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HomeMy WebLinkAbout09-5395JAMIE MICHAEL STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 09- 33 9-!r CIVIL TERM LAURA JEAN STINE, Defendant : CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Jamie Michael Stine, hereinafter referred to as Father. Father resides at 153 East Louther Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Laura Jean Stine, hereinafter referred to as Mother. Mother's current place of residence is unknown. Mother's last known address is believed to be 811 Gobin Drive Carlisle, Cumberland County, Pennsylvania, 17013. 3. Father seeks partial physical custody of the minor child: Name Present Residence Age Jacob Michael Stine Unknown 10/28/04 DOB, 4 years old Jacob Michael Stine was born October 28, 2004 during the parties' marriage. Jacob is presently in the physical custody of Mother. The parties were divorced on November 16, 2007. During his lifetime, Jacob has resided at the following addresses: Name Address Date Jamie Michael Stine 167 N. West Street Birth to early Laura Jean Stine Carlisle, PA 17013 November 2004 Michael Stine Jamie Michael Stine 13 Northview Drive Early November 2004 to Laura Jean Stine Carlisle, PA 17013 November 20, 2004 Jamie Michael Stine Safe Harbor November 20, 2004 to Laura Jean Stine 102 W. High Street early December 2004 Carlisle, PA 17013 Mr. Benson 64 Willow Mill Park Road Early December 2004 to Mrs. Benson Carlisle, PA 17013 end of December 2004 3 Benson children Jamie Michael Stine Laura Jean Stine Bill Yufer 811 Gobin Drive January 2005 to Jean Yufer Carlisle, PA 17013 May 2005 Jamie Michael Stine Laura Jean Stine Michael Stine Jamie Michael Stine 13 Northview Drive May 2005 to Laura Jean Stine Carlisle, PA 17013 September 4, 2005 Bill Yufer 811 Gobin Drive September 4, 2005 to Jean Yufer Carlisle, PA 17013 unknown Laura Jean Stine Laura Jean Stine Safe Harbor Unknown 102 W. High Street Carlisle, PA 17013 Laura Jean Stine Unknown Unknown 4. Father currently lives with the following persons: Name Relationship Mandy Lynn Stine Spouse 5. It is unknown with whom Mother lives at present but when at her last known address, it is believed that Mother lived with the following persons: Name Bill Yufer Jean Yufer Relationship Father Mother 6. On September 26, 2005, Father filed a Complaint in Custody that was dismissed without prejudice by the Honorable Edgar B. Bayley, Judge President, on October 18, 2005, after Father's Motion to Dismiss. 7. As part of a Protection from Abuse Order entered by the Honorable Edgar B. Bayley, Judge President, on April 2, 2007, Father has visitation with Jacob on Tuesdays. See attached Plaintiff's Exhibit "A". 8. Father has attempted to reinstate visits with Jacob in accordance with the April 2, 2007 Order, but was not successful. 9. Father has no information of any pending custody proceeding concerning Jacob in a court of this Commonwealth. 10. Father does not know of a person not a party to the proceedings who has physical custody of Jacob or claims to have custody or visitation rights with respect to Jacob. 11. Jacob's best interest and permanent welfare will be served by granting the relief requested for reasons including, but not limited to the following: a. Prior to Jacob's birth, Father was actively involved with doctor appointments and other prenatal care during Mother's pregnancy. b. While the parties were together for the first years of Jacob's life, Father shared equally in the caretaking responsibilities for Jacob. Father also provided for Jacob's emotional, financial, physical, educational, and medical needs including establishing a stable home environment for Jacob. c. Despite the end of the relationship between Father and Mother, Father has tried to maintain contact with Jacob and develop a father/son relationship with Jacob. d. Father lives in a home that is a safe and nurturing environment in which to exercise periods of partial custody with Jacob. e. Father has all the necessary items to care for Jacob during periods of partial custody. f. Father is willing and able to care for Jacob during periods of partial custody and he is committed to establishing and nurturing a healthy father/son relationship with Jacob. g. Jacob will have access to other family members when in Father's care including, his grandmother Lisa Donivan, his great grandfather, Gus Stine, and his great uncle Michael. Stine. h. Father is willing to communicate with and work cooperatively with Mother to co- parent Jacob and will encourage their mother/son relationship. 12. Mother has not acted in Jacob's best interests in ways including but not limited to the following: a. Mother has not allowed Jacob to see Father despite the fact that Father has established a safe and suitable residence. Mother's actions are in violation of the custody provision within the April 2, 2007 Protection from Abuse Order which allows Father to have custodial visitation with Jacob. b. Mother has deliberately acted in a manner to interfere with, if not prohibit, Father from establishing a healthy father/son relationship with Jacob. 