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HomeMy WebLinkAbout04-1492 MICHAEL W. DOYLE Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW . :01-ILf't'J.... CIVIL TERM JODY M. DOYLE, Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of , 2004, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Esquire, the conciliator, at , on the _ day of , 2004 at . M. 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 this conference may provide grounds for entry of a temporary or pennanent order. By the Court, By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER 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 (717) 249.3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 scheduling conference or hearing. MICHAEL W. DOYLE, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JODY M. DOYLE, Defendant : 04~ 11..J9 ~ CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Michael W. Doyle, by his attorneys, Irwin & McKnight, and presents the following Complaint for Custody. 1. The Plaintiff, Michael W. Doyle, is an adult individual with an address of 185 Whitmer Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The Defendant, Jody M. Doyle, is an adult individual with an address of 4512 Newman Road, Fayetteville, Franklin County, Pennsylvania. 3. The parties are the natural parents of one (I) child, namely, Dylan J. Doyle, born November 11, 1998, age five (5). 4. The Plaintiff desires that the parties have shared legal custody of the minor child, Dylan J. Doyle. 5. The Plaintiff desires primary physical custody ofthe minor child, Dylan J. Doyle, with periods of temporary physical custody to Defendant as follows: A. Alternate weekends from Friday at 7:00 p.m. to Sunday at 7:00 p.m.; and B. Shared holidays. 6. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiffs request as set forth above. WHEREFORE, Plaintiff, Michael W. Doyle, respectfully requests that he be awarded primary physical custody and shared legal custody of Dylan J. Doyle, as provided herein, with periods of temporary physical custody to Defendant as provided herein. Respectfully submitted, By: / Mar sA. Me 'ght, Attorney for Plaintiff 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court 1. D. No. 25476 Date: April 7, 2004 VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. 'JrJ./ ~ IU? MICHAEL W. DOYLE Date: APRIL 7. 2004 t:J (:J -{Q. '\1::.. r; ::::: ~ ~ ~ ~ oL-l ~ ~ -..J 0' _I " ~ ~ ------~- r-.\ ,....,.:'t ..._ ~_-; C) ...L"- -11 .f,"" :.:;J >-~ I--j.::- , __J c.') , 1..,(; ,~ MICHAEL W. DOYLE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. 04-1492 CIVIL ACTION LAW JODY M. DOYLE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, April 16, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear beforeJ:ocqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thur!iday, May 06, 2004 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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 priior to scheduled hearing. FOR THE COURT. By: Isl Jacqueline M. Venury, Esq. Custody Concilllator mhc 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 OlIr WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . ~C"~?-P ~~~ 4;7-~0 ~ ,~..z. ~ ~u, fie? c?r:"'ff ~N P ~ ~ ~.~ //t:?Q";# (",."> , "'~",' I\..l,f< ".: :,-:;r'ili:J 0(".., III u':J .,:,. [;'U n:? \,1 n,' I P"";' '-"'" C:.:! LdJ!, MAY 0 e 2004 0J MICHAEL W. DOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this /J--If'. day of lit'1/" , 2004, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The Father, Michael W. Doyle and the Mother, Jody M. Doyle, shall have shared legal custody of Dylan J. Doyle, born November II, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make an major non- emergency decisions affecting the Child's general well-being including, but not limited to all decisions regarding his health, education and religion. 2. The parents shall have shared physical custody of the Child on a 5/5/2/2 alternating day schedule to coincide with Mother's work schedule. Father shall have the weekend of Friday, May 7 at 7:00 p.m. to Sunday, May 9, at 7:00 p.m. Thereafter Father's 2 day period shall begin on May 17 and 18. The alternating schedule shall continue as set forth above. 3. Transportation shall be shared as agreed by the parties. 4. Neither party shall consume alcohol immediately before or during their period of custody. 5. The parties shan cooperate with the Child's therapist and sign releases if necessary to facilitate the cooperation. 6. Both parties shall be entitled to liberal telephone contact with the Child. 7. