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HomeMy WebLinkAbout08-6000JULIE K. FLETCHER, Plaintiff vs. KRISTOPHER DOUGLAS McKAY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ?' L o a? NO. 08 •6ZY-0 eic.'t7 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 foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in 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 at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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 Bar Association 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 Telephone: (717) 249-3166 JULIE K. FLETCHER, Plaintiff vs. KRISTOPHER DOUGLAS McKAY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, twenty days of the date on which you receive this notice you must make your request for counseling within You are advised that this list is kept Failure to do so will constitute a waiver of your right to request counseling. N qq mw W c ?z r_- r. N cz? c'S? t rT? 10 Fri JULIE K. FLETCHER, Plaintiff vs. KRISTOPHER DOUGLAS McKAY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE WAIVER OF RIGHTS UNDER THE UNITED STATES SOLDIERS AND SAILORS CIVIL RELIEF ACT I, Kristopher Douglas McKay, born 26 February 1982 and having Social Security Number 519-27-8210, hereby waive my right to oppose, stay, or otherwise participate in a divorce action filed by my wife, Julie K. Fletcher, born 2 May 1986 and having Social Security Number 214-15-5879, as those rights are guaranteed or provided to me by the United States Soldiers and Sailors Civil Relief Act. With regard to such waiver, I hereby specifically state as follows: A. I am an adult individual who has read and understands this waiver. B. I am currently on active duty with the United States military and am serving in Iraq. I left for Iraq in December of 2007 and anticipate returning to the United States in 2008. C. I am currently married to Julie K. Fletcher who has requested that I cooperate so that we can obtain a divorce and dissolve and end our bonds of matrimony. D. 1 understand that I have the right to postpone or stay my wife's divorce proceedings Soldiers and Sailors Civil Relief Act. until I am no longer in active duty in the United States military and that I have certain other rights regarding my wife's divorce action guaranteed or provided to me by the United States E. I have had ample opportunity to discuss this document with an advisor or representative of my choice. F. Being aware of my rights under the said statute, I hereby waive those rights so that my wife can proceed with the divorce action without delay. G. I make this waiver of my own free will and not as a result of any coercion, duress, or threats. IN WITNESS WHEREOF I have executed this Waiver this,'?day of .? 2008. :D V1 - KRISTO ER D. Mc COMMONWEALTH OF PENNSYLVANIA ) (SS.: COUNTY OF CUMBERLAND ) On this, the 410 - day of 2008, before me, a Notary Public, the undersigned officer, personally appeared KRISTOPHER D. McKAY known to me (or satisfactory proven) to be the person whose name is subscribed to the within instrument, and acknowledge that said person executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. DAIL I&Ifwlga Notary % blic. L WFXW ? arc ?. ?ti" '?^:% t7Nwlfi?i?iJ ` i:a???:?1+ 4+grlMsl3a C) e-a "- rl 1 C- r -r l i ___1 47- 4r? JULIE K. FLETCHER, Plaintiff vs. KRISTOPHER DOUGLAS McKAY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. d? -4.OO6 lr lc?c (, 6 ?. IN CUSTODY COMPLAINT IN CUSTODY AND NOW comes the Plaintiff, JULIE K. FLETCHER, by her attorney, Samuel L. Andes, and makes the following Complaint for Custody: 1. The Plaintiff is JULIE K. FLETCHER, an adult individual who resides at 6 Graystone Manor Drive in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is KRISTOPHER DOUGLAS McKAY, an adult individual who resides at 6 Graystone Manor Drive in Camp Hill, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant are husband and wife. 4. The Plaintiff and Defendant are the parents of one minor child, Kaylee Grace McKay, born 12 October 2007. 5. Plaintiff requests this court to enter an order granting the parties shared legal custody of the child and granting to Mother primary physical custody of the child with a general schedule of temporary custody for the Father. 6. The child was not born out of wedlock and at the time of this Complaint, the child reside with both parents at the marital residence and in the joint legal and physical custody of both parents. 7. Since the child's birth, the minor child has resided with the following persons at the following addresses: October 2007 to present 6 Graystone Manor Drive Camp Hill, PA Plaintiff and at times with Defendant in the same residence 8. The mother of the child is the Plaintiff who resides at the address set out above. She is married to the Defendant. 9. The father of the child is the Defendant who resides at the address set out above. He is married to the Plaintiff. 10. The Plaintiff is the natural mother of the child. Plaintiff currently resides with the child at the address listed above. 11. The Defendant is the natural father of the child. Defendant currently resides with the child at the address listed above. 12. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the child in this or any other court. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights to the said child. 