13. Every person with rights to custody or having actual physical custody of Jacob has been named as parties to this action. WHEREFORE, Father requests this Court to grant him the following relief: 1. Grant the parties shared legal custody of Jacob. 2. Grant Father periods of partial custody with Jacob. 3. Grant Mother primary physical custody of Jacob. 4. Allow the non-custodial parent to have reasonable telephone contact with Jacob while he is with the other parent. 5. Establish an appropriate holiday schedule so that both parents can spend time with Jacob during various holidays. 6. Prohibit both parties from consuming alcohol to the point of intoxication or using illegal drugs when Jacob is in their custody and preclude the parties from allowing Jacob to be exposed to persons who have been consuming alcohol to the point of intoxication or using illegal substances. 7. Any other relief this Court finds to be just and proper. bmitted, ,ky, Esquire Services Suite K3 401 Mast Louther Street Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named PLAINTIFF, Jamie Michael Stein, verifies that the statements made in the above COMPLAINT FOR CUSTODY are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: ?? b ????'? Y " L - '94bw- Jamie Michael Stein JAMIE MICHAEL STINE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 09- CIVIL TERM LAURA JEAN STINE, Defendant CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Noemi V. Lopez, do hereby swear that I served Laura Jean Stine, with a Complaint For Custody on August 3, 2009 by certified mail, return receipt, restricted delivery, to the person and addresses below: Laura Jean Stine 811 Gobin Drive Carlisle, PA 17013 I, Noemi V. Lopez, verify that the statements made in this Affidavit of Service 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: U Signature: 4V-L TFP AUG 0 5 2009 JAMIE MICHAEL STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 09- 53g5 CIVIL TERM LAURA JEAN STINE, Defendant : CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Jamie Michael Stine, Plaintiff, to proceed in forma au eris. I, Abraham Prozesky, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party- r Abrahafn Pro y, Esquire MidPen gal Services 401 Ea Louther Street Suite 10 Carlisle, PA 17013 (717) 243-9400 ltf?4 k?fU - t"yi ??? JAMIE MICHAEL STINE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURA JEAN STINE DEFENDANT 2009-5395 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, August 12, 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, September 10, 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/ Jacqueline M Verney LEsq 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 r ? ?-: t?7 1 ? r; , ? ,. (? it f': ? .:. i :'q a ? /a may' ??`- ?? ??.. ? ?S. Jamie Michael Stine, Laura Jean Stine, v Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - 5395 : IN CUSTODY CIVIL TERM - LAW MOTION FOR CONSOLIDATION Plaintiff, Jamie Michael Stine, by and through his attorneys, MidPenn Legal Services, move the Court for an Order consolidating two (2) docket numbers into one on the grounds that: 1. A Complaint for Custody, Docket 2005-5034, was entered on September 26, 2005 by Judge Bayley. 2. Parties reconciled and on October 18, 2005 Judge Bayley entered an Order dismissing the Complaint in Custody without prejudice to either party, after the Plaintiff had withdrawn the Complaint. 3. A Complaint for Custody, Docket No. 2009-5395 was entered August 3, 2009, and scheduled for conciliation with Conciliator Jacqueline M. Verney, Esq. 4. Plaintiffs counsel was contacted by the Court Administrators and asked to file a Motion to Consolidate the two (2) dockets numbers. Wherefore, Plaintiff requests that Docket No. 2009-5395 be consolidated with Docket No. 2005-5034, and that Docket No. 2005-5034 be the only identifying docket for the custody matter. Respectfully submitted, MIDPENN LEGAL SERVICES Date: By: v v Abraham rozesl ttornev for Plaintiff Services 401 East r Street, Suite 103 MidPenn rA17013 Carlisle, (717) 243-9400 w VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S.§4904, relating to unsworn falsification to authorities. ?? .. •l .• Dated: q/`f l p f Jamie Michael Stine, Plaintiff Cad C?,5 eo,v-a? PLOL t6cct ot J--'Vrl Ai? s oqp( p % SEP 0 9 2009 2 Jamie Michael Stine, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V NO. 2009-5395 CIVIL TERM - LAW Laura Jean Stine, : Defendant IN CUSTODY ORDER FOR CONSOLIDATION AND NOW, this I.