of father. Plaintiff currently resides with the following persons: Name Relationship Lynnze Bender Daughter 10. The relationship of Defendant to the child is that of mother. Defendant currently resides with the following persons: Name Relationship Lynnze Bender Daughter Alauria Christy Daughter 3anay Christy Daughter 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. Plaintiff has no information of a custody proceeding concerning the child 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 child or who claims to have custody or visitation rights with respect to the child. 12. The best Interest and permanent welfare of the child will be served by granting the relief requested because: Plaintiff is a fit parent. . 1 Plaintiff has a close relationship with the child. The child views plaintiff as a source of love and affection. 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, the Defendant respectfully requests that this Honorable Court grant her shared legal and primary physical of the minor child. Respectfully submitted, Garr jKelley ID 6801 1119 :Front Street, Sul Harrisburg, PA 17102 (717) 238-1484 Attorney for Defendant Z\D -;t ICI E J CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 04-987 CIVIL ACTION LAW ANNA J. GREGOR (PLITT) IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, October 13, 2006 , 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, November 15, 2006 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. (?y 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 4f) L / al NOV 802006p? CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 04-987 CIVIL ACTION LAW ANNA J. PLITT Defendant IN CUSTODY ORDER OF COURT r? AND NOW, this - day of A we_,? , 204,, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall engage in a course of co-parenting counseling with Stanley Schneider or other professional selected by agreement. The purpose of the counseling shall be to assist the parties in establishing a cooperative and effective parenting relationship in order to promote and protect the emotional well-being of the Child, and to address issues in conflict which are identified in the parties' respective Court petitions. The parties shall participate in a minimum of four joint sessions (in addition to any individual sessions) and shall follow the counselor's recommendations with regard to further participation in the counseling process. The parties shall equally share any costs for joint sessions which are not reimbursed by insurance and each party shall be responsible to pay any unreimbursed costs of that party's individual sessions. The parties shall contact the counselor's office within 7 days of the date of the conciliation conference to schedule the initial sessions under this provision. 2. The parties shall make arrangements for the Child to participate in counseling with a professional selected as follows: The Father shall contact the Child's existing counselor, Lee Murand, to schedule an appointment to explore the possibility of expanding the Child's nutritional counseling to include general issues involving family conflicts or other issues of concern to the Child. The Father shall contact Lee Murand's office within 7 days of the date of the conciliation conference to schedule the appointment. In the event the Father does not desire to expand the Child's existing counseling with Lee Murand following the appointment, the Father shall notify his counsel of the decision, and, within 7 days of that time, the parties shall contact Stanley Schneider's office to make an appointment for the Child with a counselor specializing in working with Children. The parties shall follow the recommendations of the Child's counselor with regard to the frequency, duration and number of sessions for the Child and involvement of any other individual's with the Child's counseling. The parties shall equally share any costs of counseling for the Child which are not covered by insurance and each party shall be responsible to pay for any uncovered individual sessions with the Child's counselor as requested by the counselor. 3. Within six months of the date of this Order, counsel for either party may contact the conciliator to schedule a follow-up custody conciliation conference, if necessary. BY COURT, Edward E. Guido J. cc: /ter J. Russo, Esquire - Counsel for Father Aary L. Kelley, Esquire - Counsel for Mother J . r ? gp i 7 IC) /j d I-Al CHRISTOPHER L. PLITT Plaintiff vs. ANNA J. PLITT Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-987 CIVIL ACTION LAW 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 Zachary L. Plitt December 14, 1994 Mother/Father 2. A conciliation conference was held on November 15, 2006, with the following individuals in attendance: The Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire and Elizabeth Saylor, Esquire, and the Mother, Anna J. Plitt, with her counsel, Gary L. Kelley, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator Anna J. Traino : IN THE COURT OF COMMON PLEAS OF Defendant : CUMBERLAND COUNTY, PENNSYLVANIA V. : 04-987 CIVIL ACTION LAW Christopher L. Plitt IN Plaintiff TO THE HONORABLE, THE JUUDGES OF SAID COURT AND NOW, comes the Defendant, Anna.f. Traino, files this Petition to Modify the current Court Order and in support thereof respectfully avers as follows: PETITION TO MODIFY 1. Plaintiff Christopher L. Plitt who resides at 6216 Stanford Court, Mechanicsburg, Pennsylvania 17050. 2. Defendant is Anna J. Traino who resides at 88 Margaret Drive, Mechanicsburg, Pennsylvania 17050. 3. The parties are the parents of one (1) minor child, Zachary L. Plitt, date of birth December 14, 1994. 4. Pursuant to an Order dated September 6, 2005, the parties share legal custody, alternate holidays, and share physical custody of the child in accordance with the Order. 5. Plaintiff has recently begun a practice of requiring Defendant to travel to Gettysburg, Pennsylvania on the occasions that she is receiving custody. This represents a 60.8 mile roundtrip. Wherefore, the Defendant respectfully requests that this Honorable Court modify the Order to specify in section 10 that custodial parent should have the child available for pickup at his or her residence unless an alternate location is mutually agreed upon. Respectfully submitted, Anna I Trdino 88 Margaret Drive Mechanicsburg, PA 17050 (717) 418.2876 Defendant A Directions to GETTTYSBURG, PA Page 1 of 2 Directions to GETTYSBURG, PA 'yAl-100t LOCAL Summary and Notes ............................................................................................................................................. ..._....._..._.........................__ ............ ..... START 88 Margaret Dr, MECHANICSBURG, Add your notes here... PA FINISH [100-199] Sandoe Rd, GETTYSBURG, PA Total Distance: 30.4 miles, Total Time: 38 mina (approx.) > _ ....................... .......... ... ................ ............. _.._...... ............................ .......................................................................................................................................... Distance ................................................................... . 88 MARGARET DR, MECHANICSBURG, PA ..... ................................................................ 1. Start at 88 MARGARET DR, MECHANICSBURG going toward go < 0.1 mi LUCIE ST 2• Turn on LUCIE ST go < 0.1 mi 3. Turn on SKYLINE DR go 0.3 mi 4. Turn ! on RICH VALLEY RD go 0.4 mi on CARLISLE PIKE(US-11) 5 Turn 0 go 0.1 mi 6 Turn on WOODS DR go 1.2 mi 7. Turn eon HOGESTOWN RD(PA-114) go 1.6 mi 8. Continue to follow PA-114 go 3.5 mi 9• Turn 0 to take ramp onto US-15 S toward GETTYSBURG go 22.9 mi 10. Take the HUNTERSTOWN exit go 0.2 mi 11. Turn a on SHRIVERS CORNER RD(US-15-13R) go < 0.1 mi 12. Turn 0 on SANDOE RD go < 0.1 mi 13. Arrive at [100-199] SANDOE RD, GETTYSBURG [100-199] SANDOE RD, GETTYSBURG, PA ..... Distance: 30.4miles, Time: 38 mins http://xmll.maps.yahoo.com/prnt.php?v3=0&mvt=m&q2=Sandoe%20P,oad,%20Gettysbur... 6/29/2007 NatiRV%'TOI tl3A Page 2 of 2 When using any driving directions or map, it's a good idea to do a reality check and make sure the road still exists, watch out for construction, and follow all traffic safety precautions. This is only to be used as an aid in planning. .............. ................ ............... httd://xmII.maps.yahoo.com/prnt.php?v3=0&mvt=m&q2=Sandoe%2ORoad,%206ettysbur... 6/29/2007 Directions to GETTYSBURG, PA Message Thomas Traino From: Thomas Traino [irishtvtjr@comcast.net] on behalf of Anna J. Traino Sent: Thursday, June 28, 2007 6:31 PM To: 'Chris Plitt'; 'Clplitt@aol.com' Cc: 'Peter Russo' Subject: RE: Summer Schedule change just to clear things up for you Please know that Zack is old enough to be responsible for his things (our co-parenting Page 1 of ? counselors tried to make this abundantly clear to you). I buy Zack clothes and they end up destroyed at your place or scattered all over your family's and I never see them again. You have some clothes that are recently brand new that Zack only wore once. They have been with you for over a month and not returned to me. The problem with the clothes ending up in your possession occurs during the sporting seasons when I pack Zack a new set of clothes for the next day and you keep it - this is why you end up with most of his clothes & I have no idea how / why you pretend that you have none. At your request I have given you all the clothes I have of 'yours' - I expect the same courtesy. Also , I want the entire Baseball uniform - I paid for all of it . YOU unilaterally made the choice to have Zack stay in Gettysburg. There are tons of other options for him. Both you and your attorney have always made it abundantly clear how much flexibility you have in your schedule. If that is in fact the truth than you should have no problem having Zack at your apartment on my scheduled pick-up days @ 4:30p. m. To quote you: " If I am not mistaken, I will only have to go to Gettysburg one time one week and two times the next week..." -- if this isn't that much to you than there really is no problem for your Parents to have to bring him