13. The best interests and permanent welfare of the child will be served by granting the relief requested by Plaintiff for the following reasons: A. Father is scheduled to be recalled to active military duty and be assigned to Iraq in the relatively near future and, as a result, cannot provide properly for the custody of the child; B. Mother is prepared and able to provide a good and secure home for the child as she has since the child's birth; C. The parties have agreed on this custodial arrangement and have signed a written Stipulation for the entry of an order on these terms. 14. 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 asks this court to confirm the custody arrangements agreed upon by the parties by entering the attached order of court in which the parties have signed a written stipulation. il L. And Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: 1 o / G/ o R -J K. xF e.? JULIE K. FLETCHER f C- c?a `"f l ryfT1 Tyn W JULIE K. FLETCHER, Plaintiff vs. KRISTOPHER DOUGLAS McKAY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 68 - (,apd efc-jf,t-? IN CUSTODY CUSTODY STIPULATION AND NOW come Julie K. Fletcher, hereinafter referred to as "Mother" and Kristopher Douglas McKay, hereinafter referred to as Father' and agree and stipulate as follows: 1. They are the Father and Mother of one minor child, Kaylee Grace McKay. born 12 October 2007, hereinafter referred to as "Child." 2. Father and Mother shall share legal custody of their Child as controlled by Pennsylvania law. The parties will share information about the Child's health, health care, education, and religious training and, to the full extent possible, make mutual decisions regarding such matters for the Child and will consult with each other regarding all matters of importance in the Child's life. Further, each of the parties hereby consents to any physician, hospital, or other health care provider or any teacher, school, or educational institution, or any minister, church or other religious institution to share and provide full information about the Child and its care, education, and religious training with the other parent. 3. Mother shall have primary physical custody of the Child and the Child shall reside with her. Father shall have the following periods of temporary custody of the Child: A. Alternating weekends from sometime Friday until sometime late Sunday, the specific times to be the subject of agreement by the parties; B. One half of the major holidays scheduled as the parties mutually agree; and C. Such other times and on such other occasions as the parties mutually agree. " In addition to the above, each parent shall have the right to have the child with them for a reasonable period of time each year for purposes of vacation. When the child starts school, I wr ,!1 P the parents' vacation periods shall be limited to the summer months during the child's summer vacation. 4. This agreement shall be entered as an order by the Court of Common Pleas of Cumberland County, Pennsylvania. In the event that the parties are not able to agree upon a specific schedule to implement the terms and provisions of this order, or in the event that any other dispute arises between the parties regarding the custody of their child, either party may petition the court for modification, clarification, or enforcement of this order. 5. Neither party shall travel out of the Commonwealth of Pennsylvania with the child without the prior written consent of the other parent. In the event that either parent plans to take a trip with the child outside the Commonwealth, they shall notify the other parent when they make their plans and will provide the other parent with the location where the child will be staying and a ready means of contacting the child and the parent who is traveling with the child. 6. Father's periods of custody shall be at a mutually agreeable location and with facilities approved by both parties. IN WITNESS WHEREOF the parties have set their hands and seals thisam day of 2008. j " K. y=-ems.,, JULIE K. FLETCHER KRIS HER DO McKAY IMONWEALTH OF PENNSYLVANIA ) NTY OF CUMBERLAND (SS.: On this, thee'"day of c?WJyJw 2008, before me, the undersigned officer, ally appeared JULIE K. FLETCHER known to me (or satisfactorily proven) to be the whose name is subscribed to the within instrument, and acknowledged that said person ed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ,OMMONWEALTH OF PENNSYLVANIA UNTY OF CUMBERLAND My Co mission Expires: 80K?0UTMYMAM (SS.. On this, thei" day of t '/ , 2008, before me, the undersigned officer, sonally appeared KRISTOPHER DOUGLAS McKAY known to me (or satisfactorily proven) to the person whose name is subscribed to the within instrument, and acknowledged that said ,son executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Co ?ission Wt. womewo'cummmuft 000 80 0 JAPAMO ,)Usuq YFATOP IW Y7?I m aiVA7N . a 1 h 0 a 3 i .jA38 JAIRATOIA 31.l"YPAI?'Yil??i?.2?M O YMA YWW= O e. *WOW .$, AYM v It JULIE K. FLETCHER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO KRISTOPHER DOUGLAS McKAY ) C , Defendant ) IN CUSTODY COMPLAINT IN CUSTODY r AND NOW comes the Plaintiff, JULIE K. FLETCHER, by her attorney $6Mu eI± - Andes, and makes the following Complaint for Custod : , `=7 - -? e y 1. The Plaintiff is JULIE K. FLETCHER, an adult individual who resides at 6 Graystone Manor Drive in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is KRISTOPHER DOUGLAS McKAY, an adult individual who resides at 6 Graystone Manor Drive in Camp Hill, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant are husband and wife. 4. The Plaintiff and Defendant are the parents of one minor child, Kaylee Grace McKay, born 12 October 2007. 