- day of September, 2009, upon consideration of the attached Motion for Consolidation, the Docket No. 2009-5395 shall be consolidated with Docket No. 2005-5034 and the custody matter will be identified by Docket No. 2005-5034. .stribution MidPenn Legal Services 401 E Louther Street Carlisle PA 17013 J" g Q`? FLED-OFACE OF THE PRCTI O ,K"JTARY 2009 SEP -9 PM 3: 0 2 CUM r:3LA rY' PENNSYLVANIA is SEP 14 2009 JAMIE MICHAEL STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-5395 ? CIVIL ACTION - LAW LAURA JEAN STINE, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 01 day of , 2009, upon _(?D 01A/ consideration of the attached Custody Concilia ion Report, i is rdered and directed as follows: 1. The custody provision in the Order of Court dated April 2, 2007 at docket number 05-4792 is hereby vacated. 2. The Father, Jamie Michael Stine and the Mother, Laure Jean Stine, shall have shared legal custody of Jacob Michael Stine, born October 28, 2004. 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 child. Each 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 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. 3. Mother shall have primary physical custody. 4. Father shall have the following periods of partial physical custody: A. Every Friday from 3:00 p.m. to 7:00 p.m. s B. Every Saturday from 9:00 a.m. to 12:00 noon. 5. Transportation shall be shared such that the parties shall exchange custody at St Paul's Church in Carlisle. 6. Both parties shall only transport the child in a vehicle with an approved and properly installed car seat or booster seat. 7. Neither party shall use illegal drugs nor permit the child to be exposed to illegal drugs, nor partake in alcoholic beverages to the point of intoxication while the child is in their physical custody. 8. Neither party may do or say anything nor permit a third party from doing or saying anything which may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 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. Another Custody Conciliation Conference is scheduled for November 9, 2009 at 9:30 a.m. BY THE COURT, ? t/ J. cc: graham Prozesky, Esquire, MidPenn Legal Services, Counsel for F her /Adam Britcher, certified legal intern, Family Law Clinic, and Thomas Place, Esquire Counsel for Mother eo es n-,,-at ?L JAMIE MICHAEL STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-5395 CIVIL ACTION - LAW LAURA JEAN STINE, 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: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jacob Michael Stine October 28, 2004 Mother 2. A Conciliation Conference was held in this matter on September 10, 2009, with the following in attendance: The Father, Jamie Michael Stine, with his counsel, Abraham Prozesky, Esquire, MidPenn Legal Services and the Mother, Laura Jean Stine, with her counsel, Adam Britcher, certified legal intern and Thomas Place, Esquire, Family Law Clinic. 3. The Honorable Edgar B. Bayley previously entered an Order of Court dated April 2, 2007 in a PFA matter at docket number 05-4792 providing for Father to have custodial visitation every Tuesday from 12:00 p.m. to 4:00 p.m. provided he have a suitable residence. 4. The parties agreed to an Order in the form as attached. Date acq ine M. Verney, Esquire Custody Conciliator R44f LL; n OF !T-E ° ' 4 , 'j . 7,'ARY 2009 SE 15 A 6, 31 6 p ,. NOV 0 9 2009 G~ `~ JAMIE MICHAEL STINE, Plaintiff V. LAURA JEAN STINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2009-5395 IN CUSTODY ORDER OF COURT CIVIL ACTION -LAW AND NOW, this _~ day of ~ , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated September 14, 2009 shall remain in full force and effect with the following modifications. 2. Father shall have the following periods of partial physical custody: A. Every Friday from 3:00 p.m. to 8:00 p.m. B. Every Saturday from 9:00 a.m. to 6:00 p.m. 3. 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. Another Custody Conciliation Conference is scheduled for January 11, 2010 at 9:30 a.m. c~ck Matash, Esquire, MidPenn Legal Services, Couns for Father Edward Chase, certified legal intern, Family Law Clinie1~and Anne MacDonald-Fox, Esquire, Counsel for Mother / /!~[ ~~ NOV 0 9 2009 ~ JAMIE MICHAEL STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2009-5395 CIVIL ACTION -LAW LAURA JEAN STINE, . 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 Jacob Michael Stine October 28, 2004 Mother 2. A Conciliation Conference was held in this matter on November 9, 2009 with the following in attendance: The Father, Jamie Michael Stine, with his counsel, Nick Matash, Esquire, MidPenn Legal Services and the Mother, Laura Jean Stine, with her counsel, Edward Chase, certified legal intern and Anne MacDonald-Fox, Esquire, Family Law Clinic. 3. The Honorable Edgar B. Bayley previously entered an Order of Court dated September 14, 2009 providing for shared legal custody, Mother having primary physical custody and Father having periods of partial physical custody every Friday and Saturday. 4. The parties agreed to an Order in the form as attached. Date "/ ac eline M. Verney, Esquire -~ Custody Conciliator ~~~~ ~~ t ~ ~ ~ ~~~ ~j J C~~isr, .. _ ~ i_.: ,. ~ ~ i ~` ~w~zzury li JAMIE MICHAEL STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2009-5395 CIVIL ACTION -LAW LAURA JEAN STINE, N c Defendant K.