to your apartment. Additionally: You are not "accommodating" or "making adjustments" for anyone's schedule other than the Court Order . It is YOUR responsibility to have Zachary at your apartment for pickups at the appointed time - would you like for me to have you pick him up at his Grandmother's in Harrisburg on the days I am working and he is with her? (I run all the way over there to get him in the spirit of co-operation so that you can pick him up locally.) . I "suddenly" cannot provide free daycare during your custody times as I have done in the past because of your irresponsibility in terms of financial support (like dropping health insurance, not paying for half of all other costs, etc.) You must realize this, don't you? Wasn't that you and your attorney scoffing at the value of this convenience you've enjoyed 6/29/2007 A. Message at m expense for so long? -----Original Message----- From: Chris Plitt [mailto:cplitt@chelseasettlement.com] Sent: Wednesday, June 27, 2007 1:46 PM To: Anna J. Traino Cc: Thomas Traino; clplitt@aol.com Subject: RE: Summer Schedule change I have been in a training seminar in Lancaster and just got into the office. Page 2 of 3 First let me address the issue of sending Zachary out in his underwear. You HAVE clothes to put on him and you should do so. Sending him out to my vehicle in his underwear is uncalled for, is humiliating and embarrassing to Zachary and in my opinion borders on emotional abuse. His clothes are his clothes and he should be able to wear them, and decide what he wants to wear.... Please don't do that to him again. Second, as far as the summer schedule goes, I will not be making any adjustments to it. You will be able to pick Zachary up in Gettysburg at 4:30. I'm not sure how you expect me to have him at my house at 4:30 when you know I work until 5:00. 1 made adjustments to the schedule based on your availability, short notice and no reasoning of changing the schedule and with no discussion with me about the changes. I am sorry that Zachary's grandparents cannot be running Zachary up here to Mechanicsburg. If I am not mistaking you will only have to go to Gettysburg one time one week and two times the next week. On a side note, how is it that you sat in the Domestics meeting and said how you have to care for him in the summer and not even a week after the meeting you all of a sudden can't watch him? As far as you keeping Zachary on Thursday during the day, that will be fine. I will pick Zachary up at your house on Friday @ 5:30. Christopher Plitt Post Closing/ Recording Dept. Chelsea Settlement Services Phone: 717-731-9700 Fax: 717-731-7282 -----Original Message----- From: Anna J. Traino [mailto:ajgregor@comcast.net] Sent: Tuesday, June 26, 2007 7:41 PM To: Chris Plitt Cc: Peter Russo Subject: RE: Summer Schedule change I am not in agreement with the commute I have to make to get Zack. As stated before and keeping with the status quo thus far I will pick Zack up at your apartment A/29/2nn7 -Message Page 3 of 3 on the days I am receiving custody which is 4:30 p.m. Tomorrow (6.27.07) I will be at your apartment at 4:30 p.m. to pick him up. Also, I will be keeping him on Thursday and you may pick him up on Friday at my home at 5:30 p.m. Please get back to me no later than tomorrow by 12:00 p.m. if you are unwilling to have Zack at your apartment tomorrow by 4:30 p.m. -----Original Message----- From: Chris Plitt [mailto:cplitt@chelseasettlement.com] Sent: Tuesday, June 19, 2007 10:51 AM To: ajgregor@comcast.net; Thomas Traino Cc: Peter Russo Subject: Summer Schedule change Anna, I don't think it was very considerate of you to give such short notice on changing the schedule. Letting me know a 10:00 pm on Sunday night that you were not going to be watching Zachary that Monday morning and Thursdays is not making an effort to work together. Please next time give me more notice or at least comunicate with me verbally. As far as you changing the summer schedule: I have made the adjustments to accomodate you as follows: I will pick Zachary up Tuesdays as stated in the Court Order. Every Wednesday Zachary will be at his grandparents. Every Thursday until 4:30 Zachary will be at his grandparents. Every Monday following the weekend Zachary is with me, he will be at his grandparents. NOTE: I AM NOT CHANGING ANY OF MY SCHEDULED TIME WITH ZACHARY STATED IN THE COURT ORDER. I AM ONLY MAKING SURE ZACHARY HAS CARE FOR THE TIME HE IS SCHEDULED TO BE WITH ME ACCORDING TO THE COURT ORDER. That being said, you will be able to pick Zachary up on the Mondays following my weekends and every Thursday at 4:30 in Gettysburg. Since it is preferred that you do not come on to their property, you can meet them at the exchange place that was used before. The Texaco stop at the end of the exit. As far as the exchange next Wednesday, You can pick Zachary up in Gettysburg Wednesday at 4:30. 1 will pick Zachary up Thursday morning at 8:00 am at your house. Thursday you will pick Zachary up at 4:30 in Gettysburg at the Texaco stop. If you have any questions, feel free to contact me. Christopher Plitt Post Closing/ Recording bept. Chelsea Settlement Services Phone: 717-731-9700 Fax: 717-731-7282 6/29/2007 Message Thomas Traino Page 1 of 1 From: Thomas Traino [irishtvtjr@comcast.net] on behalf of ajgregor@comcast.net Sent: Sunday, June 17, 2007 9:57 PM To: Chris Plitt (CPlitt@chelseasettlement.com); 'Clplitt@aol.com' Cc: 'Peter Russo' Subject: Summer Schedule Beginning this week (Monday 6/18/2007); For weekends that you have custody, I will pick Zack up at your house 4:30 pm Monday evening and Thursday evening at 4:30 pm. Alternating weeks when I have weekend custody, I will pick Zack up at your house Thursday evening at 4:30 pm. Anna J. Traino 6/29/2007 iV n d h? V F?- CIA _ Y d m fi { f N v ?u t? V ?N ay? AW ANNA J. TRAINO -PEjkFN+WF- be4?j i V. CHRISTOPHER L. PLITT 1014i'l+. -Ft-" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-987 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, July 05, 2007 , 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 1705-5--.--. on Tuesday, August 07, 2007 at 12:00 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. 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 -7 1 ? ?"?' L U ;C WJ 6- Mr LUZ ?t?lUtiUita vHI J0 1 t 4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION ANNA J. TRIANO Plaintiff VS. CHRISTOPHER L. PLITT Defendant DOCKET NUMBER 00237 S 2007 PACES NUMBER 635109064 Other State ID Number PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1930.5(b) AND NOW, COMES, Defendant, Christopher L. Plitt by and through his counsel, Law Offices of Peter J. Russo, P.C. and avers the following in support of his Petition: 1. Christopher L. Plitt is an adult individual and the father of Zachary L. Plitt, born December 14, 1994 2. Anna J. Triano is an adult individual and the mother of Zachary L. Plitt, born December 14, 1994. 3. Plaintiff filed an action for child support on March 30, 2007. 4. A Support Conference was held in the Cumberland County Domestic Relations Office on 6/12/2007 before Amy Ickes. 5. During the Support Conference several issues were raised, to wit: a. Plaintiff's earning capacity b. Plaintiff's inability to obtain full time employment. 6. Notwithstanding the issues raised at the Support Conference, the parties were able to come to a private agreement as to the obligation contained in the Support Order. 7. On June 29, 2007, Plaintiff appealed the private agreement of the parties and seeks a hearing de novo. 8. As a result of Plaintiffs desire for a hearing de novo, the issues raised relating to Plaintiffs earning capacity and ability to obtain full time employment are again salient to the determination of a support obligation. 9. Plaintiffs last employment position was a full time position earning approximately $16.32 per hour with a subsidiary of Gannett Fleming. 10. It is Defendant's belief that Plaintiff voluntarily quit that position for personal reasons and should therefore be imputed an earning capacity equal to the last full time position she held with Gannett Fleming's subsidiary. 11. Plaintiffs position has been that the company was sold and there were no opportunities for her to be assimilated into the parent company, Gannett Fleming. 12. Plaintiff has also asserted that she is unable to work on a full time basis as a result of a recommendation written by Dr. Arnold Shienvold following a custody evaluation. 13. Defendant is entitled to conduct discovery prior to the de novo hearing so that Defendant may be prepared to address and rebut the assertions of Plaintiff. . [t . 14. Defendant has no manner in which to obtain personnel records from Gannett Fleming or depose a corporate designee of Gannett Fleming without formal discovery. 15. Defendant has no manner in which to depose Dr. Arnold Shienvold without formal discovery. 16. Pursuant to Pa.R.C.P. 1930.5(b), it is the request of the Defendant that this matter be deemed complex and is entitled to the opportunity to conduct discovery pursuant to Pa.R.C.P. 4001 et seq. 17. Counsel for Defendant has requested the concurrence of Plaintiffs counsel and Plaintiff's counsel declined the opportunity to concur. WHEREFORE, upon the averments contained in this Petition, Petitioner respectfully requests this Honorable Court to deem this matter a complex support matter pursuant to Pa.R.C.P. 1930.5(b) and enter an Order of Court permitting Plaintiff to conduct discovery pursuant to Pa. R.C.P. 4001 et seq. Re II , Peter J. Russo, Es Attorney I.D. No. 72897 Attorney for Defendant 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 at, b VERIFICATION I, Christopher L. Plitt, verify that the statements made in this Petition for Special Relief are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to Date: 7-50-07 falsification to authorities. , . • , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION ANNA J. TRIANO Plaintiff . VS. - CHRISTOPHER L. PLITT Defendant DOCKET NUMBER 00237 S 2007 PACES NUMBER 635109064 Other State ID Number CERTIFICATE OF SERVICE I, Ashley Sipe, hereby certify that I am on this day serving a copy of the foregoing Petition for Special Relief Pursuant to Rule 1930.5 (b) upon the person and in the manner indicated below: Certified Mail, Restricted Delivery, Return Receipt Requested, and addressed as follows: Laguna Reyes Maloney, LLP Laura C. Reyes Maloney 1119 North Front Street Harrisburg, PA 17102 Date: -A*?n (h0Q, t F - 4a. '- ipe, Paral al Ashley 7'L- Q Q W U Ob 'D C? a 0 C o -rt "! 