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Home My WebLink About09-1668Mindy S. Goodman, Esquire Attorney ID No. 78407 2215 Forest Hills Drive Suite 35 Harrisburg, PA 17112 (717) 540-8742 ADAM BROWNLEY, Plaintiff, V. ASHLEY POLAND, Defendant THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O''- A 6,? Curl CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, ADAM C. BROWNLEY, by and through his attorney, Mindy S. Goodman, and avers the following: 1. Plaintiff is an adult individual currently residing at 72 Woodview Road, Biglerville, Cumberland County, Pennsylvania. 2. Defendant is an adult individual currently residing at 140 Old State Road, Gardners, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant are the natural parents of one minor child whose name and date of birth are as follows: TRAE WILLIAM BROWNLEY DoB November 12, 2006 4. The minor child is currently living with his father, Plaintiff, at the address identified above. 3 5. The parties have lived at the following addresses since the child's birth: a. 305 Middour Avenue, Fayetteville, Pennsylvania; b. 140 Old State Road, Gardners, Pennsylvania; C. 72 Woodview Road, Biglerville, Pennsylvania. 6. Defendant is the natural mother of two other children, Brianna Eiker and Dylan Eiker, who have been living with the parties at the above-identified addresses. 7. The natural mother and natural father are not married and the minor child was bom out of wedlock. 8. Plaintiff is seeking primary legal and primary physical custody of the minor child and asserts that the best interest and permanent welfare of the minor child will be served by granting the relief requested for the following reasons (Plaintiff is also very concerned about the safety and welfare of the other minor children and would assume custody of Brianna Eiker and Dylan Eiker, but Plaintiff is uncertain whether he has standing to do so): a. Plaintiff believes that Defendant is involved with the sale and use of illegal drugs and has placed the child in harm's way. b. Although she is not working, Defendant has been unable to do basic housekeeping, cooking and caring for the minor child. 4 C. Plaintiff feeds the minor child, bathes the minor child, and provides for all of the minor child's most basic needs, emotionally, physically and financially. d. On or about December 3, 2008, Defendant was arrested for driving a vehicle involved in the sale and delivery of drugs, as a result of which her vehicle was seized and impounded. e. On or about December 12, 2008, Defendant had a motor vehicle accident with the minor child in the vehicle. The vehicle was demolished. Both Defendant and the minor child were treated at the hospital and released. f. Later that same month, the exact date is unknown, Defendant is in a second motor vehicle accident. No children were in the vehicle, and this second vehicle was demolished. g. On or about January 11, 2009, Defendant was in another motor vehicle accident, Plaintiff is uncertain whether any children were in the vehicle. h. On or about February 23, 2009, Plaintiffs mother (the maternal grandmother) received a letter from David Eiker, the father of Defendant's other two children, indicating that Defendant is involved with the sale of drugs and engaging in the usage of drugs (a copy of the letter is attached hereto as Exhibit A). 5 i. On or about March 9, 2009, Defendant was involved in another motor vehicle accident with the minor child in the car. There was major damage to the vehicle, but no one was injured. However, the minor child handed Plaintiff a piece of glass that he found in his sweatshirt after the accident and upon his return home to Plaintiff. Plaintiff then searched the child and found additional pieces of glass on the minor child that had not been cleaned and/or removed by Defendant. j. Later that same night, on or about March 9, 2009, Defendant is involved in a fifth motor vehicle accident, after which Defendant was taken to the police station for questioning. This accident resulted in a third vehicle being demolished within a three-month period. k. On or about March 10, 2009 there was a report made to an insurance carrier that the second accident involving Defendant on March 9, 2009 resulted in a hit and run. Defendant was arrested and was requested to provide samples for blood and urine tests; however, Plaintiff is uncertain of the results of those tests. 