~ ~ : IN CUSTODY ~ `- ~ ; ~ ,' W 7 1 ORDER OF COURT ~;-~ ~ ~- .' ~ =~= c -= ~ AND NOW this / ~ ' day of ~.,r,,.. 2010 upon=- , ~ , , consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated September 14, 2009 and November 12, 2009 are hereby vacated. 2. The Father, Jamie Michael Stine and the Mother, Laure Jean Stine, shall have shared legal custody of Jacob Michael Stine, born October 28, 2004. 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 child. Each 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 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. 3. Mother shall have primary physical custody of the child. 4. Father shall have the following periods of partial physical custody: A. Alternating weekends, Friday at 3:00 p.m. to Saturday at 6:00 p.m. to begin once Father provides proof that he has a bed for the child. B. Alternating weekends, Friday from 3:00 p.m. to 8:00 p.m. and Saturday from 9:00 a.m. to 6:00 p.m. 5. Father shall be responsible for all transportation. 6. Both parties shall only transport the child in a vehicle with an approved and properly installed car seat or booster seat. 7. Neither party shall use illegal drugs nor permit the child to be exposed to illegal drugs, nor partake in alcoholic beverages to the point of intoxication while the child is in their physical custody. 8. Neither party may do or say anything nor permit a third party from doing or saying anything which may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 9. Father shall not permit any visitors to his home unsupervised contact with the child. 10. Holidays: A. Father shall have physical custody of the child on Easter from 3:00 p.m. to 7:00 p.m. B. Father shall have physical custody of the child on Father's Day from 1:00 p.m. to 8:00 p.m. C. Thanksgiving shall be shared such that Mother shall always have physical custody of the child from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the child from 3:00 p.m. to 9:00 p.m. D. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon Christmas Eve to 12:00 noon Christmas Day. Block B shall be from 12:00 noon Christmas Day to 12:00 noon December 26. Father shall have Block A in even numbered years and Block B in odd numbered years. Mother shall have Block A in odd numbered years and Block B in even numbered years. When Father has Block A, he shall assure that the child will accompany Mother to church on Christmas Eve. 11. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. cc: ana M. Walter, Esquire, MidPenn Legal Services, Counsel for Father Lan Truong, certified legal intern, Family Law Clinic, and Anne MacDonald-Fox, Esquire, Counsel for Mother Cep «.~ m~~l~-.. i f' 3f'~ Baru ~ 2 zoo JAMIE MICHAEL STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2009-5395 CIVIL ACTION -LAW LAURA JEAN STINE, 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 Jacob Michael Stine October 28, 2004 Mother 2. A Conciliation Conference was held in this matter on January 11, 2010, with the following in attendance: The Father, Jamie Michael Stine, with his counsel, Shana M. Walter, Esquire, MidPenn Legal Services and the Mother, Laura Jean Stine, with her counsel, Lan Truong, certified legal intern and Anne MacDonald-Fox, Esquire, Family Law Clinic. 3. The Honorable Edgar B. Bayley previously entered Orders of Court dated September 14, 2009 and November 12, 2009 providing for shared legal custody, Mother having primary physical custody and Father having periods of partial physical custody every Friday and Saturday. 4. The parties agreed to an Order in the form as attached. A ~' ~; Date acq ine M. Verney, Esquire Custody Conciliator JAMIE M? CHAEL STINE, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA t, v. CIVIL ACTION - LAW rncu c- z-n Zm fTi... NO. 2009 - 5395 CIVIL Tl Ica LAURA AN STINE, =° Defendant/Petitioner IN CUSTODY © x C:)-n x PETITION FOR MODIFICATION OF CUSTODY C a AN NOW comes the Petitioner, Laura Jean Stine, by her attorneys, Irwin & McKnight, P.C., and p esents the following Petition for Modification of Custody. 1. The lPetitioner is Laura Jean Stine, an adult individual residing at 154B West Penn Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent is Jamie Michael Stine, an adult individual residing at 153 East Louther Street, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of one (1) minor child, namely Jacob Michael Stine, born October 28, 2004. 4. The arties are currently governed by a custody Order of Court dated January 10, 2010, a copy of which is attached hereto and marked as Exhibit "A". 