1 F f l - ?' _ - s CHRISTOPHER L. PLITT Plaintiff VS. ANNA J. TRAINO Defendant AUG 1320D7V? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-987 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 174 day of kw? - , 2007, upon consideration of the attached Custody Conciliation Repot , it is ordered and directed as follows: 1. The prior Order of this Court dated September 6, 2005, shall continue in effect as modified by this Order. 2. The parties shall participate in a course of co-parenting counseling at Interworks. The purpose of the counseling shall be to assist the parties in establishing sufficient communication and cooperation to enable them to effectively co-parent their Child. Each parent shall contact Interworks within 10 days of the custody conciliation conference to schedule the first session. Both parties shall cooperate in scheduling all sessions in a timely manner. The parties shall follow the recommendations of the counselor with regard to the duration and frequency of the co-parenting counseling and neither party shall unilaterally terminate the counseling process. 3. The parties shall arrange for the Child's continued participation in counseling. The parties shall request guidance from the Child's counselor and the co-parenting counselor relating to parenting issues and arrangements focusing on meeting the Child's needs during the school year. The parties shall sign any authorizations deemed necessary by either the Child's counselor or the co-parenting counselor to enable both professionals to share information and collaborate in an effort to provide the requested guidance to the parents with regard to the Child's needs. The parties agree to comply with any short term or ongoing recommendations of the counselors with regard to the parenting schedule. 4. The Child's legal name, Zachary Plitt, shall be used on all documents and records concerning the Child including, but not limited to, all school and activity records and paperwork. The Child's name shall not be hyphenated to include the surname of the Mother's husband unless expressly agreed between the parties. k1K jN' !. '? j,,) 1 F•! vc L I z uut- JLI S. 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 mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: Peter J. Russo, Esquire - Counsel for Father Roger Laguna, Esquire - Counsel for Mother BY THE C T, Edward E. Guido J. ll_ rAU6 132007A CHRISTOPHER L. PLITT Plaintiff vs. ANNA J. TRAINO Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-987 CIVIL ACTION LAW 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 Zachary L. Plitt December 14, 1994 Mother/Father 2. A custody conciliation conference was held on August 7, 2007, with the following individuals in attendance: the Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire and Elizabeth Saylor, Esquire, and the Mother, Anna J. Traino (formerly Plitt), with her counsel, Roger Laguna, Esquire. 3. The parties agreed to entry of an Order in the form as attached J vGc?? ?-- o?lJ-7 Date Dawn S. Sunday, Esquire Custody Conciliator LAGUNA REYES MALONEY, LLP I I 1 9 NORTH FRONT STREET, HARRISBURG, PA 1 7 1 02 TEL.: (71 7) 233-5292 / FAX: (7 1 7) 233-5394 LRMQ' STANFORDALUMNI.0RG ATTORNEYS FOR PETITIONER ANNA J. TRAINO CHRISTOPHER L. PLITT, § IN THE COURT OF COMMON PLEAS OF § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO.: 2004-987 § CIVIL ACTION - CUSTODY ANNA J. TRAINO § (FORMERLY ANNA J. PLITT), § PETITION FOR A PROMPT HEARING TO CONSIDER THE PRIMARY CUSTODIAN'S REQUEST TO RELOCATE WITH THE SUBJECT CHILD AND NOW, comes the Defendant in the above-captioned matter, and the Petitioner of the instant Petition, Anna J. Traino, by and through her attorney, Laguna Reyes Maloney, LLP, and represents as follows: 1. The Custody of the subject child is governed by Order of Court dated September 6, 2005 (Attached as Exhibit A) and by subsequent Order dated April 27, 2006 (Attached as Exhibit B). 2. Paragraph 5 of the above-referenced Order dated September 6, 2005 states that a party must provide advance notice if he/she intends to move more than 100 miles from the other party, and provide the address and telephone number of the new residence. 3. Petitioner ("Mother") has been the primary custodian and caretaker of the Child from birth until present. 4. Mother has advised Christopher L. Plitt, the Respondent, that she intends to move to Connecticut with the Child and her husband (hired at a new job) because it is in the best interest of the family and Child that she do so in order keep the family intact. 5. The Child's counselor/therapist offered the opinion that, all things considered, it is in the Child's best interest to remain in custody of Mother despite the move. 6. The Mother advised the Respondent of the above circumstances, however, he allegedly indicated that he would not permit the move unless it was court ordered. 7. The current Order does not prohibit a move such as the one contemplated by Mother, however, due to the contentious past litigation of the underlying custody matter, Mother has indicated that she will remain in the Commonwealth until the Court hears this matter while her husband travels ahead to Connecticut. 8. Petitioner respectfully requests that a hearing of this matter be expedited to minimize the hardship that will be caused by the split pending a decision. WHEREFORE, Defendant/Petitioner respectfully requests that this Honorable Court schedule a prompt hearing in order to address the relocation relief is found to be in the best interest of'gie subject minor thereafter, to grant whatever tted, Supreme Court I.D. go.: 75900 Attorney for Defendant/Petitioner LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 CHRISTOPHER L.. PLITT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 04-987 CIVIL ACTION LAW ANNA J. PLITT Defendant IN CUSTODY ORDER OF COURT AND NOW, this (0 day of 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court are vacated and replaced with this Order. 2. The Father, Christopher L. Plitt, and the Mother, Anna J. Plitt, shall have shared legal custody of Zachary L. Plitt, bom December 14, 1994. Each parent shall have an equal right, to be exercised jointly with the other parent, 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 this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and .information. Each party shall notify the other of any emergencies involving the Child which arise during that party's period of custody. The custodial parent shall provide all school papers and information concerning school and extracurricular activities for the_Child to the other parent within two days of receipt. The parties shall consult with each other in enrolling the Child in any sports or other activities and enrollment in such activities shall require the signatures of both parties on the appropriate forms unless one party provides written consent to the other parent to complete the signup procedures. Each party shall notify the other party in writing of an impending sign-up for an activity 72 hours in advance and that party shall respond within 24 hours of notification. In order to ensure the sharing of all information pertaining to the Child, the parties shall notify each other'y e-mail every Sunday evening of all appointments, activities, enrollments or any other significant developments concerning the Child. The parties acknowledge that strict compliance with this requirement is essential to a continued sharing of legal custody. Counsel for either party may contact the conciliator to schedule an additional custody conciliation conference if necessary-to address the inability or unwillingness of either party to strictly comply with this notice requirement. The parties agree to consult with each other before placing the Child in the care of unrelated third parties for extended activities during which the custodial parent will not be present. EXHIBIT A the holiday in odd numbered years and the Father shall have custody in even numbered years. G. Easter: In every year, the Father shall have custody of the Child on Easter Sunday from 9:00 a.m. until 3:00 p.m. and the Mother shall have custody fiom 3:00 p.m. until 9:00 P.M. H. Mother's Day/Father's Day: In every year, the Mother shall have custody of the Child over the Mother's Day weekend from Sunday at 9:00 a.m. through Monday at 9:00 a.m., and the Father shall have custody of the Child over the Father's Day weekend from Sunday at 9:00 a.m. through Monday at 9:00 a.m. 1. Parents' Birthdays: The Mother shall have custody of the Child on her birthday (December 4) and the Father shall have custody of the Child on his birthday (November 20) from 9:00 a.m. until 9:00 p.m. J. Child's Birthday: In every year, the Father shall have custody of the Child from December 13 at 3:00 p.m. through December 14 at 3:00 p.m., and the Mother shall have custody from December 14 at 3:00. p.m. through December 15 at 3:00 p.m. K. The holiday schedule shall supercede and take precedence over the regular custody schedule. 5. In the event either party intends to remove the Child from the Commonwealth of Pennsylvania or more than 100 miles from that party's residence, that party shall provide advance notice to the other party of the address and telephone number where the Child can be contacted. 6. The custodial parent shall ensure that the Child returns all telephone calls to the non- custodial parent within 24 hours. 