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HomeMy WebLinkAbout08-6560SCOTT A. HAUNSTEIN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0 F- G S -Z6 L1J, I c ??, MERI E. HAUNSTEIN, CIVIL ACTION - LAW Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Scott A. Haunstein, residing at 424 Boxwood Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Meri E. Haunstein, residing at 120 East Penn Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks shared legal custody and physical custody of the following child: NAME Whitney M. Haunstein PRESENT RESIDENCE 120 East Penn Street Carlisle, Pennsylvania D.O.B. August 30, 2000 The child was not born out of wedlock. The child is presently in the custody of Defendant, who resides at 120 East Penn Street, Carlisle, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATE Scott A. Haunstein - Father 3843 Valley Road October 2001 to Meri E. Haunstein - Mother Marysville, Pennsylvania June 2005 Scott A. Haunstein - Father 1 Longwood Drive June 2005 to Meri E. Haunstein - Mother Mechanicsburg, Pennsylvania August 2008 Meri E. Haunstein - Mother 120 East Penn Street August 2008 to Carlisle, Pennsylvania Present The mother of the child is the Defendant, currently residing at 120 East Penn Street, Carlisle, Pennsylvania. She is married. The father of the child is the Plaintiff, currently residing at 424 Boxwood Court, Mechanicsburg, Pennsylvania. He is married. 4. The relationship of Plaintiff to the child is that of Father. The Plaintiff currently resides alone. 5. The relationship of Defendant to the child is that of Mother. The Defendant currently resides with the following person/persons: NAME RELATIONSHIP Whitney M. Haunstein daughter 6. 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. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff, Scott A. Haunstein, requests the court to grant shared legal and physical custody of the minor child, Whitney M. Haunstein, to him. Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: I I L4 - 0'9 By: mtto . o nne , Jr., Esqt 5615 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff VERIFICATION I, Scott A. Haunstein, 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. Section 4904 relating to unworn falsification to authorities. Date: l - y - 0 g .- colt A. Haunstein n C { ?1 Y Yep f N t 40 1 SCOTT A. HAUNSTEIN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-6560 CIVIL ACTION LAW MERI E. HAUNSTEIN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, November 10, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on _ Thursday, December 18, 2008_____ at 10:00 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/ ohn . Man an r. 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 ZS .Z did Z, owl ,5o- Cl ;sue ?f li v i:_v ?(_'3ZA A o SCOTT A. HAUNSTEIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-6560 CIVIL ACTION LAW MERI E. HAUNSTEIN, IN CUSTODY Defendant ORDER OF COURT AND NOW this Po' day of December 2008, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Scott A. Haunstein, and the Mother, Meri E. Haunstein, shall have shared legal custody of Whitney M. Haunstein, born 08/30/2000. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody: Mother shall have primary physical custody of the Child subject to Father's partial physical custody of the Child as follows: a. Father shall have physical custody of the Child two overnights between Monday and Friday every week, and if it fits the parties' schedules, specifically Tuesday and Thursday from after school or when Father gets off of work until the following morning dropping the Child off at school, Mother's residence or maternal grandmother's residence as agreed. b. Father shall have physical custody one weekend per month (his "corporate weekend") pursuant to his work schedule from Friday after school or when Father gets off of work until Sunday 6:30 pm, returning the Child to Mother's residence. Father has agreed to make all reasonable efforts to bring the Child to religious services on Sunday. Father shall also notify Mother at the earliest possible time of when his "corporate weekend" is so that arrangements may be made. Both parties have also agreed to be flexible in regard to any pre-planned activities that either parent has planned during Father's "corporate weekend", with the intent to ensure Father's periods of partial custody during his "corporate weekends" without interruption. Father shall also make all reasonable efforts to make sure that Whitney attends her social and extra-curricular activities that are scheduled during Father's "corporate weekend", to the extent said activities were planned prior to Mother's knowledge of Father's "corporate weekend". C. In the spring of 2009 when Mother has her educational classes, Father shall have custody of the Child every Monday from 5:00 pm until 7:00 pm, Father picking the Child up at day care and Mother shall pick the Child up when she is done with her classes. Father shall be responsible for transporting Whitney to any scheduled activities she has for this evening. FILL OF 7HE VP ' ARY 2008 DEC 30 AN 13.5! d. During any given month when Father has off from work on a Saturday or Sunday, Mother shall give favorable consideration for Father to have custodial time on this day if it is convenient for the parties' and the Child's schedule. e. The parties may alter this schedule by mutual agreement in the best interest of the Child. 