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual ,;onsent. In the absence of mutual consent, the terms ofthis Order shall contro\. Another Conciliation Conference is scheduled for July 6, 2004 at 8:30 a.m. cc~arcus A. McKnight, III, Esquire, Counsel for Father .Jessica Diarnondstone, Esquire, Counsel for Mother ~~F~ J. ~ 05./~-OLJ J. '" ';/;t\~V/\-L,t.,S!\: 1'>J:Jd ,UNr:CC~ t"::~1l"ln8 co :2 Vd 2 I ,1Jlti ~COl AU\'lL.j\iOH10cd 3\41 :10 3~":i:!0-031H MICHAEL W. DOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None 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 Dylan J. Doyle November II, 1998 Mother 2. A Conciliation Conference was held in this matter on May 6, 2004 with the following individuals in attendance: The Father, Michad W. Doyle, with his counsel, Marcus A. McKnight, III, Esquire and the Mother, Jody M. Doyle, with her counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. 3. The parties agreed to the entry of an Order in the form as attached. S-f..o -0 y Date a o~ 11.~ ~Verney, EsqUire Custody Conciliator \; MICHAEL W. DOYLE, Plaintiff JUr 2004 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION .. LAW : IN CUSTODY ORDER OF COURT AND NOW, this I }.A day of ~ , 2004, upon consideration of the attached Custody Co~, it is ordered and directed as follows: I. The prior Order of Court dated May 12, 2004 shall remain in full force and effect with the following modifications and additions: 2. The Child shall be enrolled in Franklin COWIty School District. 3. Transportation shall be shared. While the Child is in Father's custody during the school year, Father shall be responsible for transporting the Child to school and Mother shall be responsible for transporting the Child back to Father. 4. Due to the Child's occasional inappropriate behavior, Mother shall arrange for therapeutic family counseling. Both parties shall cooperate with said counseling, providing releases and participating when requested. 5. Holidays: A. Mother's Day/Father's Day. Mother shall have physical custody of the Child on Mother's Day and Father shall have physical custody of the Child on Father's Day, at times agreed by the parties. B. Thanksgiving shall be alternated with Father having physical custody in even numbered years and Mother having physical custody in odd numbered years, at times agreed by the parties. C. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in even numbered years and Block B in odd numbered years. Father shall have Block A in odd numbered years and Block B in even numbered years, 6. Each party shaH be entitled to seven unint(lrrupted days in the summer, provided they give the other party 30 days prior notice. 7. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shaH control. Byr ~ Edward E. Guido, 1. cc: Marcus A. McKnight, III, Esquire, Counsel for Father Jessica Diamondstone, Esquire, Counsel for Mother ~ ~ '7./3-0'1 ~ VlN\7'f\:l\SN\{3d ,UNG"''' ,"'.~' '"''-\'I''Q (II,) \ l,,,'l"t"'.,<p,:."I. ~,,- ,,-,.. ,.....,"...~-' . Ot :5 \4~ to \ III! ~UOl AU';'JDNOH10\:ld 3H1 :10 '~2H;\O-a;1l\~ .' JUll 0 2004 MICHAEL W. DOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION .. LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody ConciHator submits the following report: I. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Dylan J. Doyle November 11, 1998 shared 2. A Conciliation Conference was held in this matter on July 8, 2004 with the following individuals in attendance: The Father, Michael W. Doyle, with his counsel, Marcus A. McKnight, III, Esquire and the Mother, Jody M. Doyle, with her counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. 3. The Honorable Edward E. Guido entered an Order of Court dated May 12, 2004 providing for shared legal and shared physical custody. 4. The parties agreed to the entry of an Order in the form as attached. 1-t-tJf Date ~,!i"q~ Custody Conciliator MICHAEL W. DOYLE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2004-1492 CIVIL ACTION LA W JODY M. DOYLE Defendant IN CUSTODY PETITION FOR MODIFICATION OF MAY 12.2004 and JULY 13.2004 CUSTODY ORDERS TO THE HONORABLE, THE JUDGES OF THE SAID COURT: Jody M. Doyle, the Petitioner, hereby petitions this Honorable Court for modification of the May 12,2004 and July 13,2004 Custody Orders and respectfully represents that: 1. The Petitioner, Jody M. Doyle ("Petitioner"), resides at 4512 Newman Road, Fayetteville, PA 17222. 2. The Respondent is Michael W. Doyle ("Respondent") who resides at 185 Whitmer Road, Shippensburg, Pennsylvania 17257. 3. On May 12,2004 and July 13,2004, Orders of Court were entered pertaining to custody of Dylan 1. Doyle, born November 19, 1998, age six (6). True and correct copies of said Orders are attached hereto and marked as Exhibit "A" and Exhibit "B" respectively. 