7.. Each party shall be entitled to have custody of the Child during the summer school break each year for two non-consecutive weeks upon providing at least 30 days advance notice to the other party. Each party shall schedule his or her periods of vacation custody under this provision to include his or her regular weekend periods of custody. A party providing notice first under this provision shall be entitled to preference on his or her selection of vacation dates. In 2005, the Mother shall have custody of the Child for vacation from August 23 through August 30. As the parties-acknowledge this period of vacation custody falls over the Father's regular alternating weekend, the Father shall have make-up periods of custody with the Child on August 15, 2005 and from September 8, 2005 at 4:30 p.m. through his regular alternating weekend period of custody ending on Monday, September 12 before school. If the Father obtains an excused absence from the Child's school the Father may keep the Child out of school on Friday, September 9, to travel to a family wedding. ? S. The parties shall obtain counseling for th-& Child with a child psychologist as recorn-mended by Dr. Shienvold. The parties shall select the professional by agreement, with the assistance of Dr. Shienvold, if appropriate. The parties shall select a child psychologist under this provision whose services will be covered by the Father's insurance, unless the parties agree to equally share the costs of the sessions. 9. The parties shall participate in a minimum of two mediation sessions With Deborah Salem, LPC to address difficulties in communication: For ilre two initial sessions, the parties. shall equdlly share all costs. Thereafter, payment of the costs shall be as arranged by agreement between the parties. 10. The party receiving custody shall be responsible to provide transportation for the exchange of custody unless otherwise.agreed. 11. Neither party 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.: Both parties shall ensure that third parties having contact with the Child comply with this provision. 12. The parties may modify the provisions of this Order by written mutual consent only. In the absence of mutual written consent, the terrns of this Order shall control. BY TCOURT, CHRISTOPHER L. PLITT, Plaintiff V. ANNA J. GREGOR (PLITT), Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-987 CIVIL ACTION -CUSTODY ORDER OF COURT AND NOW, 2006, upon agreement of the parties, it is hereby ORDERED and DECREED that the Petition For Emergency Relief filed By Defendant is resolved and the hearing scheduled for Thursday, April 27, 2006 at 9:00 AM is cancelled. It is further ORDERED and DECREED that by agreement of the parties Defendant shall have custody of the minor child, Zachary, from Friday, May 5, 2006 after school through Monday, May 8, 2006. In exchange, Plaintiff shall have custody of the minor child, Zachary, from Friday, July 21, 2006 through Monday, July 24, 2006 at 4:30 PM. The parties are aware that Plaintiff will be exercising his vacation for the week of July 14, 2006 through July 21, 2006 in conjunction with the above modification. All other aspects of the Court's Order dated September 6, 2005 shall remain in full force and effect. BY T-HE E V R. T: Edward E. Guido, JUDGE EXHIBIT B' LAGUNA REYES MALONEY, LLP 1 1 19 NORTH FRONT STREET, HARRISBURG, PA 1 7 1 02 TEL.: (7 1 7) 233-5292 / FAx: (7 1 7) 233-5394 LRMgA STANFORDALUMNI.ORG ATTORNEYS FOR PETITIONER ANNA J. TRAINO CHRISTOPHER L. PLITT, § IN THE COURT OF COMMON PLEAS OF § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO.: 2004-987 § CIVIL ACTION - CUSTODY ANNA J. TRAINO § (FORMERLY ANNA J. PLITT), § CERTIFICATE OF SERVICE I hereby certify that I served a copy of the Petition for a Prompt Hearing to Consider the Primary Custodian's Request to Relocate with the Subject Child filed in the above- captioned case upon counsel for Plaintiff/Respondent, by first-class U.S. mail, addressed to: D at Peter J. Russo, Esquire 3800 Market St. Camp Hill, PA 17011 ?? 33 AA- F e ?-- ll O (7 U1 xy ao 9 ? CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ANNA J. TRAINO DEFENDANT 2004-0987 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, February 01, 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, March 04, 2008 at 9:00 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/ Dawn S. Sunday, Esq. Custody Conciliator i 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 7 /?5 ` * 5o . %- r a.:-rw ker f -t;w? e -Sa_-7 'z° ,5(,- d7 , r I Z .ZI Wj 9-- 933 80DZ ?ldUi?1l ;cd 3Hi ?0 MAR 0 3 2008 CHRISTOPHER L. PLITT Plaintiff vs. ANNA J. TRAINO Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2004-0987 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ? day of /K 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall obtain written guidance from the Child's counselor, Lee Morand, as to the primary custodial arrangement during the school year which will best meet the Child's needs in light of the Mother's upcoming relocation to Connecticut. The counselor's guidance shall be based on her past counseling history with the Child, ongoing counseling sessions with the Child, and any other sources deemed necessary by the counselor. 2. Within ninety (90) days of the date of this Order, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary. BY T OURT, cc:/ Peter J. Russo, Esquire - Counsel for Father /Roger R. Laguna, Esquire - Counsel for Mother Edward E. Guido J. 3 ?1?111?tA?l! 8 Z :1 ! WV 9- HVW BOBZ AtNiG G- 41016d 3Hi 3GI' G- w CHRISTOPHER L. PLITT Plaintiff VS. ANNA J. TRAINO Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2004-0987 CIVIL ACTION LAW 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 Zachary L. Plitt December 14, 1994 Mother/Father 2. A custody conciliation conference was held on February 28, 2008, with the following individuals in attendance: the Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire, and the Mother, Anna J. Traino, with her counsel, Roger R. Laguna, Esquire. 3. The parties agreed to'entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator APR 1 42008,01 CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2004-0987 CIVIL ACTION LAW ANNA J. TRAINO Defendant IN CUSTODY ORDER OF COURT AND NOW, this I G' day of AOU-1 , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court are vacated and replaced with this Order. 2. The Father, Christopher L. Plitt, and the Mother, Anna J. Traino, shall have shared legal custody of Zachary L. Plitt, born December 14, 1994. 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. 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. Neither party shall administer prescribed medications to the Child, other than routine antibiotics, without the consent of the other parent. 3. The Mother shall be permitted to relocate with the Child to Connecticut, effective Tuesday, April 8, 2008, subject to the Father's periods of partial custody set forth in this Order. 4. The parties shall have physical custody of the Child in accordance with the following schedule: A. SCHOOL YEAR: During the school year, the Mother shall have primary physical custody of the Child. The Father shall have partial physical of the Child for one (1) weekend each month, when the Father does not have an extended holiday period of custody during the same month. J The Father shall travel to Connecticut for the weekend periods of custody and shall provide at least seven (7) days advance notice to the Mother. The Father may select extended weekends when the Child does not have school on either the Friday or Monday adjacent to the weekend. B. SUMMER SCHOOL BREAK: During the summer school break, the Father shall have primary physical custody of the Child. The Mother shall have partial physical custody of the Child at such times when the Mother travels to Pennsylvania. The Mother's periods of custody under this provision shall take place during the Father's work hours. The Mother shall provide at least seven (7) days advance notice to the Father of periods of custody under this provision, which shall be scheduled to accommodate previously scheduled activities for the Child. C. The summer custody schedule shall begin on the first Saturday after the last day of school. The school year custody schedule shall begin on the Saturday preceding the first day of school. 5. The parties shall share or alternate having custody of the Child on holidays/school breaks as follows: A. CHRISTMAS/NEW YEAR'S: In even-numbered years, the Father shall have custody of the Child from the day after school ends before the holiday through December 30 and the Mother shall have custody of the Child for the remainder of the Christmas/New Year's school break. In odd-numbered years, the Mother shall have custody of the Child from the beginning of the Christmas break through December 27 and the Father shall have custody from December 27 through the day before school resumes after the holiday. B. THANKSGIVING: In even-numbered years, the Mother shall have custody of the Child for the entire Thanksgiving break. In odd-numbered years, the Father shall have custody of the Child from the day before Thanksgiving through the Sunday after Thanksgiving. C. FEBRUARY RECESS/SPRING RECESS: The Father shall have custody of the Child during his February recess and spring recess from school from Saturday through Saturday. 6. The Mother shall be entitled to have custody of the Child for one (1) full week during the summer school break each year upon providing at least thirty (30) days advance notice to the Father. In 2008, the Mother's vacation shall be scheduled during the last week before the Labor Day weekend, which shall conclude the summer school break custody schedule. The Mother's vacation period shall run from Saturday through the Saturday before Labor Day, unless otherwise agreed between the parties. 7. The parties shall make arrangements for the Child to travel by train between the parties' residences for exchanges of custody, for which the Mother shall pay the costs. In the event the Father elects to drive to Connecticut to pick up the Child at the beginning of a period of custody and/or elects to drive to Connecticut to return the Child following a period of custody, the Mother shall pay the costs of either the round trip or the one-way trip ticket, whichever applies, directly to the Father within ten (10) days of the Father's provision of transportation. In the event the parties arrange to meet at a halfway point for an exchange of custody, unless otherwise agreed, the parties shall use the location equidistant from each party's residence as determined by MapQuest. 