5. Plaintiff requests this court to enter an order granting the parties shared legal custody of the child and granting to Mother primary physical custody of the child with a general schedule of temporary custody for the Father. 6. The child was not born out of wedlock and at the time of this Complaint, the child reside with both parents at the marital residence and in the joint legal and physical custody of both parents. 7. Since the child's birth, the minor child has resided with the following persons at the following addresses: October 2007 to present 6 Graystone Manor Drive Camp Hill, PA Plaintiff and at times with Defendant in the same residence 8. The mother of the child is the Plaintiff who resides at the address set out above. She is married to the Defendant. 9. The father of the child is the Defendant who resides at the address set out above. He is married to the Plaintiff. 10. The Plaintiff is the natural mother of the child. Plaintiff currently resides with the child at the address listed above. 11. The Defendant is the natural father of the child. Defendant currently resides with the child at the address listed above. 12. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the child in this or any other court. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights to the said child. 13. The best interests and permanent welfare of the child will be served by granting the relief requested by Plaintiff for the following reasons: A. Father is scheduled to be recalled to active military duty and be assigned to Iraq in the relatively near future and, as a result, cannot provide properly for the custody of the child; B. Mother is prepared and able to provide a good and secure home for the child as she has since the child's birth; C. The parties have agreed on this custodial arrangement and have signed a written Stipulation for the entry of an order on these terms. 14. 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 asks this court to confirm the custody arrangements agreed upon by the parties by entering the attached order of court in which the parties have signed a written stipulation. E tamubl L. And Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date:lo/G/oR J ?," K• E49&Aam JULIE . FLETCHER r OCT 0 8 2008 Ct JULIE K. FLETCHER, Plaintiff vs. KRISTOPHER DOUGLAS McKAY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-(66 IN CUSTODY ORDER OF COURT AND NOW, this - a6ay of , 2008, upon the Stipulation of the - altc??, parties, we hereby order and decree as follows: 1. Father and Mother shall share legal custody of their Child as controlled by Pennsylvania law. The parties will share information about the Child's health, health care, education, and religious training and, to the full extent possible, make mutual decisions regarding such matters for the Child and will consult with each other regarding all matters of importance in the Child's life. Further, each of the parties hereby consents to any physician, hospital, or other health care provider or any teacher, school, or educational institution, or any minister, church or other religious institution to share and provide full information about the Child and its care, education, and religious training with the other parent. 2. Mother shall have primary physical custody of the Child and the Child shall reside with her. Father shall have the following periods of temporary custody of the Child: A. Alternating weekends from sometime Friday until sometime late Sunday, the specific times to be the subject of agreement by the parties; B. One half of the major holidays scheduled as the parties mutually agree; and C. Such other times and on such other occasions as the parties mutually agree. In addition to the above, each parent shall have the right to have the child with them for a reasonable period of time each year for purposes of vacation. When the child starts school, the parents' vacation periods shall be limited to the summer months during the child_:s nmer vacation. BY THEZOURT, Distribution: ?Samuel L. Andes, Esquire (Attorney for Plaintiff) 525 North 120' Street, P.O. Box 168, Lemoyne, PA 17043 v`Kristopher Douglas McKay (Defendant) 6 Graystone Manor Drive, Camp Hill, PA 17041 (26plts? J. act 9J j '[ f ;? ? I Il t C l JULIE K. FLETCHER, Plaintiff vs. KRISTOPHER DOUGLAS McKAY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. TUC& - 60 IN DIVORCE u =C-KP,t--N E Q -F !FRYIICE I, KRISTOPHER DOUGLAS McKAY, hereby accept service of the original Complaint in livorce and acknowledge that I have received a copy of the Complaint and of my Waiver of ights under the United States Soldiers and Sailors Civil Relief Act this day. 2 KRIS HER LAS McKAY 6 Graystone Manor Drive Camp Hill, PA 17011 ?? \ j ?? ,..?%c ^; ? ^t' " .?' ?'?(S ? _ 4Q' JULIE K. FLETCHER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-6000 Civil Term KRISTOPHER DOUGLAS McKAY, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 7 October 2008 and served upon the Defendant on or about 21 October 2008 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. 1 consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree in divorce without notice. 2. 