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HomeMy WebLinkAbout04-2287 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04- ;)'~f7 8l.J~L'-r~ TODD M. EDWARDS, PlaintitT : DAWN L. BULLOCK Defendant CIVIL ACTION - LAW IN CUSTODYIVISITATION COMPLAINT FOR CUSTODY 1. Plaintiff is Todd M. Edwards, an adult individual who currently resides at 4 Zenu Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Dawn L. Bullock, an adult individual who currently resides at 831 Broadway, Hanover, York County, Pennsylvania 17331. 3. Plaintiff seeks sole legal custody and primary physical custody of the following child: Name Present Residence Date of Birth Paige K. Edwards 4 Zenu Road Mechanicsburg, P A May 22, 1995 The child was not born in wedlock. The child is presently in the custody of Plaintiff who resides at 4 Zenu Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 4. During the past five years, the child has resided with the following persons and at the following addresses: A. Plaintiff Todd M. Edwards 4 Zenu Road Mechanicsburg, Pennsylvania November, 2003 - Present B. Plaintiff Todd M. Edwards 417 E. Middle Street Hanover, Pennsylvania 1999 - November, 2003 Defendant Dawn L. Bullock 831 Broadway Hanover, Pennsylvania 2000 - Present C. Plaintiff Todd M. Edwards Defendant Dawn L. Bullock 287 South Street Hanover, Pennsylvania 1996-1999 5. The mother of the child is Defendant Dawn L. Bullock, who is currently residing at 831 Broadway, Hanover, York County, Pennsylvania 17331. She is single. 6. The father of the child is Plaintiff Todd M. Edwards, who is currently residing at 4 Zenu Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. He is single. 7. The relationship of Plaintiff Todd M. Edwards to the child is that of Father. The Plaintiff resides with the foUowing persons: Name Relationship Doreen Appel Girlfriend Nicholas Appel Girlfriend's son Alexa Appel Girlfriend's daughter 8. The relationship of Defendant Dawn L. Bullock to the children is that of Mother. The Defendant does not reside with anyone. 9. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 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. 10. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Plaintiff has been involved in the child's life since birth. For the past six months, he has exclusively provided a nurturing, loving and stable home environment for the child. The child is doing well in the custody of Plaintiff and should not be removed from his care. B. The child is presently being counseled by Bonnie Howard, PhD., ofReigler Shienvold and Associates due to the strained relationship she experiences with her Mother. Due to some past events which have occurred between Mother and child, Dr. Howard has suggested that no overnight visits take place between Mother and child, and no weekday visits occur. C. And other reasons which may fully appear at conference. II. Each parent whose parental rights to the child, which have not been terminated, and the person who has physical custody of the child, has been named as parties to this action. There are no other persons who are known to have a claim or right to custody or visitation in this matter. WHEREFORE, Plaintiff requests this Honorable Court to grant sole legal custody and primary physical custody of the child to Plaintiff, Todd M. Edwards, subject to periods of partial physical custody with Defendant, Dawn L. Bullock. Respectful1y submitted, DALEY ZUCKER & GINGRICH, LLC o~~~ Attorney No. 68736 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Attorney for Plaintiff VERIFICATION Upon my personal knowledge, information and belief, I, Todd M. Edwards, do hereby verify that the facts averred and statements made in the foregoing Complaint are true and correct. I understand that false statements or averments therein made will subject me to the criminal penalties of 18 Pa.C.S.A. ~4904 relating to unsworn falsification to authorities. Date: -sf, '1)) U.... By: ~~~,}~ Todd M. Edwards TODD M. EDWARDS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 04-2287 CIVIL ACTION LAW DAWN L. BULLOCK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 27, 2004 , upon consideration of the attached Complaint, it is hereby directed tbat parties and their respective counsel appear before Melissa P. Greevy, Esq. at 301 Market Street, Lemoyne, PA 17043 on Thursday, July 08, 2004 , the conciliator, 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existinl~ Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin!!. FOR THE COURT. By: Isl Melissa P. Greevy. F.sq. Custody Conciliator mhc The Court of Common Pleas of Cumberland County is requin:d 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 Stre,et Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~-r,~ ~ ~ ACl'((,_5" . ~ 7' ~ ~~ ACl. t...e.5 ~4f;7 r ~ ~ ~c/.