8. The parties shall continue to abide by the recommendations of the Child's counselor with regard to continued counseling while in the custody of either parent. 9. The non-custodial parent shall be entitled to have reasonable telephone contact with the Child 10. The parties shall communicate directly with each other concerning issues affecting the Child. Each party shall accept telephone calls from the other party and shall return telephone calls promptly if requested. 11. The parties shall keep each other informed concerning all developments concerning the Child. The Mother shall provide the Father with all school contact information necessary to enable the Father to maintain contact with the Child's teachers and other school personnel. 12. When designating the Child's name on school, medical or any other documentation or for any other purpose, the parties shall designate the Child's surname as it appears on his Birth Certificate. 13. The Father's consent to the Mother's relocation of the Child to Connecticut shall be without prejudice as to any other move by the Mother to a different location, which shall be considered a separate request for relocation requiring approval of the Court or agreement of the parties. 14. Jurisdiction over this custody matter shall remain in this Court. 15. Neither party 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. Both parties shall ensure that third parties having contact with the Child comply with this provision. 16. 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 mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY-ITIE COURT, Edward E. Guido J. cc: "?'eter J. Russo, Esquire - Counsel for Father 'Roger R. Laguna, Esquire - Counsel for Mother 0-6 P i'FS /' z.-,, L -y/?L fog lE.;s? .. ?f no z 0 •1111,11 91 M Ron CHRISTOPHER L. PLITT Plaintiff vs. ANNA J. TRAINO Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 2004-0987 CIVIL ACTION LAW 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 Zachary L. Plitt December 14, 1994 Mother/Father 2. A custody conciliation conference was held on April 4, 2008, with the following individuals in attendance: the Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire, and the Mother, Anna J. Traino, with her counsel, Roger R. Laguna, Esquire. 3. The parties agreed to entry of an Order in the form as attached permitting the Mother to relocate with the Child to Connecticut and providing for school year and summer school break custody arrangements. q Date Dawn S. Sunday, Esquire Custody Conciliator CHRISTOPHER L. PLITT, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2004-987 ANNA J. PLITT, CIVIL ACTION - LAW Defendant/Respondent CUSTODY EDWARD E. GUIDO, JUDGE PETITION FOR CUSTODY MODIFICATION OF MINOR CHILDREN AND NOW, COMES, the Plaintiff, CHRISTOPHER L. PLITT, by and through his attorney, Peter J. Russo, Esquire, and respectfully submits the following in support of Plaintiffs Petition for Special Relief Seeking Custody Modification: 1. The Petitioner and Respondent have shared legal custody of the subject minor child pursuant to an Order of this Court dated April 16, 2008. A true and correct copy of said order is attached as Exhibit "A." 2. Pursuant to the above Order, specifically Paragraph 9,-the non-custodial parent was to be entitled to reasonable telephone contact with the Child. 3. Petitioner has not spoken to. the Child for. approximately two weeks. 4. Petitioner and Respondent have not been able to come to an agreement regarding establishing a more reliable telephone schedule so that Petitioner can be insured regular telephone contact with his son. 5. Petitioner requests that a telephone schedule be created and incorporated into an Order of Court including Respondent being responsible for insuring that the telephone called are placed and/or received by the Child. 6. Petitioner has been advised that prior counsel, Roger Laguna, no longer presents Respondent and based on the inability of the parties to resolve the issues to date, Petitioner believes that Respondent does not concur with the relief requested in this Petition. 7. The Honorable Judge Kevin A. Hess and the Honorable Judge Edward E. Guido have entered previous Orders in this' matter as follows: a) April 27, 2004 Judge Edward E. Guido Custody Order b) June 28, 2004 Judge Edward E. Guido Custody Order c) October 11, 2004 Judge Edward E. Guido Custody Order d) August 3, 2005 Judge Edward E..Guido Custody Order e) September, 6, 2005 Judge Edward E. Guido Custody Order f) September 22, 2005 Judge Edward E. Guido Order Denying Entry of Divorce g) October 10, 2005 Judge Edward E. Guido h) October 12, 2005 Judge Edward E. Guido i) April 24, 2006 Judge Edward E. Guido j) April 27, 2006 Judge Edward E, Guido k) November 26, 2006 1) March 6, 2008 m) April 16, 2008 Judge Edward E. Guido Judge Edward E. Guido Judge Edward'E. Guido Order Denying Entry of Divorce Order Granting Entry of Divorce Order Granting Emergency Hearing Order Cancelling Emergency Hearing By Agreement of the Parties Custody Order Custody Order Custody Order WHEREFORE, Plaintiff requests this Honorable Court to order that regular telephone contact with the non-custodial shall be established with the custodial parent being responsible for insuring said telephone schedule is maintained. Date: d 2 Res e 1 submitted, Peter J. usso Attorney for Plaintiff PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 prusso@pjrlaw.com (717) 591-1755 CHRISTOPHER L. PLITT, Plaintiff/Petitioner V. ' ANNA J. PLITT, Defendant/Respondent Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-987 CIVIL ACTION - LAW CUSTODY EDWARD E. GUIDO, JUDGE VERIFICATION I, Christopher L. Plitt, verify that the statements made in the foregoing document are true and correct. I understand that false statements' made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification Date: l 117A 0 Y EX?IIBIT A CHRISTOPHER L. PLITT Plaintiff vs. ANNA J. TRAINO Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2004-0987 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AvotJ 2008, upon AND NOW, this 1 ` day of consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court are vacated and replaced with this Order. 2. The Father, Christopher L. Plitt, and the Mother, Anna J. Train, shall have shared legal custody of Zachary L. Plitt, born December 14, 1994. 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. 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. Neither party shall administer prescribed medications to the Child, other than routine antibiotics, without the consent of the other parent. 3. The Mother shall be permitted to relocate with the Child to Connecticut, effective Tuesday, April 8, 2008, subject to the Father's periods of partial custody set forth in this Order. 4. The parties shall have physical custody of the Child in accordance with the following schedule: A. SCHOOL YEAR: During the school year, the Mother shall have primary physical custody of the Child. The Father shall have partial physical of the Child for one (1) weekend each month, when the Father does not have an extended holiday period of custody during the same month. The Father shall travel to Connecticut for the weekend periods of custody and shall provide at least seven (7) days advance notice to the Mother. The Father may select extended weekends when the Child does not have school on either the Friday or Monday adjacent to the weekend. B. SUMMER SCHOOL BREAK: During the summer school break, the Father shall have primary physical custody of the Child. The Mother shall have partial physical custody of the Child at such times when the Mother travels to Pennsylvania. The Mother's periods of custody under this provision shall take place during the Father's work hours. The Mother shall provide at least seven (7) days advance notice to the Father of periods of custody under this provision, which shall be scheduled to accommodate previously scheduled activities for the Child. C. The summer custody schedule shall begin on the first Saturday after the last day of school. The school year custody schedule shall begin on the Saturday preceding the first day of school. 5. The parties shall share or alternate having custody of the Child on holidays/school breaks as follows: A. CHRISTMAS/NEW YEAR'S: In even-numbered years, the Father shall have custody of the Child from the day after school ends before the holiday through December 30 and the Mother shall have custody of the Child for the remainder of the Christmas/New Year's school break. In odd-numbered years, the Mother shall have custody of the Child from the beginning of the Christmas break through December 27 and the Father shall have custody from December 27 through the day before school resumes after the holiday. B. THANKSGIVING: In even-numbered years, the Mother shall have custody of the Child for the entire Thanksgiving break. In odd-numbered years, the Father shall have custody of the Child from the day before Thanksgiving through the Sunday after Thanksgiving. C. FEBRUARY RECESS/SPRING RECESS: The Father shall have custody of the Child during his February recess and spring recess from school from Saturday through Saturday. 6. The Mother shall be entitled to have custody of the Child for one (1) full week during the summer school break each year upon providing at least thirty (30) days advance notice to the Father. In 2008, the Mother's vacation shall be scheduled during the last week before the Labor Day weekend, which shall conclude the summer school break custody schedule. The Mother's vacation period shall run from Saturday through the Saturday before Labor Day, unless otherwise agreed between the parties. 