5. The (Petitioner desires that the parties share joint legal custody of said minor child. ?F? 6. Thel Petitioner desires that primary physical custody of said child remain with Petitioner, with period of temporary custody to Respondent to be modified to every other weekend with said minor 7. The best interests and permanent welfare of said minor child requires that the Court grant the Petitioner's request as set forth above. W EREFORE, Petitioner, Laura Jean Stine, respectfully requests that she retain primary physical custody and shared legal custody of Jacob Michael Stine, as provided herein, with period of temporary custody to Respondent as specified above. Respectfully submitted, IRWIN & 1 c IG7, P.C. X1 1 By: it c Knight,'#II, :orney or Plaintiff West Pomfret Street Car Penns lean' 3-3222 (717) 249-2353 Supreme Court I. D. No. 25476 Date: July 1, 2011 VERIFICATION The been foregoing Petition for Modification of Custody is based upon information which has by counsel and myself in the preparation of this action. I have head the statements made in thi? 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. SecOon 4904, relating to unsworn falsification to authorities. LAURA JEA TINE Date: July ?5, 2011 4N 1 2 zuivy IE AGCHAEL STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY VANIA V. : NO. 2009-5395 L ACTION - LAW RA JEAN STMT ; a Defendant : IN CUSTODY ORDER DYCQURT AND NOW, this i ? - day of 20101upon ? d deration of the attached Custody Co rR? ort, it is ordered and directed as ' u Ns: : t ed 1. The prior Orders of Court 14, 2009 and November 12 Selptember are hereby vacated. , 2. The Father, Jamie Michael Stine and the Mother, Laure 7can Stine, steal] e shared 10981 custody of Jacob Michael Stine, born October 28, 2004. Each parent Il have an equal right, to be exercised jointly with the other parent, to make all major -ernergency decisions affecting the Child's general well-being including, but not ited to, all decisions regarding his health, education and religion. Pursuant to the as of 23 P&C.S. §5309, each parent shall be entitled to all records and information taming to the child including, but not limited to medical, dental, religious or school )rds, the residence address of the child and the other parent. To the extent one parent possession of any such records or information, that pm ent shall be required to share same, or copies thereof, with the other parent within such reasonable time as to make records and information of reasonable use to the other parent. Both parents shall be tied to frill participation in all educational and medical/treatment planning meetings evaluations uith regard to the minor child. Each parent shall be entitled to full and 'plate information from any physician, dentist, teacher or authority and copies of any Drts given to them as parents including, but not limited to: medical records, birth Ifleates, school or educational attendance records or report cards. Additionally, each Int shall be entitled to receive copies of any notices which come from school with and to school pictures, extracurricular activities, children's pardns, musical sentations, back to-school nights, and the like. 3. Mother shall have primary physical custody of the child. 4. Father shall have the following periods of partial physical custody: A. Alternating weekends, Friday at 3:00 p.m. to Saturday at 6:00 p.m. to begin once Father provides proof that he has a bed for the child. B. Alternating weekends, Friday from 3:00 p.m. to 8:00 p.m. and L50-3 500/ZO?d SKI-d. -WOH3 8Z111 IT,-LO-90 T ' Saturday from 9:00 a.m. to 6:00 p.m. 5. Father shall be responsible for all transportation. 6. Both parties shall only transport the child in a vehicle with an approved d properly installed car seat or booster seat. 7. Neither party shall use illegal drugs nor permit the child to be exposed to :gal drugs, nor partake in alcoholic beverages to the point of intoxication while the ild is in their physical custody. 8. Neither party may do or say anything nor permit a third party from doing saying anything which may estrange the child from the other parent, iWure the opinion the child as to the other parent, or hamper the free and natural development of the lid's love and respect for the other parent. 9. Father shall not permit any visitors to his home unsupervised contact with % child. 10. Holidays: A. Father shall have physical custody of the child on Easter from 3.00 p.m. to 7:00 p.m. B. Father shall have physical custody of the child on Father's bay from 1:00 P.M. to 8:00 P.M. C. Thanksgiving shall be shared such that Mother shall always have physical custody of the child from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the child from 3:00 p.m_ to 9:00 p.m. D. Christmas shall be. divided into two Blocks. Block A shall be from 12.00 noon Christmas Eve to 12:00 noon Christmas Day. Block B shall be from 12:00 noon Christmas Day to 12:00 noon December 26. Father shall have Block A in even numbered years and Block B in odd numbered years. Mother shall have Block A in odd numbered years and Block B in even numbered years, When leather has Block A. he shall assure that the child will accompany mother to church on Christmas Eve. 11. This Order is entered pursuant to an agreement of the parties at a Custody ation Conference. The parties may modify the provisions of this Order by mutual . In the absence of mutual consent, the terms of this Order shall control. BY THE COUP'T, J. L50-3 500/£N £Tib-I -WOli3 8z: K tit ,-L0-90 i• At M. Walter, Esquire, MidPenn Legal Services, Counsel for Father Truong, cerMed legal intern, Family Law Clinic, and Anne MacDonald-Fox, Esquire, Counsel for Mother iu rnm.tltJ.