1 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. 3. 1 understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit 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. I Qhog Dated. JK- p 4t,'5, 4,C JULIE K. FLETCHER ? ? ? r? JULIE K. FLETCHER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-6000 Civil Term KRISTOPHER DOUGLAS McKAY, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 7 October 2008 and served upon the Defendant on or about 21 October 2008 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. 1 consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree in divorce without notice. 2. 1 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. 3. 1 understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit 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. 1 WabnQ , Dated: KRI PHER DOUG . S McKAY t_°, _ ,? __,, ? ?,?, :--a _. ;-?. ?,;?. - ., -fir ?? _; -. ? ?? K' , :: ` x.? - ?? ... ,: .. ?? ..-? ? Yi JULIE K. FLETCHER, Plaintiff ) vs. ) KRISTOPHER DOUGLAS McKAY, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-6000 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: Irretrievable breakdown under Section 3301(c). 2. Date and manner of service of the Complaint: Acceptance of Service indicating service upon the Defendant on 10 October 2008 and filed on 21 October 2008. 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: 4 June 2008 by Defendant: 4 June 2008 (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of the Plaintiffs Affidavit upon the Respondent: 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 22 January 2009 and filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: dated 22 January 2009 and filed contemporaneously herewith. zi Date*. 2L January 2009 B ue1 L. An Attorney for Plaintiff 77 .? f_„ - IN THE COURT OF COMMON PLEAS OF JULIE K. FLETCHER ;CUMBERLAND COUNTY, PENNSYLVANIA V. KRISTOPHER DOUGLAS McKAY : NO. 2008-6000 Civil Term DIVORCE DECREE AND NOW, N it is ordered and decreed that JULIE K. FLETCHER , plaintiff, and KRISTOPHER DOUGLAS MCKAY, defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None Attest: "*?) J. *Prothonotary ?ad g0. E' _& . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JULIE K. FLETCHER Plaintiff NO. 08-6000 CIVIL TERM V. KRISTOPHER D. McKAY Defendants CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO WITHDRAW PETITION FOR EMERGENCY CUSTODY PETITION TO THE PROTHONOTARY OF THE SAID COURT: Based on the fact that the parties have been able to temporarily set up a schedule of partial custody rights for Defendant, Kristopher McKay, Defendant by his attorney whereby withdraws his Petition for Emergency Custody Order filed on June 17, 2009. 'd116? DCLIFF, ESQUIRE torney gistration No 32112) 3448 Trindle Road Camp Hill, PA 17011 Email: dianeradcliff @comcast.net Phone: (717) 737-0100 Fax: (717) 975-0697 Counsel for Petitioner Dated: June 22, 2009 CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure: Service by First Class Mail Addressed as Follows Samuel L. Andes, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne, PA 17043 (Attorney for Plaintiff /Respondent) Camp Hill, PA 17011 Email: dianeradcliff comcast net Phone: (717) 737-0100 Fax: (717) 975-0697 Counsel for Petitioner Dated: June 22. 2009 FILFEI.",- 2169 J? ' C23 PH li, 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JULIE K. FLETCHER Plaintiff V. KRISTOPHER D. McKAY Defendants NO. 08-6000 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY AFFIDAVIT OF PROCESS SERVER Affidavit of Process Server IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA (NAME OF COURT) KRISTOPHER D MCKAY vs JULIE K FLETCHER et al 09 4130 CIVIL TERM PLAINTIFF/PETITIONER DEFENDANT/RESPONDENT CASE NUMBER 1 RICHARD KREITZER being first duly sworn, depose and say: that I am over the age of 18 years and not a party to this action, and that within the boundaries of the state where service was effected, I was authorized by law to perform said service. Service: I served JULIE K FLETCHER NAME OF PERSON / ENTITY BEING SERVED with (list documents) CUSTODY COMPLAINT, PETITION FOR EMERGENCY RELIEF by leaving with JULIE K FLETCHER SELF At NAME RELATIONSHIP ? Residence 335 SHERWOOD DRIVE APT E YORK PA 17043 ADDRESS 11 Business CITY/STATE ADDRESS CITY/STATE On 6 17 09 AT 6:00 PM DATE TIME Thereafter copies of the documents were mailed by prepaid, first class mail on from DATE CITY STATE ZIP Manner of Service: I] Personal: By personally delivering copies to the person being served. ? Substituted at Residence: By leaving copies at the dwelling house or usual place of abode of the person being served with a member of the household over the age of and explaining the general nature of the papers. ? Substituted at Business: By leaving, during office hours, copies at the office of the person/entity being served with the person apparently in charge thereof. ? Posting: By posting copies in a conspicuous manner to the front door of the person/entity being served. Non-Service: After due search, careful inquiry and diligent attempts at the address(es) listed above, I have been unable to effect process upon the person/entity being served because of the following reason(s): ? Unknown at Address ? Moved, Left no Forwarding ? Service Cancelled by Litigant ? Unable to Serve in Timely Fashion ? Address Does Not Exist ? Other Service Attempts: Service was attempted on: (1) (2) DATE TIME DATE TIME (3) (4) (5) DATE