7. The parties shall make arrangements for the Child to travel by train between the parties' residences for exchanges of custody, for which the Mother shall pay the costs. In the event the Father elects to drive to Connecticut to pick up the Child at the beginning of a period of custody and/or elects to drive to Connecticut to return the Child following a period of custody, the Mother shall pay the costs of either the round trip or the one-way trip ticket, whichever applies, directly to the Father within ten (10) days of the Father's provision of transportation. In the event the parties arrange to meet at a halfway point for an exchange of custody, unless otherwise agreed, the parties shall use the location equidistant from each party's residence as determined by MapQuest. 8. The parties shall continue to abide by the recommendations of the Child's counselor with regard to continued counseling while in the custody of either parent. 9. The non-custodial parent shall be entitled to have reasonable telephone contact with the Child 10. The parties shall communicate directly with each other concerning issues affecting the Child. Each party shall accept telephone calls from the other party and shall return telephone calls promptly if requested. 11. The parties shall keep each other informed concerning all developments concerning the Child. The Mother shall provide the Father with all school contact information necessary to enable the Father to maintain contact with the Child's teachers and other school personnel. 12. When designating the Child's name on school, medical or any other documentation or for any other purpose, the parties shall designate the Child's surname as it appears on his Birth Certificate. 13. The Father's consent to the Mother's relocation of the Child to Connecticut shall be without prejudice as to any other move by the Mother to a different location, which shall be considered a separate request for relocation requiring approval of the Court or agreement of the parties. 14. Jurisdiction over this custody matter shall remain in this Court. 15. Neither party 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. Both parties shall ensure that third parties having contact with the Child comply with this provision. 16. 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 mutual consent. In the absence of mutual consent, the terms of this Order shall control. BYWTHE COURT, Edward E. Guido J. cc: Peter J. Russo, Esquire - Counsel for Father Roger R. Laguna, Esquire - Counsel for Mother .y CHRISTOPHER L. PLITT Plaintiff vs. ANNA J. TRAINO Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2004-0987 CIVIL ACTION LAW 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 Zachary L. Plitt December 14, 1994 Mother/Father 2. A custody conciliation conference was held on April 4, 2008, with the following individuals in attendance: the Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire, and the Mother, Anna J. Traino, with her counsel, Roger R. Laguna, Esquire. 3. The parties agreed to entry of an Order in the form as attached permitting the Mother to relocate with the Child to Connecticut and providing for school year and summer school break custody arrangements. Date Dawn S. Sunday, Esquire Custody Conciliator CHRISTOPHER L. PLITT, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO., 2004-987 ANNA J. PLITT, CIVIL ACTION - LAW Defendant CUSTODY : EDWARD E. GUIDO, JUDGE CERTIFICATE -OF SERVICE I, Peter Russo, hereby certify that I am on this day serving a copy of the foregoing documents upon the person (s) and in the manner indicated below; US MAIL via First Class, Postage Pre-Paid addressed as follows: Anna J. Traino 52 Spice Hill Drive East Hampton, CT 06424 Peter . usso Date: 1 I I zok ct Y Yi . CHRISTOPHER L. PLITT, § Plaintiff § V. § ANNA J. TRAINO § (FORMERLY ANNA J. PLITT), § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 2004-987 CIVIL ACTION - CUSTODY PRAECIPE FOR WITHDRAWAL OF APPEARANCE To the Prothonotary: Please withdraw the appearance Maloney, LLP, as counsel for Anna J. Da Laguna, Jr., E uire and Laguna Reyes )efendant in tl* above-captioned case. loge 1. Lagun?r., Esquire Supreme Court I. `No.: 75900 LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of Gary L. Kelley, Esquire as counsel for Anna J. Traino, the Defendant in the above-captioned case. r Dat 14712P L4& G ry . Kelley, Es ire 31 hestnut St. Camp Hill, PA 17011 (717) 612-1485 CY x..,? 4 ?y a -r y _ , __ ?.^, ?. CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ANNA J. PLITT DEFENDANT 2004-987 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, November 26, 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 Monday, December 29, 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/ Dawn S. Sunda Es . 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!' ?? .! i?, ? ? ? - -?, '? ? i r ! ? ? ? ;?y °? .. ., ., is+,1?? ?1G''+T ?, r? MAR 0 2 CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2004-0987 CIVIL ACTION LAW ANNA J. TRAINO Defendant IN CUSTODY ORDER OF COURT AND NOW, this q+4& day of /*A , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated April 16, 2008 shall continue in effect as modified by this Order. 2. The Father shall have reasonable, liberal telephone contact with the Child. The Father shall be entitled to contact the Child at least every Sunday between 7:30 p.m. and 9:00 p.m. The Father shall first try the Child's cell phone and, if he is not able to reach the Child on his cell phone, may contact the Mother on her cell phone. The Mother shall encourage the Child to participate fully in maintaining telephone contact with the Father. In the event the Father is unable to reach the Child on a weekly Sunday telephone call and requests a return call, the Mother shall ensure that the Child returns the Father's telephone call in a timely manner. 3. The parties shall cooperate in establishing a regular means of communication on a weekly basis to share information pertaining to the Child by email or in another manner agreed upon between the parties. The parties shall share all information concerning medical, dental or other appointments for the Child, all contact information for the Child's physicians or other professionals providing any type of care for the Child, including telephone numbers, and any and all information pertaining to the Child's school performance, activities and other developments which would be reasonably expected to be of interest and importance to the other parent. The parent having primary custody at the time shall be responsible to initiate the weekly information sharing contact. 4. At the beginning of the Mother's periods of partial custody during the summer school break, the Mother shall pick up the Child at the Father's residence in the morning at a time to be arranged by agreement between the Mother and the Child. The Father shall pick up the Child after work between 4:30 p.m. and 5:00 p.m. on workdays at the place designated by the Mother at least 24 hours in advance. The Father shall not be required to travel more than 15 miles from his place of employment to pick up the Child. In the event the Mother does not provide the notice required by this provision or changes the location more than 24 hours in advance, the parties shall thereafter exchange custody at 4:30 p.m. at the Father's place of employment. 5. The Father may make arrangements for the Child to participate in counseling during the Father's periods of custody for the purpose of addressing issues which have arisen or may hereafter arise in the relationship between the Father and Son. 6. Unless otherwise agreed between the parties in advance or pursuant to an Order of Court, the Father shall not use a plane, other than a commercial aircraft, to pick up the Child for a period of custody. 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. Edward E. Guido J. cc " t er J. Russo, Esquire - Counsel for Father Gary L. Kelley, Esquire - Counsel for Mother oz ?, L VWA-U3NN3# kLw)+o'? ONY1 Gl -!Iwv 1- 8 AMC1NOHiOdd 3?U ?O .'C? CHRISTOPHER L. PLITT Plaintiff vs. ANNA J. TRAINO Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2004-0987 CIVIL ACTION LAW IN CUSTODY Prior Judge: Edward E. Guido 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 Zachary L. Plitt December 14, 1994 Mother/Father 2. A custody conciliation conference was held on February 24, 2009, with the following individuals in attendance: the Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire, and the Mother's counsel, Gary L. Kelley, Esquire. The Mother, Anna J. Train, participated in the conference by telephone. 3. The parties agreed to entry of an Order in the form as attached with the exception of the transportation arrangements for exchanges of custody during the summer school break, which are the recommendations of the conciliator. a.r.100 q Date Dawn S. Sunday, Esquire Custody Conciliator LAW OFFICES OF PETER J. RUSSO, P.C. BY: PETER J. RUSSO, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com CHRISTOPHER L. PLITT, Plaintiff/Petitioner V. ANNA J. TRAINO, Defendant/Respondent Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-987 CIVIL ACTION - LAW CUSTODY PETITION FOR MODIFICATION OF CUSTODY Petitioner, Christopher L. Plitt, by and through his counsel, The Law Offices of Peter J. Russo, P.C., states the following: 1. The Petitioner and Respondent have shared legal custody of the subject minor child pursuant to an Order of this Court dated April 16, 2008. A true and correct copy of said order is attached as Exhibit "A". 2. Pursuant to the above Order, specifically Paragraph 3a, Father travels to Connecticut as he has partial custody one (1) weekend each month. 3. Father requests that the following language be added to Paragraph 3a of the current Order: Father shall be responsible for all transportation and related costs, and all exchanges of custody shall be at Mother's residence of record 4. Pursuant to the above Order, specifically Paragraph 3b, Father should have Primary physical custody of the Child during the Summer School Break and Mother should have partial physical custody. 