~ /70'C.C05 VN~V/\l;\SNN,'~d ) '''n'',~ ,',' ".,'e, "yo,W!V'\ \..\..1 '", ,(, /,,' ""',' ,:,l::~~,;, 'II h..} L 0 :2 !Jd l.Z A Vl~ ~DDl "'\i: ("'i()U 'Uc"" , :JHl -'0 AU 1. .11/,;u. 0'0 ...u .;l 301:1::10-0311::1 OS/22/2004 08:13 SAIDIS SHUFF, FLOWER & LINDSAY I\ITORNEVS-AToT.^W 26 W. High SU'eel C:Jrlislc, PA 71 72435510 5AIDIS SHUF~ FLOWER PAGE 03/84 TODD M. EDWARDS, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04 2:!87 CIVIL TERM Plaintiff VS. DAWN L. BULLOCK, Defendant : IN CUSTODYNlSITATION PRAECIPE TO WITHDRAWAPPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance on behalf of the Defendant, DAWN L. BULLOCK, in the above captioned case. PRAECIPE TO ~:N ER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Defendant, DAWN J. BULLOCK, in the above captioned case. SAlDIS, SHUFF, FLOWER & LINDSAY, PoCo Attorneys; for P . tiff By: Carol . in say, Esquire ID# 44 93 26 We High Street Carlisle, PA 17013 (717) 243-6222 r-> c:::> = X' (- ~:.: o -n -:::\ 'I...-- fnp -CJrn :',-q9 ~216 ~:~~~ n:.' N (J1 -;-;. l..D o ~ -, AUG 1 1 2004 ~ c Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2287 CIVIL TERM TODD M. EDWARDS, v. CIVIL ACTION - LAW DAWN L. BULLOCK, IN CUSTODY Defendant ORDER OF COURT AND NOW, this ~ day of August, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Leqal Custody. The parties, Todd M. Edwards and Dawn L. Bullock, shall have shared legal custody of the minor child, Paige K. Edwards, born May 22, 1995. 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 her health, education and religion. Pursuant to the terms of 23 Pa. C. S. S5309, 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. The Father, Todd M. Edwards, shall have temporary primary physical custody of the minor child subject to Mother's rights of partial custody which shall be arranged as follows: A. August 12, 2004 at 6:00 p.m. until August 15, 2004 at 7:00 p.m. B. Effective August 27,2004, on alternating weekends from Friday at 6:30 p.m. until Sunday at 7:00 p.m. C. At such additional times as are recommended by the child's therapist, Bonnie Howard. 3. Howard. The parties shall continue in their therapeutic counseling work with Bonnie 88 :8 HJ L I ~);"ltfllGJZ :JO NO. 04-2287 CIVIL TERM 4. The Custody Conciliation Conference shall reconvene on October 19, 2004 at 10:30 a.m. at the office of the Custody Conciliator, Melissa Peel Greevy, Esquire, 301 Market Street, Lemoyne, PA 17043. This Conciliation may be cancelled by mutual consent of the parties which will be communicated to the Conciliator one (1) week prior to the Conciliation date. BYTHECQU::'~~ J. Dis!: ,...e;ara,A. Boyanowski, Esquire, 1029 Scenery Drive, Harrisburg, PA 1:1109 )d'<:If01 J. Lindsay. Esquire, 26 West High Street. Cariisle, PA 17013 AUG 11 2004f Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2287 CIVIL TERM TODD M. EDWARDS, v. DAWN L. BULLOCK, CIVIL ACTION - LAW IN CUSTODY Defendant 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 THE CUSTODY OF Paige K. Edwards May 22, 1995 Father 2. A Custody Conciliation Conference was held on August 5, 2004 in response to the filing of Father's Custody Complain on May 20, 2004. Present for the conference were: the Father, Todd M. Edwards, and his counsel, Cara A. Boyanowski, Esquire; the Mother, Dawn L. Bullock, and her counsel, Carol J. Lindsay, Esquire. ~ I ~i;T _ohod '" ,g-~r;r O~ohed Date Melissa Peel Greevy, Esquire Custody Conciliator :233462 NOV U i LLlJ4 r Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2287 CIVIL TERM TODD M. EDWARDS, v. DAWN L. BULLOCK, CIVIL ACTION - LAW IN CUSTODY Defendant OLER, J. --- ORDER OF COURT AND NOW, this S It- day of November, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Leaal Custody. The parties, Todd M. Edwslrds and Dawn L. Bullock, shall have shared legal custody of the minor child, Paige K. Edwards, born May 22, 1995. 