1. After the accidents that occurred on March 9, 2009, Plaintiff separated from Defendant and Defendant repeatedly threatened Plaintiff that he would never see his child again. M. On or about March 11, 2009, Defendant requested her mother to come to Pennsylvania and take Defendant and all three of her children to North Carolina. n. As a result of Defendant's threats to remove the child from the Commonwealth of Pennsylvania coupled with the earlier threat that Plaintiff would never see his child again, Plaintiff took custody of the child and has vacated the residence once shared by Plaintiff and Defendant. o. Plaintiff is uncertain whether Defendant has left for North Carolina with her mother and the other children, but is under the impression that Defendant leaving for North Carolina would be a violation of the terms of her bail. p. Plaintiff provides the best opportunity for the minor child to grow physically, emotionally and spiritually. 8. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. WHEREFORE, the Plaintiff respectfully requests Your Honorable Court to grant him primary legal custody and primary physical custody of TRAE WILLIAM BROWNLEY, subject to periods of partial custody with Defendant. Respectfully submitted, Mindy S. Goodman, Esquire Attorney for Plaintiff 7 VERIFICATION I have reviewed the contents of the foregoing Complaint for Custody. I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. j,. Adam Br nle , Plaintiff It Mar 09 r,9:4- ?,a 8EC'. CY Ski" !TH STATE FARM I Post-its Fax Mote ie # 7671 I Date -r u3 Co. Phone !I Fax ti Y _. r ._ V-N j 1 \ r? ti m°vn MCA QFZ a •% i f ?i P' l .'lA V?iL 6 ' ? r ; s ?r t 'i r p Mar 09 09:4Sa °F.''CY S."VI TY' STATE FARM I R' ?<. _. j? e, -i - - J' cr.Ja?c _5 _ _ ------- --- - - iviar i -t vi u9:458 BECKY SMITH STATE FARM 1 e- 0 07 rfr .:! _D..C2_ _ G/-•'."li? '? <-. ??J _i G'? ??'./?.__G?a-!?'?l-?-f?'-"4'?--+- -- ?GC.t?.__.. GQ_'??iT._J „?_p_'«'.??, ?G+!-r.? 70 t :%t1'?,L?i G,?y? _ _ T.r"v.?2 .. . `<.71??/,_ .'13?f- r? .._ ._ _ -?-.._.C?'?. ?? .? _ _c?•'7,:5.__G-? _?_?.,,?";?? _. .00 w ? ? o qK? (? U Ce 0 -_j +z. m r??- ADAM BROWNLEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ASHLEY POLAND DEFENDANT • 2009-1668 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, March 20, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 02, 2009 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR. THE COURT, By: /s/ ac ueKne 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 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 ?AS 8VW 690Z -ft APR 0 3 2008 r, ADAM BROWNLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND ZCIVIL OUNTY, PENNSYLVANIA V. : NO. 2009-1668 ACTION - LAW ASHLEY POLAND, Defendant : IN CUSTODY ASHLEY RENEE POLAND, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-1675 CIVIL ACTION - LAW ADAM BROWNLEY, Defendant IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this y of , 2009, upon consideration of the attached Custody Conciliation eport, it is ordered and directed as follows: The prior Order of Court dated March 19, 2009 is hereby vacated. 2. The dockets in this matter are hereby consolidated. 3. The Father, Adam Brownley and the Mother, Ashley Poland, shall have shared legal custody of Trae William Brownley, born November 12, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 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 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor cluid. Lach parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each j? w parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 4. Father shall have supervised visitation with the child in accordance with an Adams County Children & Youth Services Safety Plan. The supervisors shall be Sally or Brandon Showers. Father shall have supervised visitation when Mother does not. 5. Mother shall have supervised visitation with the child in accordance with an Adams County Children & Youth Safety Plan. The supervisor shall be her sister. Mother's periods of supervised visitation shall be from Friday at 5:00 p.m. to Sunday at 5:00 p.m. 6. Transportation shall be shared such that the relinquishing party shall transport. Exchanges shall be accomplished by third parties. 7. No one is to remove the child from the jurisdiction of either Adams County or Cumberland County. 8. Neither party may partake in alcohol to the point of intoxication or use illegal drugs immediately before or during their period of visitation. 9. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. A telephone conference shall be held on Thursday, April 9, 2009 at 12:00 p.m. cc: Mindy Goodman, Esquire, Counsel for Father race D'Alo, Esquire, Mid Penn Legal Services, Counsel for Mother co ? 'Qc.S ?7.7. t l-CCL Arr mfr °.' n"CC'v i, Z2, i:F,?irSLr N 0 ADAM BROWNLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-1668 CIVIL ACTION - LAW ASHLEY POLAND, Defendant : IN CUSTODY ASHLEY RENEE POLAND, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-1675 CIVIL ACTION - LAW ADAM BROWNLEY, Defendant : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, P.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 Trae William Brownley November 12, 2006 Father 2. A Conciliation Conference was held in this matter on April 2, 2009, with the following in attendance: The Father, Adam Brownley, with his counsel, Mindy Goodman, Esquire, and the Mother, Ashley Poland, with her counsel, Grace D'Alo, Esquire, Mid Penn Legal Services. 3. A prior Order of Court was entered by the Honorable Edgar B. Bayley at Docket No. 09-1675, dated March 19, 2009 referring the Mother's Petition for Special Relief to the Conciliator. 4. The parties agreed to an Order in the form as attached. y - z -0q ?Veit?,uire?? Date ac eline M. Custody Conciliator AM 13 2009 ? ADAM BROWNLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-1668 " CIVIL ACTION - LAW ASHLEY POLAND, Defendant : IN CUSTODY ASHLEY RENEE POLAND, Plaintiff V. ADAM BROWNLEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-1675 CIVIL ACTION - LAW : IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this day of i4"L , 2009, upon consideration of the attached Custody Conciliation eport, it is ordered and directed as follows: The prior Order of Court dated April 6, 2009 shall remain in full force and effect with the following modifications. 2. The requirement that Father's periods of physical custody be supervised is hereby vacated. 3. Mother shall have periods of supervised visitation on alternating weekends beginning April 24, 2009 provided her grandmother, Peggy Dively, supervises the visits. 4. This Order is entered pursuant to an agreement of counsel for 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. A telephone conference shall be held on Thursday, April 16, 2009 at 12:00 p.m. cc? Goo( n Hooper, man, Esquire, Counsel for Father Esquire; MidPenn Legal Services, Counsel for Mother 4 w. t'+? r ;,? C% ??: ? ?? ` a i f 'APR 1s 2oD9 ADAM BROWNLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-1668 CIVIL ACTION - LAW ASHLEY POLAND, Defendant : IN CUSTODY ASHLEY RENEE POLAND, Plaintiff- V. ADAM BROWNLEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-1675 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, P.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 Trae William Brownley DATE OF BIRTH November 12, 2006 CURRENTLY IN CUSTODY OF Father 2. A telephone conference was held in this matter on April 9, 2009, with the following: Father's counsel, Mindy Goodman, Esquire, and Mother's counsel, Ben Hooper, Esquire, MidPenn Legal Services. 3. A prior Order of Court was entered by the Honorable Edgar B. Bayley dated April 6, 2009 providing for shared legal custody, and both parents having supervised visitation pursuant to a safety plan from Adams County Children & Youth Services. 4. Counsel for the parties agreed to an Order in the form as attached. 1/ 14, 1/?44 Date acq ine M. Verney, Esquire Custody Conciliator APR 2 0 Z0 ;;zl og6 ADAM BROWNLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND C LINTY, PENNSYLVANIA V. : NO.2009-1668 CIVIL ACTION -LAW ASHLEY POLAND, Defendant : IN CUSTODY ASHLEY RENEE POLAND, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-1675 CIVIL ACTION - LAW ADAM BROWNLEY, Defendant IN CUSTODY ORDER OF COURT AND NOW, this Z1 day of A,M , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated April 6 and 13, 2009 shall remain in full force and effect with the following modifications. 2. Father shall have primary physical custody of the child. 3. Beginning April 19, 2009, Mother shall have periods of supervised visitation every Sunday for at least one hour or longer in accord with Adams County Children & Youth safety plan regarding Mother's other children. The supervisor shall be grandmother, Peggy Dively. Mother shall have such other times as agreed by the parties. 