5. Father requests that the following language be added to Paragraph 3bi of the current Order: At the beginning of the Mother's periods of partial custody during the summer school break, Mother shall pick up Child at the Father's residence of record in the morning at a time to be arranged by agreement between Mother and Child, but not before 7:30 a.m. Mother shall return Child to Father's residence of record no later than 5:00p.m. that same day. 6. Pursuant to the above Order, specifically Paragraph 3bii, Mother has child for one (1) full week during the summer break each year. 7. Father requests that the following language be added to Paragraph 3bii of the current Order: Mother shall be responsible for all transportation and related costs and all exchanges of custody shall be at Father's residence of record. 8. Father requests that an additional paragraph be added in regards to exchanges, as Mother and Father have not been able to come up with a mutual agreement that is convenient to both parties. 9. Father requests that the following language be added to the current Order: a. For all exchanges of custody set forth under this Agreement, transportation shall be via automobile only unless the parties mutually agree otherwise in writing. b. For all exchanges of custody not otherwise specifically addressed hereunder, the exchange of custody shall be at the residence of record of the parent relinquishing custody and no earlier than 2:00 p.m. and no later than 4:00 p.m. The parent relinquishing custody shall have the Child ready and available at his or her residence of record between 2:00 p.m. and 4:00 p.m. The parent receiving custody shall be responsible for all transportation and related costs. For the purpose of this Agreement, exchange(s) of custody shall be interpreted to mean the time in which the Child physically becomes in the presence of the parent receiving custody. 10. The Honorable Edward E. Guido has entered the previous Order in this matter. 11. Opposing counsel, Gary L. Kelly, has been contacted by phone and mail, but Petitioner's counsel has received his concurrence or non concurrence with the requested modification herein. WHEREFORE, Plaintiff requests this Honorable Court to order that the exchange schedule of the child be established between both parties. ec ubmitted, Peter J. Russo, Esquire Attorney I.D. No. 72897 Elizabeth J. Saylor, Esquire Attorney I.D. No. 20013 Attorneys for Plaintiff 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Date: _? Z'L( 0? Facsimile: (717) 591-1756 i .. VERIFICATION 1, Christopher L. Plitt, verify that the statements made in the forgoing document 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 unswom falsii Dated: ;/- « n . LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: PETER J. RUSSO, Esquire PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com CHRISTOPHER L. PLITT, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2004-987 ANNA J. TRAINO, CIVIL ACTION - LAW Defendant/Respondent CUSTODY CERTIFICATE OF SERVICE I, Ashley R. Sipe, hereby certify that I am on this day serving a copy of the Petition for Modification of Custody upon the person(s) and in the manner indicated below: US Regular Mail addressed as follows: Gary L. Kelly, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Date: Ashley . Sipe, aralegal C)Fh ` ' Y? CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ANNA J. TRAINO DEFENDANT 2004-987 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, July 29, 2009 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 Thursday, September 03, 2009 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/ Dawn S. Sunda Es . 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 OF T-HE 2099 .'' _ 29 PI-I k t¢ A f j SEP 1 12009 CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2004-987 CIVIL ACTION LAW ANNA J. TRAINO Defendant IN CUSTODY ORDER OF COURT AND NOW, this l day of 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court dated April 16, 2008 and March 4, 2009 are vacated and replaced with this Order. 2. The Father, Christopher L. Plitt, and the Mother, Anna J. Traino, shall have shared legal custody of Zachary L. Plitt, born December 14, 1994. 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. 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 parties shall have physical custody of the Child in accordance with the following schedule: A. School Year: During the school year, the Mother shall have primary physical custody of the Child. The Father shall have partial physical custody of the Child for one weekend each month from Friday at 6:00 p.m. through Sunday at 6:00 p.m., when the Father does not have an extended holiday period of custody during the same month. The Father shall travel to Connecticut for the weekend periods of custody and shall provide at least seven (7) days advance notice to the Mother. The Father may select extended weekends when the Child does not have school on either the Friday or Monday adjacent to the weekend, in which case if there is no school on Friday, the beginning of the period of custody would be Thursday at 6:00 p.m. or if there is no school on Monday, the period of custody would end on Monday at 6:00 p.m. B. Summer School Break: During the summer school break, the Father shall have primary physical custody of the Child. The Mother shall have partial physical custody of the Child at such times when the Mother travels to Pennsylvania. The Mother's periods of custody under this provision shall take place during the Father's work hours. The Mother shall provide at least seven (7) days advance notice to the Father of periods of custody under this provision, which shall be scheduled to accommodate previously scheduled activities for the Child. At the beginning of the Mother's periods of partial custody during the summer school break, the Mother shall pick up the Child at the Father's residence in the morning at a time to be arranged by agreement between the Mother and the Child. The Father shall pick up the Child after work between 4:30 p.m. and 5:00 p.m. on work days at the place designated by the Mother at least 24 hours in advance. The Father shall not be required to travel than 15 miles from his place of employment to pick up the Child. In the event the Mother does not provide the notice required by this provision or changes the location more than 24 hours in advance, the parties shall thereafter exchange custody at 4:30 p.m. at the Father's place of employment. C. The summer custody schedule shall begin on the first Saturday after the last day of school. The school year custody schedule shall begin on the Saturday preceding the first day of school. 4. The parties shall share or alternate having custody of the Child on holidays/school breaks as follows: A. Christmas/New Year's: In even-numbered years, the Father shall have custody of the Child from the day after school ends before the holiday through December 30 and the Mother shall have custody of the Child for the remainder of the Christmas/New Year's school break. In odd- numbered years, the Mother shall have custody of the Child from the beginning of the Christmas break through December 27, and the Father shall have custody from December 27 through the day before school resumes after the holiday. B. Thanksgiving: In even-numbered years, the Mother shall have custody of the Child for the entire Thanksgiving break. In odd-numbered years, the Father shall have custody of the Child from the day before Thanksgiving through the Sunday after Thanksgiving. C. February Recess/Spring Recess: The Father shall have custody of the Child during his February recess and spring recess from school from Saturday through Saturday. 5. The Mother shall be entitled to have custody of the Child for one (1) full week during the summer school break each year upon providing at least thirty (30) days advance notice to the Father. The Mother's vacation period shall run from Saturday through Saturday before Labor Day, unless otherwise agreed between the parties. 6. The parent relinquishing custody of the Child to the other parent shall be responsible to provide transportation for the exchange of custody and shall be responsible for all costs associated with the exchange of custody. The parties may make arrangements for the Child to travel by train between the parties' residences (in addition to each parent having the option to return the Child to the other party's custody by car) so long as train travel does not require the Child to change trains during the route by himself. In the event a parent intends to return custody of the Child to the other parent by train travel, that parent shall notify the other parent at least one week in advance of the scheduled train arrival time at the other parent's locale. In the event the parent later decides to return custody of the Child by car, that parent shall provide at least one day advance notice to the other parent of the change in travel arrangements. Both parents shall schedule the return time for the Child to arrive at the other parent's local train station, if the Child is traveling by train, or at the other parent's residence, if the Child is traveling by car, by 4:00 p.m. 7. Both parents shall be entitled to have reasonable telephone contact with the Child. The Father shall be entitled to contact the Child at least every Sunday between 7:30 p.m. and 9:00 p.m. The Father shall first try the Child's cell phone and, if he is not able to reach the Child on his cell phone, may contact the Mother on her cell phone. The Mother shall encourage the Child to participate fully in maintaining telephone contact with the Father. In the event the Father is unable to reach the Child on a weekly Sunday telephone call and requests a return call, the Mother shall ensure that the Child returns the Father's telephone call in a timely manner. 8. The parties shall cooperate in establishing a regular means of communication on a weekly basis to share information pertaining to the Child by email or in another manner agreed upon between the parties. The parties shall share all information concerning medical, dental or other appointments for the Child, all contact information for the Child's physicians or other professionals providing any type of care for the Child, including telephone numbers, and any and all information pertaining to the Child's school performance, activities and other developments which would be reasonably expected to be of interest and importance to the other parent. The parent having primary custody at the time shall be responsible to initiate the weekly information sharing contact. 