4. The Orders of Court dated May 12, 2004 and July 13,2004 should be modified because: a. Respondent has been unwilling to participate in or provide funding for Dylan's therapeutic counseling as set forth in Paragraph 4 of Exhibit <<B". b. Respondent has violated Paragraph 4 of this Court's May 12,2004 Order and as a result subject Dylan to a potentially harmful situation. c. Petitioner continues to be Dylan's primary caregiver and provider of emotional support; d. Petitioner is more likely to foster a relationship between the child and the other parent. 5. The Petitioner requests that the Orders of Court dated May 12, 2004 and July 13, 2004 be modified to grant Petitioner primary physical custody of Dylan subject to periods of temporary physical custody to Respondent as follows: a. Alternative weekends from Friday at 7:00 p.m. to Sunday at 7:00 p.m.; and b. Shared holidays. 6. The Petitioner requests that legal custody remain shared. 7. The best interests and permanent welfare of Dylan requires that the Court grant the Petitioner's request as set forth above WHEREFORE, Petitioner, lody M. Doyle, respectfully requests this Honorable Court to modify the May 12,2004 and July 13,2004 Orders of Court in accordance with the requests ofthe Petitioner set forth above. Respectfully submitted, ,~\?~ THOMAS P. GLEASON, ESQUIRE 95 Airport Road Shippensburg, P A 17257 (717) 729-2511 Supreme Court ID No. 82259 Attorney for Petitioner VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. ({Ji{ va vl/, JO~ ~OYLE ~r /J-/(f-o'l DATE MAY 0 e 2004 ~ MICHAEL W. DOYLE, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this /J-~ day of /Il"7f ' 2004, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Michael W. Doyle and the Mother, Jody M. Doyle, shall have shared legal custody of Dylan J. Doyle, born November 11, 1998. 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. 2. The parents shall have shared physical custody of the Child on a 5/5/2/2 alternating day schedule to coincide with Mother's work schedule. Father shall have the weekend of Friday, May 7 at 7:00 p.m. to Sunday, May 9, at 7:00 p.m. Thereafter Father's 2 day period shall begin on May 17 and 18. The alternating schedule shall continue as set forth above. 3. Transportation shall be shared as agreed by the parties. 4. Neither party shall consume alcohol immediately before or during their period of custody. 5. The parties shall cooperate with the Child's therapist and sign releases if necessary to facilitate the cooperation. 6. Both parties shall be entitled to liberal telephone contact with the Child. 7. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for July 6,2004 at 8:30 a.m. ~X\--\\Bl\, \.~ Ai' J. cc: Marcus A. McKnight, III, Esquire, Counsel for Father Jessica Diamondstone, Esquire, Counsel for Mother L- -"'" V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2004-1492 CIVIL TERM MICHAEL W. DOYLE, Plaintiff JODY M. DOYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None 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 Dylan J. Doyle November 11, 1998 Mother 2. A Conciliation Conference was held in this matter on May 6, 2004 with the following individuals in attendance: The Father, Michael W. Doyle, with his counsel, Marcus A. McKnight, III, Esquire and the Mother, Jody M. Doyle, with her counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. 3. The parties agreed to the entry of an Order in the form as attached. :;--&t -0 t.( Date O.~k~ Qne M. Verney, Esquire Custody Conciliator t) MICHAEL W. DOYLE, Plaintiff JUr 20M : IN THE COURT OF COMMON PLEAS OF : CIDIBERLAJ.~D COUNTY, PENNSYL V AJ.~IA V. : NO. 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NO'.V, this /3A day of ~ , 2004, upon consideration of the attached Custody ConcNiati':m Report, it is ordered and directed as follows: 1. The prior Order of Court dated May 12, 2004 shall remain in full force and effect with the following modifications and additions: 2. The Child shall be enrolled in Franklin County School District. 3. Transportation shall be shared. While the Child is in Father's custody during the school year, Father shall be responsible for transporting the Child to school and Mother shall be responsible for transponing the Child back to Father. 4. Due to the Child's occasional inappropriate behavior, Mother shall arrange for therapeutic family counseling. Both parties shall cooperate with said counseling, providing releases and participating when requested. 