3. Right of first refusal: In the event that the custodial parent should require a care- taker/babysitter (excluding regular day care and significant others) for the Child a period of time in excess of four hours, the custodial party shall first offer said opportunity to the non- custodial parent. 4. Counseling: The parties shall continue the Child in counseling. 5. Before either parent introduces the Child to their prospective significant other, the parents shall discuss with one another this issue and also discuss this issue with the Child's counselor(s). 6. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. 7. Holidays: a. Easter: Mother shall have Easter Day from 9:00 am until 2:00 pm. Father shall have from 2:00 pm until 8:00 pm. Should Father not be working the following Monday, his period shall run from Easter Day 2:00 pm until the following morning 10:00 am. b. Halloween: If trick or treat night is on the same night on both parents' neighborhoods, the parents shall both go with Whitney on this night. The parents shall alternate neighborhoods each year. c. Thanksgiving: Mother shall have custody Thanksgiving Day from 8:00 am until 2:00 pm. Father shall have from 2:00 pm until 8:00 pm unless he is not working the following day, whereby he shall have custody until 10:00 am Friday. d. Mother's and Father's Day: Each parent shall have physical custody of the Child from 9:00 am until 6:30 pm on their respective days. e. Christmas: For 2008, Father shall have custody on 12/22/08 for the day and on 12/23/08 for the day until 12/24 returning the Child to Mother in the morning. Father shall have custody of the Child 12/25/08 from 2:00 pm until 8:00 pm. Additionally, Father shall have custody of the Child from after work on 12/26/08 until 12/28/08 at 6:30 pm, dropping the Child off at Mother's residence. In subsequent odd years, Father shall have custody of the Child from 12:00 pm on 12/24 until 5:00 pm. Mother shall then have custody of the Child from 5:00 pm until 10:00 pm 12/24 delivering the Child to Father's residence whereby he shall have custody until 2:00 pm 12/25. Mother shall have from 2:00 pm 12/25 until 2:00 pm 12/26. In subsequent even years, Mother shall have custody of the Child at 2:00 pm on 12/24 until 2:00 pm 12/25. Father shall have from 2:00 pm 12/25 until 2:00 pm 12/26. f. New Year's: On 01/01/09, Father shall have custody from 1:00 pm until 01/2/09, dropping the Child off at Mother's before he goes to work. Thereafter, the parents shall alternate New Year's Eve on a repeating basis commencing with Father having New Year's Eve until New Year's Day from noon 12/31/09 until noon 01/01/10. g. If either parent is working during one of the scheduled holidays, the non-working parent shall have physical custody of the Child for that time period the parent is working. 8. Each parent shall have two non-consecutive weeks of vacation with the Child per year. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the parry first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 9. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 10. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 11. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 12. 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. By the Court, Distribution: A f Lindsay, Esquire g1nstine Brann, Esquire ?ohn J. Mangan, Esquire SCOTT A. HAUNSTEIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-6560 CIVIL ACTION LAW MERI E. HAUNSTEIN, IN CUSTODY Defendant CUSTODY CONCILIATION SUAEKARY REPORT IN ACCORDANCE W1TH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Whitney M. Haunstein 08/30/2000 Father and Mother 2. A Conciliation Conference was held with regard to this matter on December 18, 2008 with the following individuals in attendance: The Mother, Meri E. Haunstein, with her counsel, Carol Lindsay, Esq. The Father, Scott A. Haunstein, with his counsel, Christine Brann, Esq. 3. The parties agreed to the entry of an Order in the form as attached. 12.E Z3 tU ?Date John ai squire y nciliator Cus d ? C? SCOTT A. HAUNSTEIN PLAINTIFF IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-6560 CIVIL ACTION LAW n a `` 3 MCD rn MERI E. HAUNSTEIN Z rte- r 1N CUSTODY r DEFENDANT r-2-, C C7 y c-a ca --n ? ? ORDER OF COURT :;;c= w 2 C) AND NOW, Wednesday, July 06, 2011 upon consideration of the attache Compl aint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, August 12, 2011 at 2:30 PM _ ....... ---..