9. The parties shall continue to abide by the recommendations of the Child's counselor with regard to continued counseling while in the custody of either parent. 10. The Father may make arrangements for the Child to participate in counseling during the Father's periods of custody for the purpose of addressing issues which have arisen or may hereafter arise in the relationship between the Father and Son. 11. The parties shall communicate directly with each other concerning issues affecting the Child. Each party shall accept telephone calls from the other party and shall return telephone calls promptly if requested. 12. The parties shall keep each other informed concerning all developments concerning the Child. The Mother shall provide the Father with all school contact information necessary to enable the Father to maintain contact with the Child's teachers and other school personnel. 13. When designating the Child's name on school, medical or any other documentation or for any other purpose, the parties shall designate the Child's surname as it appears on his birth certificate. 14. The Father's consent to the Mother's relocation of the Child to Connecticut shall be without prejudice as to any other move by the Mother to a different location, which shall be considered a separate request for relocation requiring approval of the Court or agreement of the parties. 15. Unless otherwise agreed between the parties in advance or pursuant to an Order of Court, the Father shall not use a plane, other than a commercial aircraft, to pick up the Child for a period of custody. 16. The Father shall ensure that the Child's summer homework assignments are completed by the end of his period of summer custody. The Mother shall provide a written list of the Child's summer homework assignments to the Father promptly upon receipt. 17. Jurisdiction over this custody matter shall remain in this Court. 18. Neither party 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. Both parties shall ensure that third parties having contact with the Child comply with this provision. 19. 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 mutual consent. In the absence of mutual consent, the terms of this Order shall control. BYRE COURT, Edward E. Guido J. Z cc: P t er J. Russo, Esquire - Counsel for Father /Gary L. Kelley, Esquire - Counsel for Mother ?bpt?ES rn? t I ?1 CHRISTOPHER L. PLITT Plaintiff vs. ANNA J. TRAINO Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2004-987 CIVIL ACTION LAW 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 Zachary L. Plitt December 14, 1994 Mother/Father 2. A custody conciliation conference was held on September 3, 2009, with the following individuals in attendance: the Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire, and the Mother's counsel, Gary L. Kelley, Esquire. The Mother, Anna J. Traino, resides in Connecticut and participated in the conference by telephone. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator nLEC,--,. r _ OF THE RR ? ?-' INIOTAPY 2009 SEP 14 P 12: 3 1 CHRISTOPHER L. PLITT PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 2004-987 CIVIL ACTION LAW M W r7;'- ANNA J. TRAINO IN CUSTODY DEFENDANT -< CO ORDER OF COURT - '" AND NOW, Wednesday, June 08, 2011 , upon consideration of the attache dfo ml1aint, 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, July 05, 2011 at 4:00 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. 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. IC,41 • arj mailP ? Pus- co ovileV ,?P/l Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 cowl ??? ? CHRISTOPHER L. PLITT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2004-987 CIVIL ACTION LAW ANNA J. TRAINO Defendant IN CUSTODY ORDER OF COURT AND NOW, this I 4r_ day of 4tv?- , 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: A hearing is sche led in Courtroom Number 3 of the Cumberland County Courthouse on the J - day of , 2011 at I :A pm., at which time testimony will be taken. F purposes of the heari g, the Father, Christopher L. Plitt, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least 10 days prior to the hearing date. BY COURT, Edward E. Guido J. E- _-= -j cc: ?eter J. Russo, Esquire - Counsel for Father /?? Gary L. Kelley, Esquire - Counsel for Mother lrDPies BA Dc CHRISTOPHER L. PLITT Plaintiff vs. ANNA J. TRAINO Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2004-987 IN CUSTODY CIVIL ACTION LAW CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: follows: I. The pertinent information concerning the Child who is the subject of this litigation is as NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Zachary L. Plitt December 14, 1994 Mother 2. A custody conciliation conference was held on July 26, 2011, with the following individuals in attendance: the Father, Christopher L. Plitt, with his counsel, Peter J. Russo, Esquire, and the Mother, Anna J. Traino (who participated by telephone from her residence in Connecticut) with her counsel, Gary L. Kelley, Esquire. 3. The most recent Order entered by the Court in this matter was dated September 14, 2009 under which the Mother has primary physical custody of the Child during the school year in Connecticut and the Father has primary physical custody during the summer in Pennsylvania. The Father filed this Petition for Modification seeking primary physical custody of the Child. The parties were not able to reach an agreement at the conference and it will be necessary to schedule a hearing on the Father's Petition. 4. The Father's position on custody is as follows: The Father's main reason for filing the Petition for primary custody focuses on an incident which occurred at the end of April 2011 during which the Child threatened the Mother and the Mother contacted the police. The Child was handcuffed and taken to the police station before being released. The Connecticut Agency for Children and Youth became involved and the Child was ultimately placed on probation. The Father is concerned that while on probation an additional incident such as this one would lead to the Child being placed in juvenile detention and, if the Child is 17 at the time, he will be treated as an adult in the Connecticut Court System. The Father believes it would be in the Child's best interests to live with his Father in Pennsylvania for the remaining two years of high school. The Father expressed concern that the difficulties between the Mother and her husband, resulting in the Child calling the police, is having and will continue to have a detrimental impact on the Child. The Father believes that the Mother's household is a particularly bad environment for the Child at this point in time considering the anger and other issues that the Child is addressing. 5. The Mother's position on custody is as follows: The Mother acknowledges that she contacted the police in April due to threats made by the Child and a concern for her safety. The Mother indicated that she handled the situation as recommended by the Child's counselors. The Mother stressed that the Child does not want to move to Pennsylvania as he has friends, school and sports all centered in Connecticut now. The Mother believes that the incident in April was a necessary evil from which the Child learned a lesson and is now learning coping skills through his ongoing counseling. The Mother indicated that the Child is doing everything that he is supposed to do to get back on track and she believes that it would be detrimental to him to change his school and environment. 6. The conciliator recommends an Order in the form as attached scheduling a hearing in this matter. It should be noted that there is a school issue involved and the Father has requested that a hearing be scheduled prior to the beginning of the 2011-2012 school year if possible. The parties anticipate that there will be at least six witnesses, mainly counselors and mental health professionals who will be called to testify at the hearing in addition to the parties themselves. Therefore, it is anticipated that at least a full day may be necessary for the hearing. 7, in / / Date Dawn S. Sunday, Esquire Custody Conciliator CHRISTOPHER L. PLITT, IN THE COURT OF COMMON PLEJS QZ n Plaintiff CUMBERLAND COUNTY, PENNSYL . -off ...., v. NO. 2004-987 CIVIL TERM == C ANNA J. TRAINO, Defendant =-n IN CUSTODY =O y?C W C? x -+ ORDER OF COURT `i AND NOW, this 17th day of August, 2011, our Order of September 14, 2009, is modified as follows: The existing Paragraph 8 is deleted and replaced with the following: The custodial parent shall e-mail the non-custodial parent on a weekly basis to share information concerning the child. The information shall include all information concerning medical, dental or other appointments the child has had, all contact information for the child's physicians or other professionals providing any type of care for the child, including telephone numbers, and all information pertaining to the child's school performance, activities and other developments which would be reasonably expected to be of interest and importance to the other parent. The e-mail shall also include something positive about the child that occurred during the week. Copies of all e-mails shall be saved and presented as an exhibit at any future hearing. Paragraph 19 is deleted and replaced with the following: The custodial parent shall make sure that the child contacts the non-custodial parent by phone at least once each week. Unless the parties agree otherwise, the phone contact shall be initiated between noon and 1:00 on Sundays and ' r Plitt v. Traino 2004-987 Civil Term Page 2 shall last as long as the child desires. In all other respects, our Order of September 14, 2009, shall remain in full force and effect. By the Court, Edward E. Guido, J. Peter J. Attorney Gary L. Attorney srs Russo, Esquire for Plaintiff ?,1?ed Kelley, Esquire ?$(18111 for Defendant I 00