5. Holidays: A. ;,lother's Day/Father's Day. ~lother shall haYe physical custody 0f the Child on Mother's Day and Father shall have physical custody of the Child on Father's Day, at times agreed by the parties. B. Thanksgiving shall be alternated with Father having physical custody in even numbered years and Mother having physical custody in odd numbered years, at times agreed by the parties. C. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block. B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in even numbered years and Block B in odd numbered years. Father shall have Block A in odd numbered years and Block B in even numbered years. \::X M\ 13(\ \.\ (SlI 6. Each party shall be entitled to seven uninterrupted days in the summer, provided they give the other party 30 days prior notice. 7. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the proyisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Edward E. Guido, J. cc: Marcus A. McKnight, III, Esquire, Counsel for Father Jessica Diamondstone, Esquire, Counsel for Mother TRUE COPY FROM RECC'AU I.n T Gltimooy w.hor~. , here unto ~ my haoo and the seal of said ~,~ it carlisle, P'a. This /3 e- [\1Y 0$ ';-/!:!1 ' -f'~ 'f ~. (JY1~ () ~jfJ,. J.~' ProthonotltV JUL 1 0 2004 MICHAEL W. DOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2004-1492 CIVIL TERl\1 JODY M. DOYLE, Defendant : CIVIL ACTION - LA \V : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUlVIMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent infonnation concerning the Child who is the subj ect of this litigation is as follows: NAME DATE OF BIRTH CURRENTL Y IN CUSTODY OF Dylan J. Doyle November 11,1998 shared 2. A Conciliation Conference was held in this matter on July 8, 2004 with the following individuals in attendance: The Father, Michael W. Doyle, with his counsel, Marcus A. McKnight, III, Esquire and the Mother, Jody M. Doyle, \vith her counsel, Jessica DiamondslOne, Esquire, Mid Peml Legal S~r\"ices. 3. The Honorable Ed\vard E. Guido entered an Order of Court dated May 12, 2004 providing for shared legal and shared physical custody. 4. The parties agreed to the entry of an Order in the foml as attached. 1-t-()t Date ~e~;l~i Custody Conciliator CERTIFICATE OF SERVICE AND NOW, this 29th day of December, 2004, I, Thomas P. Gleason, Esquire, hereby certify that I have this day served a copy of the Petition for Modification upon Respondent's Attorney, Marcus A. McKnight, III, Esquire by first class mail to the following address: Marcus A. McKnight, III, Esquire 60 West Pomfret Street Carlisle, P A 17013 ~?~QUlRE 95 Airport Road Shippensburg, P A 17257 (717) 729-2511 Supreme Court ID No. 82259 Attorney for Petitioner ~~1D U'\ Y--cJf~ c:4 .-f) ., 1 \..}-J ~ C;'\. CJ d' (") ,..., 0 <::::) C = .1 .s::- ~~:, c;:I -I 1:)'"., rq fFiFJ il!f;i n ~~5::' -Om N :.'19 \.0 (.)' -~~ r~:> c; ::r- -1j <:: -0 --... ~ ... ........ Of") :yt.. J -,~ 7m '--0 c1 ~c.: N -... -7 .. "':, :::J 0 ~:J -< -< FEB 0 4 2005 y/ MICHAEL W. DOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY ~ ORDER OF COURT AND NOW, this ~ day of FtAJt-y , 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated May 12, 2004 and July 13, 2004 shall remain in full force and effect with the following modifications and additions: 2. In the event that either party is in need of babysitting service, the custodial parent shall notify the non-custodial parent and offer them the opportunity to care for the child. If necessary, in order to facilitate the available times and advance notice, the parties should exchange their work schedules one month in advance. 3. Father will attempt to call the child when Mother is at work. 4. The parties shall alternate years when they may declare the child as a tax deduction. Mother shall have even numbered tax years and Father shall have odd numbered tax years. 5. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual c:onsen1. In the absence of mutual consent, the terms of this Order shall control. Either party may contact the Conciliator in June, 2005 to schedule another Custody Conciliation Conference. C Edward E. Guido, cc:)\1'arcus A. McKnight, III, Esquire, Counsel for Father Jhomas P. Gleason, Esquire, Counsel for Mother .,~ -I!J!f~ oS O~)- -0.9.'- J. ". ..) t']J S'~~l 02: \ k'J " ::'...1 FEB 0 4 2005/ ~ MICHAEL W. DOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. 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 Dylan 1. Doyle November 11,1998 shared 2. A Conciliation Conference was held in this matter on February 3, 2005 with the following individuals in attendance: The Father, Michael W. Doyle, with his counsel, Marcus A. McKnight, III, Esquire and the Mother, Jody M. Doyle, with her counsel, Thomas P. Gleason, Esquire. 3. The Honorable Edward E. Guido entered Orders of Court dated May 12, 2004 and July 13, 2004 providing for shared legal and shared physical custody. 