- lli?lld L50-3 500/b0?d MI-Z -WOKS R:K ITS-L0-90 JAMIE V. LAURA I, upon the Class, pc CHAEL STINE, ; IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009 - 5395 CIVIL TERM "AN STINE, Defendant/Petitioner IN CUSTODY CERTIFICATE OF SERVICE ;us A. McKnight, III, Esquire, hereby certify that a copy of attached document was served ving by depositing a true and correct copy of the same in the United States mail, First prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Sh a M. Walter, Esq. Mi enn Legal Services 410 East Louther Street, #103 Carlisle, PA 17013-2625 IRWIN & M cus A. McKnight, I 6 West Pomfret Street C isle, PA 17013 717-2 - Attorney I.D. #: 25476 Attorney for the Plaintiff P.C. 6 Esq. Date: July 15, 2011 FILED-OFFICE OF THE PROTHONO ?AR x 2011 JUL -5 PM 3'. 51 ruMaF._RLANQ COUNTY JAMIE V. LAURA To the Pro Kii Marcus A. that I belie party. IAEL STINE, IN T IE MILOf"MMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009 - 5395 CIVIL TERM v STINE, Defendant IN CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS honotary: 'ply allow, LAURA JEAN STINE, Defendant, to proceed in forma pauperis. I, rlcKnight, IIl, Esquire, attorney for the party proceeding in forma pauperis, certify the party is unable to pay the costs and that I am providing free legal services to the Respectfully submitted, IRWIN cKNI T, P.C. By 1 Marc cKnight, Esquire est Pomfret Street Carlisle, Pennsylvania 1701 17) 249-2353 Date: July ?, 2011 JAMIE MICHAEL STINE PLAINTIFF V. LAURA JEAN STINE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-5395 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT 3 rnm -t r1- ' r r- "o m -<> o? r-- = - C> C(__j C- -a :X a'rt C) AND NOW, Wednesday, July 06, 2011 , 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 _ Tuesday, August 09, 2011 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Jacqueline M. Vemey, 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 Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 /die n?yltt //W. Cvq /k /U / ha t( /Y70 / (P0l $/V wg?? nri/d?vr ?? UP??ey- co 17 C-- JAMIE MICHAEL STINE, Plaintiff V. LAURA JEAN STINE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNS- LVANIA CIVIL ACTION - LAW :r Zr-rj 5 IN DIVORCE NO. 2009-5395 CIVIL TES - 7 Cr_ PRAECIPE TO WITHDRAW APPEARANCE To the Prothonotary: Stine. Please withdraw our appearance from this case on behalf of the Defendant, Laura Jean ne. Respectfully submitted, Date: FAMILY LAW CLINIC By: Megan 'esmeyer, Esq. The Dale F. Shughart Community Law Center 45 North Pitt Street Carlisle, PA 17013 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter my appearance on behalf of the Defendant, Laura Jean Stine. Respectfully submitted, IRWIN MCKNI HT, P Y Marcus 4 A. McKnight, II, Esq. 0 West Pomfret Street Car ' P slc, 17013 Date: August 17, 2011 JAMIE MICHAEL STINE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAI i ic_ - .: Ulf- V. r- ..k- 2009-5395 CIVIL ACTION LAW LAURA JEAN STINE IN CUSTODY DEFENDANT .? d ORDER OF COURT AND NOW, Monday, January 23, 2012 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, February 14, 2012 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. 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/ Hubert X. Gilroy, Esq. An 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 011-ded. far G e c? -74o dP,`f , 1tY ?1'lrays ?CoP? pla??d ? ? z3/rz JAMIE MICHAEL STINE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW LAURA JEAN STINE, NO. 2009-5395 Defendant IN CUSTODY z -, rF u U) N _ _< Y> ?-- r -1 c-_, -a COURT ORDER } I3 C". n? . c-". AND NOW, this Z y day of February, 2012, upon consideration of the attached Custody' Conciliation Report, it is ordered and directed that this Court's prior Order of January 12, 2010, shall remain in place subject to the following modifications: 1. Father's periods of partial physical custody shall be on alternating weekends on Friday from 4:00 p.m. until 8:00 p.m. and on Saturday from 9:00 a.m. until 6:00 p.m. Father's overnight custody is temporarily suspended. Counsel for the Father shall communicate with counsel for the Mother on issues with respect to Father's living arrangements and other related matters. Assuming Father's life gets settled down and he has a permanent address, the Court will consider re-instituting overnight partial custody for the Father. Counsel for the parties are