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 gene!ral 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 relcords 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 pare!nt. 2. Physical Custody. The Father, Todd M. Edwards, shall have temporary primary physical custody of the minor child subject to Mother's rights of partial custody which shall be arranged as follows: A. Effective October 22, 2004 from Friday at 6:30 p.m. until Monday at 7:20 a.m. on alternating weekends. B. November 19, 2004 through Monday, November 22, 2004 during Father's trip to Florida. Because Father is out IQf town, Mother will provide all transportation incident to this custodial period. C. At such additional times as are recommended by the child's therapist, Bonnie Howard. 3. Howard. The parties shall continue in their therapeutic counseling work with Bonnie V!i\:"C;'~"\l} MiitK'(I 'T"--:"":?:~i:':il:) i12 =8 H~ 6- nON ~Daz 'i..j"r'! (',\ ir:;.~ '0' '-1 ::JjJ I J('\ ,'\....Y.J..,..dljVI U 8:..1... u. ..JV 38/,:1:-'O-G31!:j . NO. 04-2287 CIVIL TERM 4. Holidavs. The following holiday schedule will take precedence over the regular schedule: A. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 24th at 5:00 p.m. until December 25th at 5:00 p.m. Segment B shall be from December 25th at 5:00 p.m. until December 28th at 6:30 p.m. In even-numbered years, Father shall have Segment A and Mother shall have Segment B. In odd- numbered years, Mother shall have Segment A and Father shall have Segment B. B. Thanksaivina. Mother shall have custody for Thanksgiving from November 24th at 4:00 p.m. through November 29th at 7:30 a.m. in 2004. Commencing in 2005, Thanksgiving shall be divided into two segments, Segment A and Segment B. Segment A shall be from Wednesday before Thanksgiving after school until Thanksgiving Day at 2:00 p.m. Segment B shall be from Thanksgiving Day at 2:00 p.m. until the Friday after Thanksgiving at 6:30 p.m. In even-numbered years, Mother sh,all have Segment A and Father shall have Segment B. In odd-numbered years, Father shall have Segment A and Mother shall have Segment B. 5. TransDortation. The parties will meet at the usual half-way meeting place for custodial exchanges. 6. The Custody Conciliation Conference shall reconvene on January 25, 2005 at 9:30 a.m. at the office of the Custody Conc:iliator, Melissa Peel Greevy, Esquire, 301 Market Street, Lemoyne, PA 17043. BY THE COURT: Dist: JlBra A. Boyanowski, Esquire, 1029 Scenery Drive, Harrisburg, PA 17109 ."carol J. Lindsay, Esquire, 26 West High Street, Carlisle, PA 17013 " Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2287 CIVIL TERM TODD M. EDWARDS, v. DAWN 1.. BULLOCK, CIVIL ACTION - LAW IN CUSTODY Defendant 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 THE CUSTODY OF Paige K. Edwards May 22, 1995 Father 2. The parties' second Custody Conciliation Con1ference was held on October 19, 2004 as planned at the Conciliation of August 5, 2004. Present for the conference were: the Father, Todd M. Edwards, and his counsel, Cara A. Boyanowski, Esquire; the Mother, Dawn 1.. Bullock, and her counsel, Carol J. Lindsay, Esquire. 3. The parties reached an agreement as to extending the custodial weekends, Thanksgiving and Christmas. They had a different recolllection with regard to Mother's request for Wednesday evening. However, counsel agreed to fax a letter to the child's therapist to inquire whether it might be possible to begin VVednesday evening visitation on October 27, 2004 if the parties agreed. The custodial tim1e plated was either 4:00 p.m. or 5:00 p.m. through 8:00 p.m. ( /0#10/ ~~ '&L Date Melissa Peel Greevy, Esq Custody Conciliator :238003 FEB 0 3 2005}' TODD M. EDWARDS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2287 CIVIL TERM v. CIVIL ACTION - LAW DAWN L. BULLOCK, IN CUSTODY Defendant OLER, J. --- ORDER OF COURT AND NOW, this --1tL day of February, 2005, upon consideration of the attached Custody Conciliation Summary Report, this Court's Order of November 5, 2004 shall remain in full force and effect with the following modifications: 1. Easter 2005 in the event that Mother is not working on Good Friday, Mother shall pick up the child at 10:00 a.m. at Father's residence for her custodial weekend. 