4. This Order is entered pursuant to an agreement of counsel for 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. ccoX indy Goodman, Esquire. Counsel for Father „ Ilene Hockensmith, Esquire, MidPenn Legal Services, Counsel for Mother .,mss: APR 2 0 2009 ADAM BROWNLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-1668 CIVIL ACTION - LAW ASHLEY POLAND, . Defendant : IN CUSTODY ASHLEY RENEE POLAND, Plaintiff V. ADAM BROWNLEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-1675 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, P.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 Trae William Brownley November 12, 2006 Father 2. A telephone conference was held in this matter on April 16, 2009, with the following: Father's counsel, Mindy Goodman, Esquire, and Mother's counsel, Arlene Hockensmith, Esquire, MidPenn Legal Services. 3. Prior Orders of Court were entered by the Honorable Edgar B. Bayley dated April 6, and 13, 2009 providing for shared legal custody, with Father having unsupervised custody and Mother having supervised visitation pursuant to a safety plan from Adams County Children & Youth Services. 4. Counsel for the parties agreed to an Order in the form as attached. ?- Date qu ine M. Verney, Esquire Custody Conciliator ADAM BROWNLEY Plaintiff V. ASHLEY POLAND Defendant ASHLEY RENEE POLAND Plaintiff V. ADAM BROWNLEY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 -1668 CIVIL ACTION -LAW IN CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 -1675 CIVIL ACTION -LAW IN CUSTODY o n ? CUSTODY STIPULATION 4 -O t . o c u AND NOW, third ay of December, 2010, comes ASHLEY RENEE- r o-n a c, POLAND and ADAM BROWNLEY and enter into this Custody Stipulation :, < Q' ..c WHEREAS, ASHLEY RENEE POLAND (hereinafter referred to as "Mother") and ADAM BROWNLEY (hereinafter referred to as "Father") are the natural parents of one (1) minor child: TRAE WILLIAM BROWNLEY (hereinafter sometimes referred to as "TRAE"), born November 12, 2006; and WHEREAS, the child was born out of wedlock, and Mother and Father are no longer together, and have been living separate and apart; and WHEREAS, pursuant to an Order of Court dated April 27, 2009, Father was granted primary physical custody of Trae with Mother having periods of supervised visitation every Sunday for at least one hour or longer, with grandmother, Peggy Dively, serving as the visitation supervisor; and WHEREAS, circumstances have arisen such that Father will not able to exercise primary physical custody of the minor child; and WHEREAS, Mother is currently incarcerated and not able to exercise her period of supervised visitation; and WHEREAS, the Mother and Father have reached an agreement concerning the custody of their minor child and desire to put the terms and conditions of the agreement into writing. AND NOW THEREFORE, the parties hereto, stipulate and agree as follows: LEGAL CUSTODY 1. Paternal grandmother, Brenda Sue Roberts (hereinafter sometimes referred to as "Paternal Grandmother") of 72 Woodview Road, Biglerville, Adams County, Pennsylvania 17307, shall have legal custody of the minor child, Trae William Brownley. Ms. Roberts shall have the power and authority to make all decisions affecting the child's growth and development, including, but not limited to: authorizing and approving medical and dental treatment, school and church enrollment. Ms. Roberts agrees to keep Mother and Father informed of the child's educational and social progress. 2. Mother and Father shall be entitled to complete and full information from any doctor, dentist, teacher or authority and have copies of any reports given. Such documents include, but are not limited to, medical reports, academic and school report cards, birth certificates, etc. PHYSICAL CUSTODY 3. Paternal Grandmother, Brenda Sue Roberts, shall have primary physical custody of Trae. 4. Upon her release from the Work Release Center, Mother shall have periods of supervised visitation every Sunday for at least one hour or longer in accord with Adams County Children & Youth safety plan regarding Mother's other children. It is anticipated that the supervisor of the visitation will be Peggy Dively or Paternal Grandmother, Brenda Sue Roberts. 5. Father shall have periods of partial physical custody as agreed upon by the parties, and as his circumstances dictate. It is anticipated that Father's periods of partial custody will be exercised at Paternal Grandmother's residence. 