-- ........ .--......... ........ .._...._ ............. 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 ofa 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/ John j. Manzan, Jr., Esq Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Oil Ann fo.1;Vled 7? V- 00 tv, '?71PW ?b p5 p ??0? 5 '"?? red /' t V4 i; 5 Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 eopeila1w 7/e/'/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT A. HAUNSTEIN VS. MERI E. HAUNSTEIN No. 2008-6560 ?.z M CIVIL ACTION - _ CUSTODY -<> r-= <d c_ c rv CIO -v PRAECIPE TO WITHDRAW/ENTER APPEARANCE ?o TO THE PROTONOTARY: r- off: Please Withdraw my appearance as counsel for the Defendant, Meri E. Haunstein in the above captioned case. Dated: , 16 , 2011 ,- CD By _Uk,?j Vol Carol L. Li ay, Esquire T Attorney 1D. # 34 R d 26 West High Street Carlisle, PA 1.7013-2922 Phone: (717) 243-6222 Please Enter my appearance as counsel for the Defendant, Meri E. Haunstein, in the above-captioned case. ?; XS anne . Griesf, Esquire Attorn D. #34362 129 E Market Street York, ennsylvania 17401 Phone: (717) 846-8856 sgriestaghhslaw. com GHtl?s HertnoLO, SCt1AUMANN, hHE LLP TIDRNEYs AT LAW 129 Eger MARKET $TREE'1' Y-, Pr--- 17401 /? 7Yt.M-E(717) 846-8856 Dated: /? , 2011. SCOTT A. HAUNSTEIN, Plaintiff V. MERI E. HAUNSTEIN, Defendant IN THE COURT OF COMMON PLEAS . CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6560 CIVIL ACTION - LAW IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN : ss. m C= - cnr- r , j Q? ---i c, zc:) - orn -1 7) C-11 AND NOW, this '1 day of August, 2011, personally appeared before me, a Notary Public in and for the State and County aforementioned, Christine Taylor Brann, Esquire, who, being duly sworn according to law, deposes and says that a copy of the Order scheduling a custody conference for Friday, August 12, 2011, at 2:30 p.m. was served on Defendant's counsel, Suzanne H. Griest, Esquire, via facsimile (717) 845-3330 and via regular mail to Griest, Himes, Herrold, Schaumann & Ferro, 129 E. Market Street, York, PA 17401-1221, on July 11, 2011. Sworn to and subscribed before me this day of August, 2011. n Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Maria B. LaRue, Notary Public Derry Twp., Dauphin County my Commission "res Nov. 8, 2013 Member, Pennsvlvania V-%Wation of Notaries p ?nx-' Christine Taylor Br 7K`uire SCOTT A. HAUNSTEIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-6560 CIVIL ACTION LAV?= ?-, MERI E. HAUNSTEIN, IN CUSTODY M cp Ts raw ?-i 1 C= Defendant cr,Z° -rJ a Prior Judge: Kevin A. Hess, P.J. ° f- ORDER OF COURT r AND NOW this !G + day of August 2011, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: Legal Custody: The Father, Scott A. Haunstein, and the Mother, Meri E. Haunstein, shall have shared legal custody of Whitney M. Haunstein, born 08/30/2000. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Each parent shall be kept informed of any scheduled events for Whitney, including but not limited to extra-curricular events, medical appointments and educational events. Neither parent shall sign Whitney up for activities without informing and receiving the consent of the other parent. Said consent shall not be unreasonably withheld. 2. Physical Custody: Mother shall have primary physical custody of the Child subject to Father's partial physical custody of the Child as follows: a. In week one, commencing 08/19/11, Father shall have physical custody of the Child from Friday until Monday morning. The parties shall transport the Child by agreement of the parties; however, Father has agreed to provide the majority of the transportation for his periods of custody. If there is no school on Monday, Mother has agreed to provide the transportation. b. In week two, Father shall have physical custody on Tuesday from after school until Wednesday morning and on Thursday from after school until Friday morning. C. Mother has agreed to, and shall, ensure that during her periods of custody, her current paramour shall not be the sole-caretaker of the Child (i.e. Mother, or some other appropriate adult shall always be present). d. The parties may alter this schedule by mutual agreement in the best interest of the Child. 3. Right of first refusal: In the event that the custodial parent should require a care- taker/babysitter (excluding regular day care and significant others) for the Child a period of U time in excess of four hours, the custodial party shall first offer said opportunity to the non- custodial parent. 4. Counseling: The parties shall continue the Child in counseling and/or mobile therapy. If recommended by the mobile therapist and/or treating professional, Father is to participate in Whitney's treatment. Before either parent introduces the Child to their prospective significant other, the parents shall discuss with one another this issue and also discuss this issue with the Child's counselor(s). 6. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. 7. Holidays: a. Easter: Mother shall have Easter Day from 9:00 am until 2:00 pm. Father shall have from 2:00 pm until 8:00 pm. Should Father not be working the following Monday, his period shall run from Easter Day 2:00 pm until the following morning 10:00 am. b. Halloween: If trick or treat night is on the same night on both parents' neighborhoods, the parents shall both go with Whitney on this night. The parents shall alternate neighborhoods each year. c. Thanksgiving: Mother shall have custody Thanksgiving Day from 8:00 am until 2:00 pm. Father shall have from 2:00 pm until 8:00 pm unless he is not working the following day, whereby he shall have custody until 10:00 am Friday. d. Mother's and Father's Day: Each parent shall have physical custody of the Child from 9:00 am Sunday until 9:00 am Monday (or to the beginning of school) on their respective days. Each shall be responsible for transportation on their respective days. e. Christmas: In odd years, Father shall have custody of the Child from 12:00 pm on 12/24 until 5:00 pm. Mother shall then have custody of the Child from 5:00 pm until 10:00 pm 12/24 delivering the Child to Father's residence whereby he shall have custody until 2:00 pm 12/25. Mother shall have from 2:00 pm 12/25 until 2:00 pm 12/26. In subsequent even years, Mother shall have custody of the Child at 2:00 pm on 12/24 until 2:00 pm 12/25. Father shall have from 2:00 pm 12/25 until 2:00 pm 12/26. f. New Year's: On 01/01/09, Father shall have custody from 1:00 pm until 01/2/09, dropping the Child off at Mother's before he goes to work. Thereafter, the parents shall alternate New Year's Eve on a repeating basis commencing with Father having New Year's Eve until New Year's Day from noon 12/31/09 until noon 01/01/10. g. If either parent is working during one of the scheduled holidays, the non-working parent shall have physical custody of the Child for that time period the parent is working. 8. Each parent shall have two non-consecutive weeks of vacation with the Child per year. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 9. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 10. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 11. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 12. A status conference is hereby scheduled for Tuesday November 15, 2011 at 9:00 am with the assigned conciliator at the Court of Common Pleas, Carlisle, PA. 13. 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. By the Court, ?j P.J. Distribution: Heather Reynosa, Esquire Christine Brann, Esquire ? John J. Mangan, Esquire 08'(x/(( QKB SCOTT A. HAUNSTEIN, Plaintiff V. MERI E. HAUNSTEIN, Defendant Prior Judge: Kevin A. Hess, P.J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-6560 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Whitney M. Haunstein 08/30/2000 Father and Mother 2. A Conciliation Conference was held with regard to this matter on December 18, 2008, an Order issued December 30, 2008 and a conference was held August 12, 2011 with the following individuals in attendance: The Mother, Meri E. Haunstein, with her counsel, Heather Reynosa, Esq. The Father, Scott A. Haunstein, with his counsel, Christine Brann, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date John J. an an, squire Custody C ciliator C_?, 4 SCOTT A. HAUNSTEIN, Plaintiff V. MERI E. HAUNSTEIN, Defendant Prior Judge: Kevin A. Hess, P.J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA r? v y j No. 08-6560 CIVIL ACTION LAq -- -' rn IN CUSTODY N c r V o C' _ 57 rv , ORDER OF COURT AND NOW this :7-Z" day of November 2011, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: Legal Custody: The Father, Scott A. Haunstein, and the Mother, Meri E. Haunstein, shall have shared legal custody of Whitney M. Haunstein, born 08/30/2000. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Each parent shall be kept informed of any scheduled events for Whitney, including but not limited to extra-curricular events, medical appointments and educational events. Neither parent shall sign Whitney up for activities without informing and receiving the consent of the other parent. Said consent shall not be unreasonably withheld. 