2. Mother will have custody for the Presidents' Day holiday 2005 on February 24, 2005. Mother will pick up the child at 10:00 a.m. at Fattler's residence. The parties will meet for the custodial exchange at the conclusion of Mother's custodial period at the church where they have customarily been meeting at 8:00 p.m. 3. Mother shall have custody each Wednesday evening from between 4:00 and 5:00 p.m. until 8:00 p.m. With regard to transportation for the Wednesday periods of custody, Mother will pick up the child after work at the beginning of her visit. The parties will meet at the church where they have been customarily been meeting at 8:00 p.m. for the custodial exchange on Wednesday evenings. 4. A hearing is scheduled in Courtroom Number 1 of the Cumberland County Courthouse, on the l'3a day of ~ ' 2005, at 1: 3/J o'clock A.M., at which time testimony will be tak n. For the purposes of the hearing, the Mother, Dawn L. Bullock, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated ~~ '-- - - {."'~) :;c c.., c-:> I (::.~) L.f,J U- Lt- C) NO. 04-2287 CIVIL TERM testimony of each witness. These memoranda shall be fiiled at least ten days prior to the hearing date. BY THE COURT: __ ;! /:/ / vt ' ;: / n ' J. Wesl~D)1er. j., . Dis!: ~ara A. Boyanowski, Esquire. Suite 201. 2080 Linglestown Road. HalCrisburg, PA 17110 ,..earol J. Lindsay, Esquire, 26 West High Street. Carlisle, PA 17013 ~~ ;;;/7/05 /U/ ~~ bf\~) . '(~~ .o? Ol),;O TODD M. EDWARDS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA f\10. 04-2287 CIVil TERM v. CIVil ACTION - lAW DAWN L. BULLOCK, IN CUSTODY Defendant 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 THE CUSTODY OF Paige K. Edwards May 22,1995 Father 2. The parties' third Custody Conciliation Conference was held on January 28, 2005. Present for the conference were: the Father, Todd M. Edwards, and his counsel, Cara A. Boyanowski, Esquire; the Mother, Dawn l. Bullock, and her counsel, Carol J. Lindsay, Esquire. 3. Mother's position on custody is as follows: Mother would like to have additional periods of custody with the child. Her present custodial schedule consists of alternating weekends from Friday at 6:30 p.m. until Monday at 7:20 a.m. and from 4:00 or 5:00 p.m. until 8:00 p.m. on Wednesdays. Because of the geographic distance between the parties, she would prefer the Wednesday evening custodial time be expanded to an overnight period of custody. Alternatively, she suggests that the custodial schedule be switched during the summer school recess such that she would have primary custody during that period of time that the child is not in school and Father would then have alternating weekend custody. This would be supplemented by two weeks of custody for purposes of summer vacation for each parent. 4. Father's position on custody is as follows: Father is unwilling to expand the periods of partial custody in the absence of a recommendation from the child therapist, Dr. Bonnie Howard. Father would be agreeable to an additional overnight of custody from Tuesday after work until Wednesday evening during the summer school recess and the two weeks of summer vacation for each parent. However, he is unwilling to expand Mother's NO. 04-2287 CIVIL TERM periods of partial custody in the summer as she has proposed. Father is also not satisfied with having to share transportation responsibility for custodial exchanges. 5. Conciliator Observation: Significant tension between the parties related to their history continues to be evident and continues to bleed over into the roles the parents playas decision makers regarding their child's needs and interests. The continued anger and conflict are necessarily harmful to the child despite attempts at therapeutic intervention. An additional complicating factor is the geographic distance between the parents' homes. 6. The parties reached an agreement regarding Easter, President's Day and Wednesday evening transportation, as reflected in the attached Order. 