TIME DATE TIME DATE TIME Description:. Age 23 Sex F Race W Height 5'4" Weigh air BR and NO Glasses NO 1 SIG A RE O ROCESS SERVER SUBSCRIBED AND SWORN to before me this ?da of 20j?22, by -, Proved to me on the basis of satisfactory evidence to be the per s) who appeared bee me. L)FNN V NOTAp?AL SEAL CS NATURE OF NOTA PUBLIC ON, Suscquehanna Tw Notary public MEGAN ANN TYSor the state of My CommissiG;, EXci PS ?a em n C g my NOTARY BLfC f 2012 fi FORM 2 NATIONAL ASSOCIATION OF PROFESSIONAL PROCESS SERVERS Affidavit of Process Server IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA (NAME OF COURT) KRISTOPHER D MCKAY vs JULIE K FLETCHER et al 09 4130 CIVIL TERM PLAINTIFF/PETITIONER DEFENDANT/RESPONDENT CASE NUMBER I RICHARD KREITZER being first duly sworn, depose and say: that I am over the age of 18 years and not a party to this action, and that within the boundaries of the state where service was effected, I was authorized by law to perform said service. Service: I served ANDREA HARRINGTON NAME OF PERSON / ENTITY BEING SERVED with (list documents) CUSTODY COMPLAINT, PETITION FOR EMERGENCY RELIEF by leaving with LEE HARRINGTON HUSBAND At NAME RELATIONSHIP ? Residence 6 GRAYSTONE MANOR DRIVE CAMP HILL PA ADDRESS CITY/STATE ? Business ADDRESS CITY / STATE On 6 17 09 AT 7:30 PM DATE TIME Thereafter copies of the documents were mailed by prepaid, first class mail on from DATE CITY STATE ZIP Manner of Service: ? Personal: By personally delivering copies to the person being served. Fi Substituted at Residence: By leaving copies at the dwelling house or usual place of abode of the person being served with a member of the household over the age of fs and explaining the general nature of the papers. ? Substituted at Business: By leaving, during office hours, copies at the office of the person/entity being served with the person apparently in charge thereof. ? Posting: By posting copies in a conspicuous manner to the front door of the person/entity being served. Non-Service: After due search, careful inquiry and diligent attempts at the address(es) listed above, I have been unable to effect process upon the person/entity being served because of the following reason(s): ? Unknown at Address El Address Does Not Exist El ? Service Cancelled by Litigant ? Unable to Serve in Timely Fashion Service Attempts: Service was attempted on: (1) (2) DATE TIME DATE TIME DATE TIME DATE TIME DATE TIME Description:. Age 55 Sex M Race W Height 6'1" Weight 180 Hair GRAY eard NO NO Glasses f ? SIG ATU F PROCESS SERVER SUBSCRIBED AND SWORN to before me this day of ,2001, b Proved to me on the basis of satisfactory evidence to be the person whoa bI by appeared before me. F l?tJN Y VA I ,? ?---, NC+TARIALSEAL S NATURE OF NOT Y PUBLIC MEGAN ANN TYSON, Notary Public SUSquehanna Twp., Dauphin County NOTARY PUS IC for the state of 5 MY Commission Expires November 19, 2012 G?I FORM 2 NATIONAL ASSOCIATION OF PROFESSIONAL PROCESS SERVERS ? Moved, Left no Forwarding Affidavit of Process Server IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA (NAME OF COURT) KRISTOPHER D MCKAY VS JULIE K FLETCHER et al 09 4130 CIVIL TERM PLAINTIFF/PETITIONER DEFENDANT/RESPONDENT CASE NUMBER I RICHARD KREITZER being first duly sworn, depose and say: that I am over the age of 18 years and not a party to this action, and that within the boundaries of the state where service was effected, I was authorized by law to perform said service. Service: I served LEE HARRINGTON NAME OF PERSON / ENTITY BEING SERVED with (list documents) CUSTODY COMPLAINT, PETITION FOR EMERGENCY RELIEF by leaving with LEE HARRINGTON SELF NAME RELATIONSHIP At 12 Residence 6 GRAYSTONE MANOR DRIVE CAMP HILL PA ADDRESS CITY/STATE ? Business ADDRESS CITY/STATE 6 17 09 DATE T 7:30 PM TIME Thereafter copies of the documents were mailed by prepaid, first class mail on CITY STATE ZIP DATE Manner of Service: 0 Personal: By personally delivering copies to the person being served. ? Substituted at Residence: By leaving copies at the dwelling house or usual place of abode of the person being served with a member of the household over the age of and explaining the general nature of the papers. ? Substituted at Business: By leaving, during office hours, copies at the office of the person/entity being served with the person apparently in charge thereof. ? Posting: By posting copies in a conspicuous manner to the front door of the person/entity being served. Non-Service: After due search, careful inquiry and diligent attempts at the address(es) listed above, I have been unable to effect process upon the person/entity being served because of the following reason(s): ? Unknown at Address El El Address Does Not Exist r-1 El Service Cancelled by Litigant 1:1 Unable to Serve in Timely Fashion Service Attempts: Service was attempted on: (1) (2) DATE TIME DATE TIME (3) DATE TIME (4) (5) DATE TIME DATE TIME Description:. Age 55 Sex M Race W Height s'1" GRAY NO NO Glasses SUBSCRIBED AND SWORN to before me this day ofj Proved to me on the basis of satisfactory evidence to be the erso ' by p ) who appeared before me. OE_EIENN Y A NOTARIAL SEAL / _ MEGAN ANN TYSON, Notary Public G ATURE OF NOTARY BLIC Susquehanna Twp., Dauphin County My Commission Expires November 19, 2012 NOTARY PU IC for the state ofc , PAT ?;°IX, FORM 2 NATIONAL ASSOCIATION OF PROFESSIONAL PROCESS SERVERS Moved, Left no Forwarding THE ('1 ?r ;1af AUG 2120094 JULIE K. FLETCHER Plaintiff VS. KRISTOPHER DOUGLAS McKAY Defendant KRISTOPHER DOUGLAS McKAY Plaintiff VS. JULIE K. FLETCHER, ANDREA HARRINGTON, LEE HARRINGTON Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-6000 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this day of ouA w. C-? , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Kristopher D. McKay, and the Mother, Julie K. Fletcher, shall have shared legal custody of Kaylee G. McKay, born October 12, 2007. Major decisions concerning the Child including, but not necessarily limited to, her health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 2. The Mother shall have primary physical custody of the Child. 