2. Physical Custody: Mother shall have primary, physical custody of the Child subject to Father's partial physical custody of the Child as follows: a. In week one, commencing 11/14/11, Father shall have physical custody of the Child from Monday after school until Wednesday morning bringing Whitney to school, Mother shall then have from Wednesday until Sunday after church. Mother shall drop Whitney off at Father's after church Sunday to Father's residence and then Father shall drop Whitney back off to church Sunday 6:00 pm. Mother shall then have from Sunday after Whitney's church program until Monday morning. b. In week Iwo, Father shall have physical custody on Monday from after school until Wednesday morning to school, Mother from Wednesday after school until Friday morning and then Father shall have custody from Friday after school until Sunday morning dropping Whitney off at church 9:00 am. C. The parties may alter this schedule by mutual agreement in the best interest of the Child.. Monday Tuesday Wednesday Thursday Friday Saturday Sunday M D D D M M M __ M M D M D D F? M M M TD D D M 3. Right of first refusal: In the event that the custodial parent should require a care- taker/babysitter (excluding regular day care and significant others) for the Child a period of time in excess of four hours, the custodial party shall first offer said opportunity to the non- custodial parent. 4. Counseling: The parties shall continue the Child in counseling and/or mobile therapy. If recommended by the mobile therapist and/or treating professional, Father is to participate in Whitney's treatment. Additionally, the parties are strongly encouraged to engage in therapeutic family counseling, (with the focus on co-parenting), with a mutually agreed upon professional. The parties will select and set up said counseling within ten days of today's date. 5. Before either parent introduces the Child to their prospective significant other, the parents shall discuss with one another this issue and also discuss this issue with the Child's counselor(s). 6. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. 7. Both parents shall ensure that Whitney's school work is completed in a timely fashion and that Whitney arrives to school in an appropriate manner. Holidays: a. Easter: Mother shall have Easter Day from 9:00 am until 2:00 pm. Father shall have from 2:00 pm until 8:00 pm. Should Father not be working the following Monday, his period shall run from Easter Day 2:00 pm until the following morning 10:00 am. b. Halloween: If trick or treat night is on the same night on both parents' neighborhoods, the parents shall both go with Whitney on this night. The parents shall alternate neighborhoods each year. c. Thanksgiving: Mother shall have custody Thanksgiving Day from 8:00 am until 2:00 pm. Father shall have from 2:00 pm until 8:00 pm unless he is not working the following day, whereby he shall have custody until 10:00 am Friday. d. Mother's and Father's Day: Each parent shall have physical custody of the Child from 9:00 am Sunday until 9:00 am Monday (or to the beginning of school) on their respective days. Each shall be responsible for transportation on their respective days. e. Christmas: In odd years, Father shall have custody of the Child from 12:00 pm on 12/24 until 5:00 pm. Mother shall then have custody of the Child from 5:00 pm until 10:00 pin 12/24 delivering the Child to Father's residence whereby he shall have custody until 2:00 pm 12/25. Mother shall have from 2:00 pm 12/25 until 2:00 pm 12/26. In subsequent even years, Mother shall have custody of the Child at 2:00 pm on 12/24 until 2:00 pm 12/25. Father shall have from 2:00 pm 12/25 until 2:00 pm 12/26. f. New Year's: On 01/01/09, Father shall have custody from 1:00 pm until 01/2/09, dropping the Child off at Mother's before he goes to work. Thereafter, the parents shall alternate New Year's Eve on a repeating basis commencing with Father having New Year's Eve until New Year's Day from noon 12/31/09 until noon 01/01/10. g. If either parent is working during one of the scheduled holidays, the non-working parent shall have physical custody of the Child for that time period the parent is working. 9. Each parent shall have two non-consecutive weeks of vacation with the Child per year. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 10. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 11. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 12. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 13. 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. By the Court, e4 P.J. Distribution: Heather Reynosa, Esquire NP&11 / Christine Brann, Esquire John J. Mangan, Esquire SCOTT A. HAUNSTEIN, Plaintiff V. MERI E. HAUNSTEIN, Defendant Prior Judge: Kevin A. Hess, P.J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-6560 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Whitney M. Haunstein 08/30/2000 Father and Mother 2. A Conciliation Conference was held with regard to this matter on December 18, 2008, an Order issued December 30, 2008, a conference was held August 12, 2011, an Order issued Auggust 16, 2011 and a conference was held November 11, 2011 with the following individuals in attendance: The Mother, Meri E. Haunstein, with her counsel, Heather Reynosa, Esq. The Father, Scott A. Haunstein, with his counsel, Christine Brann, Esq. 3. The parties agreed to the entry of an Order in the form as attached. // ",/ 111?f 4/ Date John J. , squire Custod C nciliator