7. Because the parties were not able to reach an agreement regarding Mother's request for expanded periods of partial custody, a hearing will be necessary. ( ~p~!r,~ Custody Conciliator J -I-Or; Date :243944 Cara A. Boyanowski, Esquire Supreme Court J.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, P A 1711 0 (717) 540-9170 DAWN L. BULLOCK Defendant CIVIL ACTION - LAW IN CUSTODYNISITATI TODD M. EDWARDS, Plaintiff IN THE COURT OF CO MON PLEAS CUMBERLAND COUNT ,PENNSYLVANIA v. NO. 04-2287 CIVIL TER STIPULATION FOR CUSTODY WHEREAS, Plaintiff and Defendant are the parents of one minor hild, to wit: Paige K. Edwards, born May 22, 1995; WHEREAS, Plaintiff and Defendant, after careful consideration and the opportunity for the advice and assistance of counsel, have reached an agreement to provide for t e custody of this child without the need to litigate the matter before this Honorable Court and asks the court to adopt this agreement as its Order; WHEREAS, it is the belief of the Plaintiff and Defendant that the ag eement reached herein provides for the best interest of their child; NOW THEREFORE, intending to be legally bound, the parties a ee as follows: I. Lel!aI Custody. The parties, Todd M. Edwards and Dawn L. Bullock, shall have shared legal custody oftheir minor child, Paige K. Edwards, born May 22, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all aJor non-emergency decisions affecting the child's general well being including, but not limited to, II decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. Sect" on 5309, each parent shall be entitled to all records and information pertaining to the child includi g, but not limited to, medical, dental, religious or school records, and the residence address of the child and of the other parent. To the extent one parent has possession of any such records or inform tion, that parent shall be required to share the same, or copies thereof, with the other parent within s ch reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Father, Todd M. Edwards, shall have tem orary primary physical custody of the minor child subject to Mother's, Dawn 1. Bullock, rights ofp rtial physical custody, which shall be arranged as follows: A. On alternating weekends, from Friday at 6:30 p.m. un il Monday at 7:20 a.m. B. Every Wednesday as follows: 1. During the months where school is in session, every Wednesday from after school, with the exact pick-up time to b mutually agreed upon between the parties, until Thursday at 7:20 .m. Mother to assume sole responsibility for all transportation on ednesday to begin her period of physical custody. 11. During the summer vacation months, every uesday from 6:30 p.m. until Wednesday at 8:00 p.m. C. On Monday, February 21, 2005, from 10:00 a.m. u ti18:00 p.m. Mother to assume sole responsibility for all transportation to begin her period 0 physical custody on Monday, February 21st. D. On Friday, March 25,2005, from 10:00 a.m. until Mon ay, March 28, 2005 at 7:20 a.m. Mother to assume sole responsibility for all transportation 0 begin her period of physical custody on Friday, March 25'h. E. At all other times mutually agreed upon between the arties. 3. Holiday Schedules. The following holiday schedules will ta e precedence over the regular schedule. The holidays shall be divided as follows: A. Mother's Day. Mother shall be entitled to visitation n Mother's Day from 10:00 a.m. until 8:00 p.m. B. Father's Day. Father shall be entitled to visitation on Father's Day from 10:00 a.m. until 8:00 p.m. C. Easter. Memorial Day. and Labor Day. The holi ay of Easter shall be celebrated with the parent exercising physical custody on their regul r alternating weekend schedule. The holidays of Memorial Day and Labor Day, which are lebrated on Mondays, shall be celebrated with the parent exercising physical custody on th weekend immediately preceding the holiday. For example, in 2005, Memorial Day is cele ated on Monday, May 30th. The weekend immediately preceding the holiday, May 27-2 , is Father's regularly scheduled alternating weekend; therefore, Father will continue to ex rcise physical custody on Memorial Day. D. July Fourth. The holiday of July Fourth will be alte ated each year between the parties, from 10:00 a.m. until 8:00 p.m., with the rotation