6. Either parent, or the grandparents, may have additional periods of physical custody as agreed upon. 7. The parents agree that the custody schedule set forth above may be temporarily modified based on necessity and agreement of the parties. TELEPHONE ACCESS 8. Mother, Father and Paternal Grandmother shall have reasonable telephone access to Trae while he is not in their custody. "Reasonable access" shall be considered, at a minimum, weekly telephone contact. EFFECT ON PRIOR ORDERS OF COURT 9. This Custody Stipulation and Order of Court shall supersede and replace any and all prior Orders of Court regarding the Custody of Trae William Brownley. The terms and conditions of this Custody Stipulation shall remain in full force and effect until such time as another Order of Court is entered. ENTRY AS A COURT ORDER 10. The parents agree that this Custody Stipulation shall be submitted to the Court for entry as an Order of Court. With the intent of being legally bound hereby, the parties hereto set their hands and seal the day and year first above written. -.4. 2 11 Witness cj-g- Witness i A/ SHLEY E POLAND i ADAM BROWNLEY : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 -1668 X ASHLEY POLAND CIVIL ACTION -LAW Defendant IN CUSTODY ASHLEY RENEE POLAND : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYL VAN IA V. N0.2009 - 1675 C= C= c:> -? --j . ' r ADAM BROWNLEY CIVIL ACTION -LAW te Defendant IN CUSTODY Co ORDER OF COURT" -< co AND NOW, this day of 2011, upon consideration of the attached Custody Stipulation, it is hereby ORDERED and DECREED that the terms and conditions of custody of Trae William Brownley shall be as follows: LEGAL CUSTODY 1. Paternal grandmother, Brenda Sue Roberts (hereinafter sometimes referred to as "Paternal Grandmother") of 72 Woodview Road, Biglerville, Adams County, Pennsylvania 17307, shall have legal custody of the minor child, Trae William Brownley. Ms. Roberts shall have the power and authority to make all decisions affecting the child's growth and development, including, but not limited to: authorizing and approving medical and dental treatment, school and church enrollment. Ms. Roberts agrees to keep Mother and Father informed of the child's educational and social progress. 2. Mother and Father shall be entitled to complete and full information from any doctor, dentist, teacher or authority and have copies of any reports given. Such documents include, but are not limited to, medical reports, academic and school report cards, birth certificates, etc. PHYSICAL CUSTODY 3. Paternal Grandmother, Brenda Sue Roberts, shall have primary physical custody of Trae William Brownley. 4. Upon her release from the Work Release Center, Mother shall have periods of supervised visitation every Sunday for at least one hour or longer in accord with Adams County Children & Youth safety plan regarding Mother's other children. It is anticipated that the supervisor of the visitation will be Maternal Grandmother, Peggy Dively or Paternal Grandmother, Brenda Sue Roberts. 5. Father shall have periods of partial physical custody as agreed upon by the parties, and as his circumstances dictate. It is anticipated that Father's periods of partial custody will be exercised at Maternal Grandmother's residence. 6. Either parent, or the grandparents, may have additional periods of physical custody as agreed upon. 7. The parents agree that the custody schedule set forth above may be temporarily modified based on necessity and agreement of the parties. TELEPHONE ACCESS 8. Mother, Father and Paternal Grandmother shall have reasonable telephone access to Trae while he is not in their custody. "Reasonable access" shall be considered, at a minimum, weekly telephone contact. EFFECT ON PRIOR ORDERS OF COURT 9. This Custody Stipulation and Order of Court shall supersede and replace any and all prior Orders of Court regarding the Custody of Trae William Brownley. The terms and conditions of this Custody Stipulation shall remain in full force and effect until such time as another Order of Court is entered. BY THE COURT, DiMtribution• Prothonotary (original) ? Joseph L. Hitchings, Esquire ?Adam Brownley, 72 Woodview Road, Biglerville, PA 17307 ?Ashley Renee Poland, 45 Major Bell Lane, Gettysburg, PA 17325-8265 AA .led IPs M ?I ?' 11a41 66 1