directed to communicate on these issues and counsel for the parties may contact the Custody Conciliator to schedule another conciliation conference which may be a telephone conference. The Conciliator may at that time, if appropriate, recommend a revised Order re-instituting overnight partial custody for the Father. BY THE COURT: Kevin )l. Hess, Judge cc: J Marcus A. McKnight, III, Esquire ? Jane Adams, Esquire ?Op?r s mu , ??? al,7 JAMIE MICHAEL STINE, Plaintiff VS. LAURA JEAN STINE, Defendant Prior Judge: The Honorable Kevin A. Hess : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2009-5395 IN CUSTODY' CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE 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: Jacob Michael Stine, born October 28, 2004 2. A Conciliation Conference was held on February 14, 2012, with the following individuals in attendance: The mother, Laura Jean Stine, with her counsel, Marcus A. McKnight, III, Esquire, and Jane Adams, Esquire, who appeared on behalf of the father, Jamie Michael Stine. The Father did not appear. 3. The Mother is expressing concerns with respect to Father's living situation based upon an issue that the Father may not have a permanent living situation. There are also pending accusations of sexual abuse that Children's Services is investigating as of the time of this conciliation conference. After consultation with the Attorneys for the parties, the Conciliator recommends an Order in the form as attached. Date: February )?-, 2012 Hubert X. Gilroy, Esquire Custody Conciliator JAMIE MICHAEL STINE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSXLVAQN I' t? vs. CIVIL ACTION - LAWrn LAURA JEAN STINE, r\ NO. 2009-5395 3 Defendant IN CUSTODY - COURT ORDER AND NOW, this _/day of March, 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1 1. A hearing is scheduled in Court Room No. A of the Cumberland County Courthouse on the day of , 2012 at f ; V m. At this hearing, the father shall be the moving parry and all proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least three days prior to the mentioned hearing date. 2. It is understood that the primary issue in this case is father's current living arrangements. Assuming the parties can address that issue prior to the hearing scheduled above, the parties may contact the Custody Conciliator again who may conduct a Conciliation Conference via telephone with legal counsel for the parties after which the Conciliator may submit an appropriate Order to this Court which may modify the existing Custody Order and cancel the hearing scheduled above. BY THE COURT: 6?? --c'e-, -Kevin-*-. Hr s *'Le, cc: Marcus A. McKnight, III, Esquire -/Jane Adams, Esquire (.op ?a 3I ?? JAMIE MICHAEL STINE, Plaintiff VS. LAURA JEAN STINE, Defendant Prior Judge: The Honorable Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-5395 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The Conciliator conducted a telephone conference with attorneys for the parties on March 13, 2012. Father is interested in re-instituting alternating weekends custody with the minor child. Mother continues to express concern relative to father's living arrangements which appears to be the primary issue in this case. Father wants to move it along to a hearing, and the Conciliator recommends an Order in the form as attached. Date: March 6-, 2012 4 Q?l Hubert X/Gilroy, Esquire Custo Conciliator I Ira ?? _? //pp, 11 iS'ER, f1i'Id? r.. JAMIE MICHAEL STINE, IN THE COURT OF CO EAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2009 - 5395 CIVIL TERM LAURA JEAN STINE, Defendant IN CUSTODY ORDER OF COURT AND NOW, this -?day of e& Z 2012, the Custody Hearing in the above referenced case scheduled for May 9, 2012 has been rescheduled for Thursday, May 24, 2012, at 1:00 p.m. The Hearing is scheduled in Courtroom No. 1 of the Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT: Albert H. Masland, Judge m F. Esq. cc: /Jane Adams r- ' , Attorney for Plaintiff tee, ,. Marcus A. McKnight, III, Esq. ` Attorney for Defendant = ?w f CP , es ,via . l ?/ ?- )ep JAMIE MICHAEL STINE, Plaintiff V. LAURA JEAN STINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-5395 CIVIL TERM ORDER OF COURT AND NOW, this 24th day of May, 2012, the parties having appeared in open court and presented testimony regarding their custodial responsibilities with respect to Jacob Stine, date of birth October 28, 2004, the Court directs that the record remain open until Tuesday, June 5, 2012, to afford father the opportunity to present the Court with evidence of his living arrangements. Pending receipt of evidence satisfactory to the Court that the father has stable living arrangements, father wil-,_ continue to enjoy alternating weekends consisting of Friday from 4:00 p.m. until 8:00 p.m. and Saturday from 9:00 a.m. until 6:00 p.m. Father will not have overnight custody periods until the Court receives the aforesaid evidence. Father's next weekend is May 25 and 26, 2012. By the Court, 11 7, Albert H. M sland, J. ? Jane Adams, Esquire -- ? For Plaintiff rn M, ; °. vi ? a Y ? Marcus A. McKnight, III, Esquire -rte 4 . c.a o For Defendant D- Sheriff c.? prs f oP;r s ru.