beginning ith Mother in 2005. In the event the holiday falls on either a Friday or a Monday, this rota ion schedule will be modified so that the party exercising physical custody immediately pre eding or immediately following the holiday, shall be entitled to expand his/her alternatin weekend period of physical custody to include the holiday. For example, if July Fou 1 falls on the Friday immediately preceding Mother's regularly scheduled alternating weeke d custody period, she will exercise custody from Friday, the day of the holiday, at 10:00 a. . until her regularly scheduled time on Monday. If July Fourth falls on the Monday i mediately following Father's regularly scheduled alternating weekend custody period, he will exercise custody from Friday at his regularly scheduled time until Monday, the day oft e holiday, at 8:00 p.m. E. Thanksgiving. Thanksgiving shall be divided into tw segments, Segment A and Segment B. Segment A shall be from Wednesday before Thanks ving after school until Thanksgiving Day at 2:00 p.m. Segment B shall be from Thanksgi ing Day at 2:00 p.m. until the Friday after Thanksgiving at 6:30 p.m. In even-numbered y s, Mother shall have Segment A and Father shall have Segment B. In odd-numbered y ars, Father shall have Segment A and Mother shall have Segment B. F. Christmas. Christmas shall be divided into two seg ents, Segment A and Segment B. Segment A shall be from December 24th at 5:00 p.m. ntil December 25th at 5:00 p.m. Segment B shall be from December 25th at 5:00 p.m. until December 28th at 6:30 p.m. In all even-numbered years, Father shall have Segment A nd Mother shall have Segment B. In odd-numbered years, Mother shall have Segment and Father shall have Segment B. 4. Summer Vacation. Each parent shall be entitled to e ercise two (2) non- consecutive, uninterrupted, weeks of physical custody, during the summer m nths ofJune, July and August, with thirty (30) days written notice to the other parent. Each par nt agrees to coincide his/her uninterrupted week of custody with his/her alternating weekend cus dy schedule. 5. TransDortation. The parties will meet at the usual half-wa meeting place for all custodial exchanges, except on those dates and times set forth above, when M ther shall assume sole responsibility for transportation. 6. The parties shall continue in their therapeutic counseling wor with Bonnie Howard. 7. Both parties shall establish a no-conflict zone for the child a d refrain from making derogatory comments about the other parent in the presence of the child an to the extend possible shall prevent third parties from making such comments in the presence of t e child. 8. The parties shall keep each other informed of their respectiv current addresses and telephone numbers. 9. Plaintiff is represented by Cara A. Boyanowski, Esquire. Defi ndant is represented by Carol J. Lindsay, Esquire. Both parties have been informed of the purpose 0 this Agreement and its legal effects and consequences. 10. Each of the parties has carefully read and fully considered t . s Stipulation and all of the statements, terms, conditions, and provisions thereof prior to signing b low. The parties agree that this Stipulation be made into an Order of Court which may be modified y mutual agreement. In the absence of mutual agreement, the terms of the Order shall control pendin further Order of Court. ,I; IN WITNESS WHEREOF, intending to be legally bound hereby, the arties hereto have set their hands and seals on this 6TH- day of ,2005. WITNESS: ~~~ Counsel for Plaintiff Carol J. Lindsay, Esquire Counsel for Defendant MAR 0 4 200~ "" = if? (.,.::) <~, """ --/ ~ :r =\5 ni .:n r- "TJTn :0(-' or --0 . ~ t,~J :~,:r:: f:-j ( (~ ,rTt r"-,' :;':"'; :-:0 C) -< r TODD M. EDWARDS, Plaintiff v. DAWN L. BULLOCK, Defendant IN THE COURT OF COMMON PEAS OF CUMBERLAND COUNTY, PE SYL VANIA CIVIL ACTION - LAW NO. 04-2287 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 4th day of April, 2005, upon consideration f the attached letter from Cara A. Boyanowski, Esq., attorney for Plaintiff, the hearing reviously scheduled for April 13, 2005, is cancelled. Cara A. Boyanowski, Esq. Suite 201 2080 Linglestown Road Harrisburg, PA 17110-9670 Attorney for Plaintiff Carol J. Lindsay, Esq. 26 West High Street Carlisle, PA 17013 Attorney for Defendant :rc BY THE COURT, ct~J ~k 4- G,. uS ~5- 'I!I'JW;lASNI\13d j "I"'''', -'", ,'-' J~-"'C\" IU.;\: ;\.