4. The parties agreed to the entry of an Order in the form as attached. ,7L-3-{)6 Date . I Ib~.o.P If. {~, JAcq line M. Verney, Esquire l Custody Conciliator MICHAEL W. DOYLE, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2004-1492 CIVIL TERM JODY M. DOYLE, DefendantJRespondent IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes the Petitioner, Michael W. Doyle, by his attorneys, Irwin & McKnight, and presents the following Petition for Modification of Custody. 1. The Petitioner, Michael W. Doyle, is an adult individual with an address of 185 Whitmer Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The Respondent, Jody M. Doyle, is an adult individual with an address of 4512 Newman Road, Fayetteville, Franklin County, Pennsylvania. 3. The parties are the natural parents of one (I) child, namely, Dylan J. Doyle, born November 11,1998. 4. The parties are currently governed by a custody Order of Court dated February 8, 2005, a copy of which is attached hereto and marked as Exhibit "An. 5. The Petitioner desires that the parties have shared legal custody of the minor child, Dylan J. Doyle. 6. The Petitioner desires primary physical custody of the minor child, Dylan J. Doyle, with periods of temporary physical custody to Respondent as the parties agree is in the best interest of said child. 7. The best interests and permanent welfare of the minor child requires that the Court grant the Petitioner's request as set forth above. WHEREFORE, Petitioner, Michael W. Doyle, respectfully requests that he be awarded primary physical custody and shared legal custody of Dylan J. Doyle, as provided herein, with periods of temporary physical custody to Respondent as provided herein. Respectfully submitted, By: Marcu A. MCKnight, III, Esquire Attorne for Plaintiff 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 Date: June 16,2005 r , . , n:s 0 4 LUllS yJ~ MICHAEL W. DOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY '" ORDER OF COURT AND NOW, this K day of F~ ,2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated May 12,2004 and July 13,2004 shall remain in full force and effect with the following modifications and additions: 2. In the event that either party is in need of babysitting service, the custodial parent shall notify the non-custodial parent and offer them the opportunity to care for the child. If necessary, in order to facilitate the available times and advance notice, the parties should exchange their work schedules one month in advance. 3. F ather will attempt to call the child when Mother is at work. 4. The parties shall alternate years when they may declare the child as a tax deduction. Mother shall have even numbered tax years and Father shall have odd numbered tax years. 5. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions ofthis Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Either party may contact the Conciliator in June, 2005 to schedule another Custody Conciliation Conference. Edward E. Guido, J. cc: Marcus A. McKnight, III, Esquire, Counsel for Father Thomas P. Gleason, Esquire, Counsel for Mother p '. fIB 0 4 Z005 j); ~ I MICHAEL W. DOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Dylan 1. Doyle November II, 1998 shared 2. A Conciliation Conference was held in this matter on February 3, 2005 with the following individuals in attendance: The Father, Michael W. Doyle, with his counsel, Marcus A. McKnight, III, Esquire and the Mother, Jody M. Doyle, with her counsel, Thomas P. Gleason, Esquire. 3. The Honorable Edward E. Guido entered Orders of Court dated May 12, 2004 and July 13,2004 providing for shared legal and shared physical custody. 4. The parties agreed to the entry of an Order in the form as attached. Oi. - 3 -0!J Date cq line M. Verney, Esquire Custody Conciliator VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. /1!f/H h ~' MICHAEL W. DOYLE Date: June 16, 2005 ~() ~ ..... v, ~ ~ ~ ~ ~ "', b'\ w ~~ 0\ (; I-h ~;:; :2~~ o " ..... I" ;11~~ :{j ""'"'D ,:>) -." n1 f'-' o r:_v C.J f'....J MICHAEL W. DOYLE PLAINTIFF IN THE COURT O,F COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 04-1492 CIVIL ACTlON LAW JODY M. DOYLE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, Juue 23, 2005 , upon consideration of the atlached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumherland County Courthouse, Carlisle on Tuesday. July 12, 2005 at 3:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made 10 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 lemporary 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 hearinl!:. FOR THE COURT. By: Isl ac ueline M. Verne Es Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of I990. 