3. Pending the follow-up custody conciliation conference scheduled in this Order, the Father shall have partial physical custody of the Child for two (2) long weekend periods of custody prior to October 1, 2009, for which the Father shall provide as much notice as possible as to the dates selected. The Father shall exercise his periods of long weekend custody in Pennsylvania. In addition, based on the Child's adjustment during the Father's long weekend periods of custody, the Father shall have custody of the Child for a one week period in October in Pennsylvania. Thereafter, the parties acknowledge it is their intention to schedule ongoing periods of custody with the Father at his residence in North Carolina, also based on the Child's adjustment. 4. The parties and their counsel shall attend follow-up custody conciliation conferences in the office of the conciliator, Dawn S. Sunday, Esquire, on Tuesday, October 1, 2009 at 9:00 a.m. and on Tuesday, November 3, 2009 at 9:00 a.m. for the purpose of reviewing the initial periods of custody and establishing an ongoing schedule. 5. 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 COURT, cc: ane G. Radcliff Esquire - Counsel for Father D Samuel L. Andes, Esquire - Counsel for Mother and maternal grandparents (20 P C es /rim[ .4 JULIE K. FLETCHER Plaintiff VS. KRISTOPHER DOUGLAS McKAY Defendant KRISTOPHER DOUGLAS MCKAY Plaintiff vs. JULIE K. FLETCHER, ANDREA HARRINGTON, LEE HARRINGTON Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-6000 CIVIL ACTION LAW IN CUSTODY Prior Judge: Edgar B. Bayley/J. Wesley Oler, Jr. 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 Kaylee G. McKay October 12, 2007 Mother 2. A custody conciliation conference was held on August 17, 2009, with the following individuals in attendance: the Father's counsel, Diane G. Radcliff, Esquire and the Mother, Julie K. Fletcher, the maternal grandmother, Andrea Harrington, and the maternal grandfather, Lee Harrington, with their counsel, Samuel L. Andes, Esquire. The Father, Kristopher D. McKay, is currently stationed in the military at Fort Bragg, North Carolina and participated in the conference by telephone. 3. The parties agreed to entry of an Order in the form as attached. rr.-off ?d? X00 9 4,? Date Dawn S. Sunday, Esquire Custody Conciliator r a ?. # 1-10' KOTARY 2DD9 AUG 2-3 AM 1 is 59 PEN NSAMANA I JULIE K. FLETCHER Plaintiff VS. KRISTOPHER DOUGLAS McKAY Defendant KRISTOPHER DOUGLAS McKAY Plaintiff VS. JULIE K. FLETCHER, ANDREA HARRINGTON, LEE HARRINGTON Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-6000 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 'I' day of 0C--VAS , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated August 25, 2009 shall continue in effect as modified by this Order. 2. The Father shall have custody of the Child, in accordance with the prior Order, from Monday, October 12, 2009 at 8:00 a.m., when the Father shall pick up the Child at the maternal grandparents' residence, through Sunday, October 18, 2009 at 10:30 a.m., when the Father shall return the Child to the maternal grandparents' residence. 3. The Father shall attend a one half or one full day parenting class which offers instruction on the basics of child care and shall provide written confirmation from the class provider to the Mother upon completion. The Father shall complete the parenting class, if possible, before his period of custody beginning on October 12. If it is not possible to complete the class by that time, the Father shall contact the provider by that date to schedule his class. 4. The Mother shall promptly provide confirmation from the provider of the parenting class which she previously attended to the Father documenting her completion of the class. 5. The parties shall establish ongoing communication between themselves through email and telephone in order to share information concerning the Child on a regular routine basis. 6. The parties and their counsel shall attend a follow-up custody conciliation conference in the office of the conciliator, Dawn S. Sunday, Esquire, on Tuesday, November 3, 2009 at 9:00 a.m. for the purpose of reviewing the initial periods of custody and establishing an ongoing schedule. 7. 