} --' ~ .,) }:,-~t!f"f h..J 2fJ :8 Hd S~ ~dV SOUl it'VlONOH1Cdd 3Hl .:10 3Jli:10-03llj ------------ - . ,- LAW ()FFlCES SERRATELLI SCIIlFFMAN BROWN & CALHOON, Pc. l'''\:" :\. Dr', ,'.'" !\.-,';',,,,' April I, 2005 The Honorable 1. Wesley Oler, Jr. Cumberland County Courthouse High and Hanover Streets Carlisle. PA ] 7013 RE: Edwards v. Bullock Dear Judge Oler: Please be advised that I represent Todd M, Edwar s, natural father of Paige K. Edwards, born May 22, 1995, and Carol indsey, Esquire, represents Dawn L. Bullock, natural mother ofPa ge K. Edwards. The parties have reached an agreement on the physica custody schedule they will share regarding their daughter. Counsel are resently reducing this schedule to writing in the form of a Stipulation fo Custody, which they anticipate filing with this Honorable Court in the ery near future. Therefore, I am requesting that the custody heari g, presently scheduled before you for April 13, 2005, at 9:30 a.m. be ca elled. Attorney Lindsey concurs in this request. If you have any uestions regarding the above information, please do not hesitate to cont ct me. Thank Y0l1 for 'YC\Pf kine ~ttf'nti()!1 Sincerely yours, SERRATELLI SCHIFFMAN BROWN & CAL ~~0J?Wdiu' Cara A. Boyanowski, Esquire CAB/cb cc: Todd M. Edwards Carl J. Lindsey, Esquire OON ANN WILSON, Executrix Of the Estate of HELEN E. KELLY, deceased : IN THE COURT OF COMM N PLEAS OF : CUMBERLAND COUNTY, ENNSYL VANIA v, MANORCARE HEALTH : NO, 2004-3065 CIVIL TERM SERVICES, INe., MANORCARE HEALTH CORPORATION, Villb/aMANORCAREHEALTH SERVICES - CARLISLE, HCR MANORCARE, and : CIVIL ACTION - LAW MANORCARE, INC, ORDER OF COURT AND NOW, this 6TH day of APRIL, 2005, a hearing on Plaintif s "Motion to Deny or Remove Non Pros" is scheduled for MONDAY MAY 2 2005 at 10:30 a.m. in Courtroom # 5 of the Cumberland County Courthouse, Carlisle, Pa, Lisa M, B. Woodburn, Esquire ') 4503 North Front Street Harrisburg, Pa. 1711 0 Edwin A.D, Schwartz, Esquire 2040 Linglestown Road Suite 302 Harrisburg, Pa, 17110 ~ ~ /}~j~ Court Reporter :sld .".. ".~. J..>"~ .c,L \~... L,' '<')% __0 'd,--', u.......-..: C)(:) , .. 0.';5: ~,y .....~ v- a - C'") .' - ..,,;: <>-- -J::l t ~ ~ ~ = C'" y \- "7- ~.:;~~ ....,..~ "..~.;~ ;-'1./; '\'?'.~~j .~;.} \..1; q;.'..... :5 ;0 .---- - y Cara A. Boyanowski, Esquire Supreme Court J.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, P A 1711 0 (717) 540-9170 RECEIVED APR 12 200~ TODD M. EDWARDS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-2287 CIVIL TERM DAWN L. BULLOCK Defendant CIVIL ACTION - LAW IN CUSTODYNISITATION ORDER OF COURT AND NOW, this \ ~ r( day of A f r, ( 2.0 c,5 , :w&t, upon stipulation of the parties, it is hereby Ordered and Decreed: 1. Lel!al Custody. The parties, Todd M. Edwards and Dawn L. Bullock, shall have shared legal custody of their minor child, Paige K. Edwards, born May 22, 1995. 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 her health, education and religion. Pursuant to the terms of 23 Pa.C.S. Section 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, and 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 20 :lJ lid S I HdV soaz ^tJVL(Y'~J;U.:,:tdd 3Hl :f0 3~)LJ:jCr-(En!:1 ~- to make the records and information of reasonable use to the other parent. 2, Physical Custody. Father, Todd M. Edwards, shall have temporary primary physical custody ofthe minor child subject to Mother's, Dawn L. Bullock, rights of partial physical custody, which shall be arranged as follows: A. On alternating weekends, from Friday at 6:30 p.m. until Monday at 7:20 a.m, B. Every Wednesday as follows: I. During the months where school is in session, every Wednesday from after school, with the exact pick-up time to be mutually agreed upon between the parties, until Thursday at 7:20 a.m. Mother to assume sole responsibility for all transportation on Wednesday to begin her period of physical custody. 