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 A TTORNEY AT ONCE. IF YOU DO NOT HA VE 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 .rri' ~ $p ~ ~ ~12. Jr:;,/}('.? ~~ ~ ~ ~~ SOht'-'l ~J4I P ~ ~ ~ -11l 5C?0e-~ , A.lNn,__:.'-:, .: (:~'-':~.c'~V'~nJ 91 :01 ~,IY +J21mr SOOZ AHlilONOrllO::iJ 3Hl :10 3:l!:HO{]311:l ~ECEIVED JUllS 2005 S MICHAEL W. DOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY ~ORDER OF COURT AND NOW, this dO day of \A , 2005, upon consideration of the attached Custody Co~ it is ordered and directed as follows: 1. The prior Orders of Court dated May 12,2004, July 13,2004 and February 8, 2005 are hereby vacated. 2. The Father, Michael W. Doyle, and the Mother, Jody M. Doyle, shall have shared legal custody of Dylan J. Doyle, born November 11, 1998. 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. The parties agree that Dylan will attend Shippensburg School District school for the 2005-2006 school year. 3. The parents shall have shared physical custody of the child to coincide with Mother's 5/2/2/5 work schedule. All transfers shall be at 7:00 p.m. Mother shall return the child the evening before she works and shall receive the child the evening of the last day of her work schedule. This arrangement shall begin Sunday, July 17,2005 at 7:00 p.m., which is the third day of mother's five day off period. 4. 1n the event that either party is in need of babysitting service, the custodial parent shall notifY the non-custodial parent and offer them the opportunity to care for the child. If necessary, in order to facilitate the available times and advance notice, the parties should exchange their work schedules one month in advance. 5. Transportation shall be shared as agreed by the parties. 6. The parties shall cooperate with the child's therapist and sign releases if necessary to facilitate the cooperation. 7. Both parties are entitled to liberal telephone contact with the child. 8. The parties shall alternate years when they may declare the child as a tax deduction. Mother shall have even numbered tax years and Father shaH have odd numbered tax years. 9. Holidays: A. Mother's Day/Father's Day. Mother shall have physical custody of the child on Mother's Day and Father shall have physical custody of the child on Father's Day, at times agreed by the parties. B. Thanksgiving shall be alternated with Father having physical custody in even numbered years and Mother having physical custody in odd numbered years, at times agreed by the parties. C. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at 12:00 noon to December 26, at 12:00 noon. Mother shall have Block A in even numbered years and Block B in odd numbered years. Father shaH have Block A in odd numbered years and Block B in even numbered years. 10. Each party shall be entitled to seven uninterrupted days in the summer provided they give the other party 30 days prior notice II. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Either party may contact the Conciliator within 90 days of this Order to schedule another Conciliation Conference. Edward E. Guido, J. cc: Marcus A. McKnight, III, Esquire, Counsel for Father Sean M. Shultz, Esquire, Counsel for Mother ~ (rnA; d,.< 1. .:l".1)5 C)-- " ~':':nJ I S :2 Hd 02 lr:r SGOZ AU\/..LC>JC:~-;:_Ud~ 3Hl :10 3Ji:UC}-CTr:I MICHAEL W. DOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Dylan J. Doyle November 11,1998 shared 2. A Conciliation Conference was held in this matter on July 12, 2005 with the following individuals in attendance: The Father, Michael W. Doyle, with his counsel, Marcus A. McKnight, III, Esquire and the Mother, Jody M. Doyle, with her counsel, Sean M. Shultz, Esquire. 3. The Honorable Edward E. Guido entered Orders of Court dated May 12, 2004, July 13, 2004 and February 8, 2005 providing for shared legal and shared physical custody. 4. The parties agreed to the entry of an Order in the form as attached. 1- (~-O~ Date , jlt.V~ / acq line M. Verney, Esquire d- Custody Conciliator MICHAEL W. DOYLE, Plaintiff r I" ~?'-l-,'i"'i-(T,,'~C"t ') i "\.J,,-"" ".__.,'.. ...,'/ ~ ,/ . ._0,. " ! I NOV 1 6 lOOS i I, (it' i J~~ 1 I : IN THE COURT OMMOI i FI:;EAS'OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-1492 CIVIL TERM JODY M. DOYLE, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 16th day of November, 2005, neither party having contacted the Conciliator to schedule another conciliation conference and 90 days have passed, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, , ,/ ., 1 j II, "l,l/)~~ ine M. Verney, Esquire, Cust~y Conciliator '\, ,r:' I ,.? I,',.J II" ",'J "n"7 ,J {;" _ it:",;' :::'JU0 :lU