&Aed JAMIE MICHAEL STINE, PLAINTIFF V. LAURA JEAN STINE, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 09-5395 CIVIL TERM ORDER OF COURT AND NOW, this 2? day of June, 2012, following a hearing on May 24, 2012 that raised substantial concerns for the court regarding Father's living arrangements, which concerns Father failed to adequately address, we DIRECT that the suspension of Father's overnight custody be continued indefinitely. Father shall continue to have periods of partial custody with his son on alternating weekends on Fridays from 4:00 p.m. to 8:00 p.m. and Saturdays from 9:00 a.m. until 6:00 p.m. In all other respects the prior orders of court dated January 12, 2010 and February 24, 2012, shall remain in full force and effect. By the Court, Albert H. Masland, J. ? Jane Adams, Esquire For Plaintiff. -77 ? Marcus A. McKnight, III, Esquire For Defendant :saa ?,??es led 6/?1 a JAMIE MICHAEL STINE, PLAINTIFF V. LAURA JEAN STINE, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 09-5395 CIVIL TERM MEMORANDUM OPINION AND ORDER OF COURT Masland, J., June 8,2012:-- Before the court is the issue of whether Father should be granted periods of overnight custody with his son, Jacob Michael Stine, born October 28, 2004. As background, we note that by order of court dated January 12, 2010, the parties share legal custody of Jacob with Mother having primary physical custody, subject to Father enjoying, among other things, alternating weekends. Following a conciliation conference on February 14, 2012, at which Mother expressed concerns with Father's living situation, an order of court was issued on February 24, 2012, that suspended Father's periods of overnight custody. The order further noted: Counsel for the Father shall communicate with counsel for the Mother on issues with respect to Father's living arrangements and other related matters. Assuming Father's life gets settled down and he has a permanent address, the court will consider re-instituting overnight partial custody for the Father. Counsel for the parties are directed to communicate on these issues and counsel for the parties may contact the Custody Conciliator to schedule another conciliation conference which may be a telephone conference. The conciliator may at that time, if appropriate, recommend a revised Order re-instituting overnight partial custody for the Father. The conciliator conducted a telephone conference with the attorneys for the parties on March 13, 2012. Because they were unable to reach an agreement, a hearing was scheduled for May 9, 2012 and later rescheduled to May 24, 2012. 09-5395 CIVIL TERM At the close of the hearing, the court noted its concern with Father's living arrangements. In particular, we noted the lack of a current lease, his multiple moves, the disturbing and sometimes assaultive "drama" at the residence, all of which is complicated by Father's health issues. Conversely, we found Mother to have a challenging but far more stable life than Father. The testimony of Nancy Speck, a home visitation social worker for Cumberland Cares for Families, was particularly convincing with respect to Mother's ability to parent as compared to Father. Nevertheless, by order of May 24, 2012, we kept the record open until Tuesday, June 5, 2012 to give Father the opportunity to satisfy us regarding his tenuous living arrangements. Much to our chagrin, but not to our surprise, Father has not presented any evidence that his life has "settled down." Accordingly, we entered the following order. ORDER OF COURT AND NOW, this 8'--' day of June, 2012, following a hearing on May 24, 2012 that raised substantial concerns for the court regarding Father's living arrangements, which concerns Father failed to adequately address, we DIRECT that the suspension of Father's overnight custody be continued indefinitely. Father shall continue to have periods of partial custody with his son on alternating weekends on Fridays from 4:00 p.m. to 8:00 p.m. and Saturdays from 9:00 a.m. until 6:00 p.m. In all other respects the prior orders of court dated January 12, 2010 and February 24, 2012, shall remain in full force and effect. By the Court, Albert H. Maslan , J. -2- 09-5395 CIVIL TERM Jane Adams, Esquire For Plaintiff Marcus A. McKnight, III, Esquire For Defendant :saa -3- JAMIE MICHAEL STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-5395 CIVIL ACTION -LAW� LAURA JEAN STINE, -20 Defendant IN CUSTODY C. ORDER OF COURT AND NOW,this 17th day of July, 2013, being advised that this matter was heard before the Dependency Master,the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, Ak i—qu me M. Verney, Esquire, Custody ciliator