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 COURT, cc: tamuel e G. Radcliff, Esquire - Counsel for Father ? L. Andes, Esquire - Counsel for Mother and maternal grandparents "'?'LLL JULIE K. FLETCHER Plaintiff vs. KRISTOPHER DOUGLAS McKAY Defendant KRISTOPHER DOUGLAS McKAY Plaintiff vs. JULIE K. FLETCHER, ANDREA HARRINGTON, LEE HARRINGTON Defendants Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-6000 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 Kaylee G. McKay October 12, 2007 Mother 2. A custody conciliation conference was held on October 1, 2009, with the following individuals in attendance: the Father's counsel, Diane G. Radcliff, Esquire and the Mother, Julie K. Fletcher, the maternal grandmother, Andrea Harrington, and the maternal grandfather, Lee Harrington, with their counsel, Samuel L. Andes, Esquire. The Father, Kristopher D. McKay, is currently stationed in the military at Fort Bragg, North Carolina 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 NOV 0 9 2009 ,5? JULIE K. FLETCHER Plaintiff vs. KRISTOPHER DOUGLAS McKAY Defendant KRISTOPHER DOUGLAS McKAY Plaintiff vs. JULIE K. FLETCHER, ANDREA HARRINGTON, LEE HARRINGTON Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-6000 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this AO day of 7'L 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: A hearing is scheduled in Court Room Number '-/ of the Cumberland County Court House on the q-t? day of T1 2 tt- , 2010, at 9,` 30 o'clock q m., at which time testimony will be taken. The Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties 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 seven days prior to the hearing date. BY THE COURT, Kevin . Hess J. cc. Zamuel e G. Radcliff, Esquire - Counsel for Father L. Andes, Esquire - Counsel for Mother and maternal grandparents I I h Y JULIE K. FLETCHER Plaintiff VS. KRISTOPHER DOUGLAS McKAY Defendant KRISTOPHER DOUGLAS McKAY Plaintiff vs. JULIE K. FLETCHER, ANDREA HARRINGTON, LEE HARRINGTON Defendants Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-6000 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 Kaylee G. McKay October 12, 2007 Mother 2. A custody conciliation conference was held on November 3, 2009, with the following individuals in attendance: the Mother, Julie K. Fletcher and the maternal grandparents, Andrea and Lee Harrington, with their counsel, Samuel L. Andes, Esquire, and the Father's counsel, Diane G. Radcliff, Esquire. The Father, Kristopher D. McKay, is currently stationed at Fort Bragg North Carolina and had previously participated in conferences by telephone. However, the Father did not participate in the present conference. 3. This Court previously entered Orders in this matter on August 25, 2009 and October 9, 2009, under which the Mother had primary physical custody of the Child and the Father had partial custody on an expanding schedule based on his current residence in North Carolina. The current conciliation was scheduled as a follow-up conference to establish an ongoing custody schedule beyond the dates addressed in the prior Orders. However, at the conference, the Father's counsel advised that the Father was requesting a hearing at this time and would not provide a proposal as to his requested schedule or respond to any proposals made by the Mother. Therefore, no conciliation on this matter was possible. It appears that the Father is not planning to have his available period of custody in December due to his wedding and honeymoon trip outside the country. Likewise, the Father will not be available until early March due to his temporary military training assignment. Therefore, a recommended temporary Order was not necessary. 4. The Mother's position on custody is as follows: The Mother and her parents were present for the conciliation conference and indicated their willingness to establish an ongoing custodial schedule for the Father as planned. However, without any details regarding the Father's availability, it was not possible for them to provide a proposal. The Mother is willing to work with the Father to establish a custody schedule consistent with his availability. 5. The Father's position on custody is as follows: The Father did not wish to present a position on custody at the time of the conciliation conference but instead, requested that a hearing be scheduled at this time for late February or early March when he has completed his upcoming training assignment. According to his counsel, the Father's request for a hearing is based on his belief that he will never be able to satisfy the maternal grandparents in terms of the custody arrangements. The Father will not be able to exercise a period of custody with the Child until that time as the next time he will be in Pennsylvania will be for his wedding and then a honeymoon trip outside the country. The Father did not request a period of custody with the Child when he is in Pennsylvania in December. 6. The conciliator recommends an Order in the form as attached scheduling a hearing in this matter to establish partial custody arrangements for the Father. It is requested that the hearing be scheduled in early March to ensure the Father's availability. &nee y. ST acn 9 Date Dawn S. Sunday, Esquire Custody Conciliator JULIE K. FLETCHER, Plaintiff V. KRISTOPHER D. McKAY, Defendant KRISTOPHER D. McKAY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-6000 CIVIL TERM IN CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2008-6000 CIVIL TERM n ° n JULIE K. FLETCHER, IN CUSTODY ANDREA HARRINGTON & LEE HARRINGTON --° Gal ;w IN RE : CUSTODY AGREEMENT rn ORDER OF COURT o `A cn AND NOW, this 4th day of March, 2010, upon agreem&Rt of the parties, as reflected by this order, we hereby order and decree as follows: 1) The father, Kristopher Douglas McKay, and the mother, Julie K. Fletcher, shall share legal custody of their daughter, Kaylee G. McKay, born October 12, 2007. With regard to legal custody, the parties will share and cooperate with each other in sharing information about the child, and, in particular, information regarding her health care, her education and her religious training. In the event that the child suffers any significant medical problem while in the custody of one parent, the parent then having custody shall promptly notify the other parent, and they will cooperate with each other to arrange appropriate care for that condition. 