11. During the summer vacation months, every Tuesday from 6:30 p.m. until Wednesday at 8:00 p.m. C. On Monday, February 21,2005, from 10:00 a.m. until 8:00 p.m. Mother to assume sole responsibility for all transportation to begin her period of physical custody on st Monday, February 21 . D. On Friday, March 25, 2005, from 10:00 a.m. until Monday, March 28, 2005 at 7:20 a.m. Mother to assume sole responsibility for all transportation to begin her period of physical custody on Friday, March 25th. E. At all other times mutually agreed upon between the parties. 3. Holiday Schedules. The following holiday schedules will take precedence over the regular schedule. The holidays shall be divided as follows: A. Mother's Dav. Mother shall be entitled to visitation on Mother's Day from 10:00 a.m. until 8:00 p.m. B. Father's Dav. Father shall be entitled to visitation on Father's Day from 10:00 a.m. until 8:00 p.m. C. Easter. Memorial Dav. and Labor Dav. The holiday of Easter shall be celebrated with the parent exercising physical custody on their regular alternating weekend schedule. The holidays of Memorial Day and Labor Day, which are celebrated on Mondays, shall be celebrated with the parent exercising physical custody on the weekend immediately preceding the holiday. For example, in 2005, Memorial Day is celebrated on Monday, May 30th The weekend immediately preceding the holiday, May 27-29, is Father's regularly scheduled alternating weekend; therefore, Father will continue to exercise physical custody on Memorial Day. D. Julv Fourth. The holiday of July Fourth will be alternated each year between the parties, from 10:00 a.m. until 8:00 p.m" with the rotation beginning with Mother in 2005. In the event the holiday falls on either a Friday or a Monday, this rotation schedule will be modified so that the party exercising physical custody immediately preceding or immediately following the holiday, shall be entitled to expand his/her alternating weekend period of physical custody to include the holiday. For example, if July Fourth falls on the Friday immediately preceding Mother's regularly scheduled alternating weekend custody period, she will exercise custody from Friday, the day of the holiday, at 10:00 a.m. until her regularly scheduled time on Monday, If July Fourth falls on the Monday immediately following Father's regularly scheduled alternating weekend custody period, he will exercise custody from Friday at his regularly scheduled time until Monday, the day of the holiday, at 8:00 p.m. E. Thankseivine. Thanksgiving shall be divided into two segments, Segment A and Segment B. Segment A shall be from Wednesday before Thanksgiving after school until Thanksgiving Day at 2:00 p.m. Segment B shall be from Thanksgiving Day at 2:00 p.m. until the Friday after Thanksgiving at 6:30 p.m. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. In odd-numbered years, Father shall have Segment A and Mother shall have Segment B. F. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 24th at 5:00 p.m. until December 25th at 5:00 p.m, Segment B shall be from December 25th at 5:00 p.m. until December 28th at 6:30 p.m. In all even-numbered years, Father shall have Segment A and Mother shall have Segment B, In odd-numbered years, Mother shall have Segment A and Father shall have Segment B, 4. Summer Vacation. Each parent shall be entitled to exercIse two (2) non- consecutive, uninterrupted, weeks of physical custody, during the summer months of June, July and August, with thirty (30) days written notice to the other parent. Each parent agrees to coincide his/her uninterrupted week of custody with his/her alternating weekend custody scheduJe. 5. Transportation. The parties will meet at the usual half-way meeting place for all custodial exchanges, except on those dates and times set forth above, when Mother shall assume sole responsibility for transportation. 6. The parties shall continue in their therapeutic counseling work with Bonnie Howard, 7. Both parties shall establish a no-conflict zone for the child and refrain from making derogatory comments about the other parent in the presence of the child and to the extend possible shall prevent third parties from making such comments in the presence of the child. 8, The parties shall keep each other informed of their respective current addresses and telephone numbers. BY THE COURT: J. , '" J~~' LP( f~~ r-S .\ -0 ~.\ 'i o