2) Primary physical custody of the child shall be with mother. 2008-6000 CIVIL TERM - page two 3) The father shall have the following periods of temporary custody: a) Six times a year he shall have custody for nine days, from a Saturday until the second Sunday thereafter. These periods may not be exercised consecutively, and no more than one of them may be exercised in any one calendar month. Father shall give mother at least thirty days advanced written notice of the times he will exercise this period of custody. For these custody periods, the parties will share transportation by meeting at a midpoint between mother's home and Fort Bragg, North Carolina. In the event that father is located closer than Fort Bragg, North Carolina, the parties will adjust the meeting point. In the event that he is living or stationed further than that location, mother's obligation to provide transportation shall not be expanded. 4) The parties shall share physical custody of the child on the following holidays: a) Mother shall have custody of the child from the 23rd of December until the 26th of December in even-numbered years. Father shall have custody of the child from the 26th of December until the 29th of December in odd-numbered years. The parties shall reverse that so that in odd-numbered years father shall have the child from the 23rd of December until the 26th of December, and mother shall have the child from the 26th of December until the 29th of December. The exchange times shall be at a time to be mutually agreed upon by the parties. The parties shall be reasonable and cooperative in setting that time. 2008-6000 CIVIL TERM - page three b) Father shall have custody of the child in even-numbered years for the Easter holiday for a period of three or four days to align with his leave. Mother shall have custody of the child for Easter in odd-numbered years. c) Father shall have physical custody of the child on the Memorial Day weekend for a period of three or four days to align with his leave in odd years. Mother shall have the child for the Memorial Day weekend and holiday in even years. d) Father shall have custody of the child on Labor Day in even years for three or four days to align with his leave schedule. Mother shall have custody of the child for the Labor Day weekend and holiday in odd years. e) Father shall have custody of the child for three or four days to align with his leave schedule for the Thanksgiving holiday in odd-numbered years. Mother shall have custody of the child in even years for the Thanksgiving holiday and weekend, except in 2010 when father shall have custody of the child for the Thanksgiving holiday for three or four days to align with his leave schedule. f) Father shall have custody of the child for the New Year's holiday for a three or four day period to align with his leave in even-numbered years. Mother shall have the New Year's holiday in odd-numbered years. 5) Mother shall not be required to participate in the transportation for any of the holidays outlined. Father shall give mother fourteen days advanced written notice of the times and schedule for his holiday periods of custody, and that notice shall provide information as to where the 2008-6000 CIVIL TERM - page four child will be staying and an appropriate means for the mother to contact the father and the child. 6) In addition to the above, father shall have one weekend, to be three or four days, aligning with his leave in any month when he does not otherwise have custody of the child. Father will be responsible to provide the transportation for that weekend and will notify mother in advance of the schedule of time he will pick up and return the child and the location that the child will be staying with him, and the means of contacting him and the child during that period. 7) Each parent shall have the right to have reasonable contact with the child by telephone when in the custody of the other parent. That will not be abused and will not be excessive, but it will be reasonable so that each parent can maintain contact with the child when not in their custody. By the Court, I ?. in . Hess, P.J. ? Samuel L. Andes, Esquire For M ther & Maternal Grandparents iane G. Radcliff, Esquire For Father :bg eon ??S ?iI16 JULIE K. FLETCHER, Plaintiff V. KRISTOPHER D. McKAY, Defendant KRISTOPHER D. McKAY, Plaintiff V. JULIE K. FLETCHER, ANDREA HARRINGTON & LEE HARRINGTON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-6000 CIVIL TERM IN CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-6000 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this /T day of , 2012, the Stipulation of the parties modifying this Court's Order of March 4, 2010, is APPROVED and ADOPTED as an Order of this Court. cc -/Karl R. Hildabrand, Esquire, attorney for A ? Julie K. Fletcher Kristopher D. McKay Lee Harrington &p. e6 Ma ?LI G -O:r mw rn L? C w try CD BY THE COURT: