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HomeMy WebLinkAbout09-6134Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs STEVEN RAY BREWER and IN THE COURT OF COMMON PLEAS OF DEBRA BREWER, husband and wife, and CUMBERLAND COUNTY, PENNSYLVANIA STEVEN GREGORY BREWER, Plaintiffs V. NO. 09- It 3 I CIVIL ACTION - LAW REBECCA JOLENE MOCK a/k/a REBECCA OSGOOD, Defendant IN CUSTODY PLAINTIFFS' COMPLAINT FOR CUSTODY 1. Plaintiffs are Steven R. Brewer and Debra A. Brewer (hereinafter, "Grandparents"), adult individuals currently residing at 23 Smith Road, Gardners, Cumberland County, Pennsylvania. They are the paternal grandparents of the child. 2. Plaintiff is Steven G. Brewer (hereinafter, "Father"), an adult individual currently residing at 4105 Carfew Court, Fayetteville, NC 23812. He is the Natural Father of the child and is in the military. 3. Defendant is Rebecca Jolene Mock a/k/a Rebecca Osgood (hereinafter, "Mother") an adult individual currently residing at 4032 Palaverde Drive, Kennesaw, GA 30144. She is the Natural Mother of the child. 4. Grandparents and Father seek to have Grandparents obtain primary custody of the child, Aslan Steven Brewer, who was born on September 24,1996. The child was born in wedlock. 5. Mother and Father were married on March 23, 1996, and divorced on September 23, 1998. 6. Since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: Time Period Persons Location August 2004-June 2005 June 2005- April 2006 April 2006-April 2007 Father and Stepmother Mother, Mother's boyfriend, half sister & half brother 23 Oak Lane Drive Carlisle, PA 17013 17 Austin St., Apt. A, Wellsboro, PA 16901 Mother, Mother's three different 130 Wall Street boyfriends, half sister & half brother Corning, NY 14830 April 2007-Present Grandparents 23 Smith Road Gardners, PA 17324 7. Grandparents are married and reside with the following: Name Relationship Steven R. Brewer Husband Debra Brewer Wife Aslan Brewer Grandson 8. Father is married and living separately. Father currently resides with the following: Name Relationship Michelle Brewer Wife Cavan G. Brewer Son Lorelei F. Brewer Daughter 9. Mother is married and living separately. Mother currently resides with the following: Name Relationship Name Unknown Mother's Step-mother Josh Rogalski Mother's Half-brother Andrew Rogalski Mother's Half-brother 11. Father petitioned for custody of Aslan in the state of Kentucky. A temporary Order for sole custody was given to Father on April 21, 1998, Docket Number 98-CI-00160. The Decree in Divorce issued in Kentucky on September 23, 1998, granted both Father and Mother joint custody with Father as the primary caregiver and allowed Mother certain visitation times. 12. The best interest and permanent welfare of the child will be served by granting the relief requested because Grandparents can best provide for the child's spiritual, physical and emotional welfare because: a. For the past two and one-half years, the child has resided with Grandparents who have been the primary care givers. b. During Mother's periods of custody in the past, she has been arrested multiple times, incarcerated at least twice, and has otherwise put the child at risk. C. It is believed and therefore averred, that Mother is unfit to have unsupervised custody of the child, due to allegations that she was both using drugs and having sex in front of the child when she had custody, and the child was removed from her custody by New York State authorities for neglect and child endangerment. d. Both natural parents signed over Guardianship of Aslan in 2007, and he has remained in Grandparents' primary custody. e. Grandparents are best able to provide a stable home environment for the child. f. Grandparents can best provide for the child's emotional, financial, educational and medical well-being. g. Grandparents have and can continue to provide for all of the child's educational needs, having been the parent who has attended all of the teacher conferences, school functions and other educational exams. h. Grandparents encourage and facilitate a relationship between the child and his biological parents. i. Grandparents desire to exercise primary custody of the child. 13. Grandparents and Father do not know of any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child. P WHEREFORE, Grandparents and Father request your Honorable Court to set a time and place for a hearing at which Grandparents and Father request the Court to grant Grandparents the Custody Order. Pending said hearing, Grandparents request primary custody. MARTSON LAW OFFICES By k-? Jennifer L. , Esquire 10 East High Suva Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs Date: September 8; 2009 4 VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Steven R. Brewer e 11 VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. oJ-JL Debra er i. 'Oor VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Steven G. Brewer FILED-Chl"FICE ,,OF THE PFOTHC)" OTAFY 1009 SEP -9 PM l : S 1 = L= °4D' C""" iNTY r I~ INSYLVANA e? ?ts?ry _ IT- 4w%. -N STEVEN RAY BREWER, DEBRA BREWER, IN THE COURT OF COMMON PLEAS OF AND STEVEN GREGORY BREWER PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-6134 CIVIL ACTION LAW REBECCA JOLENE MOCK A/K/A REBECCA IN CUSTODY OSGOOD DEFENDANT ORDER OF COURT AND NOW, Monday, September 14, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, October 23, 2009 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ohn . Man an r. Es q. 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 BLED- OF','?E 2009 SEP 15 AM 10: 5. 0 r'i .;?. Jx;f,, A 401 :2,A-eW 41/4 OCT 3 0 2009 6 K STEVEN RAY BREWER, DEBRA BREWER, : IN THE COURT OF COMMON PLEAS OF and STEVEN GREGORY BREWER. CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. No. 09-6134 CIVIL ACTION LAW REBECCA JOLENE MOCK A/K/A IN CUSTODY REBECCA OSGOOD Defendant ORDER OF COURT AND NOW this 3 Ott day of October 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Paternal Grandparents, Steven R. Brewer and Debra Brewer, the Father, Steven G. Brewer, and the Mother, Rebecca Mock, shall have shared legal custody of Aslan Steven Brewer, born 09/24/1996. The parties shall have an equal right to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each party 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 parties. To the extent one party has possession of any such records or information, that party shall be required to share the same, or copies thereof, with the other parties within such reasonable time as to make the records and information of reasonable use to the other parties. 2. Physical Custody: The Paternal Grandparents, Steven R. and Debra Brewer, shall have primary physical custody of the Child subject to Mother's and Father's physical custody as follows: a. Mother shall have supervised physical custody of Aslan 10/23/09 from 4:00 pm until 7:00 pm in a public setting and on 10/24/09 from 4:00 pm until between 8:00 pm and 9:00 pm again in a public setting such as Hershey Park or a bowling alley. Paternal Grandparents shall be present for the 10/23/09 visit and shall be in close proximity of Aslan on 10/24/09. b. Mother shall have supervised physical custody of Aslan November 27, 2009 and November 28, 2009 from 2:00 pm until 7:00 pm with Paternal Grandparents in close proximity of Aslan. C. For the Christmas holiday, Mother shall four days of contact with Aslan. The first two days shall be supervised for a period of time during the day with Paternal Grandparents in close proximity of Aslan. The second two days shall be for a period of time during the day unsupervised. The parties shall determine the hours of contact and specific days by mutual agreement. d. Mother may have additional periods of custody as can be agreed between the parties. e. Father shall have physical custody of Aslan as can be arranged between himself and Paternal Grandparents as agreed. 3. The parents shall have liberal telephone, internet and email contact with the Child on a reasonable basis. In the absence of agreement, Mother shall have telephone contact three times per week on Tuesday, Thursday and Sunday no later than 7:00 pm. 4. Mother shall not remove the Child from this jurisdiction without express written permission from the Paternal Grandparents or absent further Order of Court. 5. No party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other parry, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage any other party in the presence of the Child. 6. In the event of a medical emergency, the custodial party shall notify the other parties as soon as possible after the emergency is handled. 7. During any periods of custody or visitation, the parties shall not possess or use/be under the influence of illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 8. A status update conciliation conference is hereby scheduled for January 05, 2010 at 10:30 am at the Court of Common Pleas, Carlisle, PA. Mother and Father may participate via telephone if desired. 9. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, PAS J. g bution: ./J es Nealon, Esquire Jenifer Spears, Esquire ,/John J. Mangan, Esquire COF t 6 rY e' -t t?f?J 1114 JOT STEVEN RAY BREWER, DEBRA BREWER, : IN THE COURT OF COMMON PLEAS OF and STEVEN GREGORY BREWER. CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. No. 09-6134 CIVIL ACTION LAW REBECCA JOLENE MOCK A/K/A IN CUSTODY REBECCA OSGOOD Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Aslan Steven Brewer 09/24/1996 Paternal Grandparents 2. A Conciliation Conference was held with regard to this matter on October 23, 2009 with the following individuals in attendance: The Mother, Rebecca Mock, with her counsel, James Nealon, Esq. The Father, Steven G. Brewer, did not appear, but represented by Jennifer Spears, Esq. Paternal Grandparents, Steven R. Brewer and Debra Brewer, with their counsel, Jennifer Spears, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date Jo gan, Esquire Cu ody Conciliator r? t - C,"- T',ru f •?f Yt fir?!'{:'.) BAR 1 2009 NOV -4 PH t-,: 03 UPI iY fi r?'N'SYLVA441A. ~' JAN 12 2010 STEVEN RAY BREWER, DEBRA BREWER, : IN THE COURT OF COMMON PLEAS OF and STEVEN GREGORY BREWER. CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v No. 09-6134 CIVIL ACTION LA~ °- ~-~ . ~~_ ~ -a ~~ ~ REBECCA JOLENE MOCK A/K/A IN CUSTODY ~~' ` _:-: ~ ~ REBECCA OSGOOD ~-; _ w ~ :. ~ ~ , Defendant ~ `-~ _; ± C ~ Y'1 Prior Judge: M.L. Ebert, Jr. ~~ ~- ~° `~ :~ rev ORDER OF COURT AND NOW this ~7- day of January 2010, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. All prior Orders of Court entered in this matter are hereby VACATED and replaced with this Order. 2. Legal Custody: The Paternal Grandparents, Steven R. Brewer and Debra Brewer, the Father, Steven G. Brewer, and the Mother, Rebecca Mock, shall have shared legal custody of Aslan Steven Brewer, born 09/24/1996. The parties shall have an equal right to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each party 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 parties. To the extent one party has possession of any such records or information, that party shall be required to share the same, or copies thereof, with the other parties within such reasonable time as to make the records and information of reasonable use to the other parties. 3. Physical Custody: The Paternal Grandparents, Steven R. and Debra Brewer, shall have primary physical custody of the Child subject to Mother's and Father's physical custody as follows: a. Mother shall have physical custody of Aslan for a period of time in Georgia during the month of July 2010 as follows: Mother shall have custody one overnight with maternal step-grandmother when Aslan arrives in Georgia, seven overnights (one week) with maternal grandmother and three overnights with maternal step-grandmother before Aslan leaves Georgia. b. Mother shall provide paternal grandparents with specific dates for this period of physical custody no later than June O1, 2010. The paternal grandparents have agreed to facilitate travel to and from BWI. Mother has agreed to, and shall, provide the financial cost for the flights. c. Paternal grandparents and/or Father has the right to request that Mother submit to a drug test prior to Aslan going into her custody and to receive the results of the test. d. Mother may have additional periods of custody here in Pennsylvania as can be agreed between the parties. e. Father shall have physical custody of Aslan as can be arranged between himself and Paternal Grandparents as agreed. 3. The parents shall have liberal telephone, Internet and email contact with the Child on a reasonable basis. In the absence of agreement, Mother shall have telephone contact three times per week on Tuesday, Thursday and Sunday no later than 7:00 pm. 4. Mother shall not remove the Child from this jurisdiction without express written permission from the Paternal Grandparents or absent further Order of Court. 5. No party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage any other party in the presence of the Child. 6. In the event of a medical emergency, the custodial party shall notify the other parties as soon as possible after the emergency is handled. 7. During any periods of custody or visitation, the parties shall not possess or use/be under the influence of illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 8. A status update conciliation conference is hereby scheduled for September 7 2010 at 9.00 am at the Court of Common Pleas. Carlisle, PA. Mother and Father may participate via telephone if desired. 9. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, D' tribution: es Nealon, Esquire ~/Je~ifer Spears, Esquire /John J. Mangan, Esquire ~D t ~ES -~'L~t l~ P ~/l 3 ~ 1 d _~.~ ~~ STEVEN RAY BREWER, DEBRA BREWER, : 1N THE COURT OF COMMON PLEAS OF and STEVEN GREGORY BREWER. CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs . v. No. 09-6134 CIVIL ACTION LAW REBECCA JOLENE MOCK A/K/A IN CUSTODY REBECCA OSGOOD Defendant Prior Judge: M. L. Ebert, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Aslan Steven Brewer 09/24/1996 Paternal Grandparents 2. A Conciliation Conference was held with regard to this matter on October 23, 2009, an Order of Court was issued October 30, 2009 and a conciliation conference was held January O5, 2010 with the following individuals in attendance: The Mother, Rebecca Mock, with her counsel, James Nealon, Esq. The Father, Steven G. Brewer, telephonically, and represented by Jennifer Spears, Esq. Paternal Grandparents, Steven R. Brewer and Debra Brewer, with their counsel, Jennifer Spears, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date John an, squire Custo C nciliator F:~FILES\CGrnts\13520 Brewer113520. Lcoacur Created. 9/20104 0:06PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs STEVEN RAY BREWER and DEBRA BREWER, husband and wife, and STEVEN GREGORY BREWER, Plaintiffs v. REBECCA JOLENE MOCK a/k/a REBECCA OSGOOD , Defendant N <_- --- _ ; r 1.... _.; .~.. ~~. c.~ -- rn -- ~.. ; c ~.:., - -, : IN THE COURT OF COMMON PLEAS OE, ~I CUMBERLAND COUNTY, PENNSYLVANIA "`' NO. 09-6134 CIVIL ACTION -LAW IN CUSTODY CERTIFICATE OF CONCURRENCE/NON-CONCURRENCE I, Jennifer Spears, Esquire, attorney for Plaintiffs, hereby certify that I: Concur with Petition of James G. Nealon, III, to Withdraw as Counsel. [ ] Do Not Concur with the Petition of James G. Nealon, III, to Withdraw as Counsel. Date: ~ Z ~! / U MARTSON LAW OFFICES By C Jennife L. pears, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Certificate ofConcurrence/Non-Concurrence was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: James G. Nealon, III, Esquire 2411 North Front Street Harrisburg, PA 17110 MARTSON LAW OFFICES By T ' a D. Eckenroad Te East High Street Carlisle, PA 17013 (717) 243-3341 Dated: 1/28/10 ri~F~_ ',~ ~µ, - _ ,: James G. Nealon,111, Esquire NEALON LAW FIRM, PC Attorney I.D. #46457 P.O. Box 8514 Erie, PA 16505 (717) 648-3133 i nealon[~ng olawfi rm.com STEVEN RAY BREWER, DEBRA BREWER And STEVEN GREGORY BREWER PENNSYLVANIA Plaintiff VS. REBECCA JOLENE MOCK A/K/A, REBECCA OSGOOD Defendant 201 ~,`ui I & `~~ ~~ t_ 0010 _Y~vls f ~ Pm a %a~$ T. GiJ, ~, ;, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, N0.09-6134 CIVlL ACTION IN CUSTODY MOTION TO MAKE RULE ABSOLUTE 1. James G. Nealon, lil, Esquire is counsel of record for Defendant, Rebecca Jo{ene Mock, in the above captioned matter. 2. On January 25, 2010, This Honorable Court, per the Honorable Michael L. Ebert, Jr., issued a Rule to Show Cause upon all parties to show cause as to why James G. Nealon, III, Esquire, should not be permitted to withdraw as counsel for defendant. 3. Plaintiffs file a Concurrence to the Petition to Withdraw as Counsel. 4. Defendant has not filed a Response to the Petition. WHEREFORE, Petitioner, James G. Nealon, III, urges this Honorable Court to make the Rule Absolute and permit him to withdraw as counsel of record for the Defendant. Respectfully NEALON By: Date: -~~ y f v James G. Nealon, III, Esquire Attorney I.D. #46457 P.O. Box 8514 Erie, PA 16505 (717) 648-3133 M CERTIFICATE OF SERVICE AND NOW, this .~~day of August, 2010, I hereb certi that I hav Y fy a served the foregoing Motion to Make Rule Absolute on the following by U.S. Mail: Rebecca Mock 4032 Palaverde Drive Kennesaw, GA 30144 Jennifer L. Spears, 10 East High S Carlisle, PAS JAMES G. NEALON, III, ESQUIRE r AUG 19 2010 James G. Nealon, III, Esquire 14h'j 8 NEALON LAW FIRM, PC o?bLVG" Attorney I.D. #46457 P.O. Box 8514 Erie, PA 16505 (717) 648-3133 inealonOmplawfirm.com STEVEN RAY BREWER, DEBRA BREWER IN THE COURT OF COMMON PLEAS And STEVEN GREGORY BREWER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. REBECCA JOLENE MOCK A/K/A, REBECCA OSGOOD Defendant NO. 09-6134 CIVIL ACTION IN CUSTODY RULE ABSOLUTE 'th AND NOW, this A? day of August, 2010, upon consideration of the Motion to Make Rule Absolute, it is hereby Ordered and Decreed that James G. Nealon, III, Esquire, is permitted to Withdraw as Counsel for Defendant, Rebecca Jolene Mock, a/k/a Rebecca Osgood. BY THE COURT Distribution: R ecca Mock, 4032 Paloverde Drive, Kennesaw, GA 30144 Jennifer Spears, Esquire 10 East High Street, Carlisle, PA 17013 es G. Nealon, III, Esquire, 2411 North Front Street, Harrisburg, PA 17110 l.: iES rn4a tLd- ??.3/lc7 - :Ty'vj 3 F~.\FILES\Cliena\ U 520 Brewer\ 13520.1. custodystipulation. wpd Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs STEVEN RAY BREWER and DEBRA BREWER, husband and wife, and STEVEN GREGORY BREWER, Plaintiffs v. REBECCA JOLENE MOCK a/k/a REBECCA OSGOOD, Defendant OCT p 4 2010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6134 CIVIL ACTION -LAW IN CUSTODY STIPULATION FOR AN AGRE~ED~ORDER OF CUSTODY AND NOW on this ~ ~ day of Oc!~~ , 2010, upon consideration of the within stipulation of the parties, it is Ordered and Directed as follows: 1. The Order of January 12, 2010, shall remain in full force and effect with the following additions: a. Mother shall have physical custody of Aslan in Georgia for a period of three (3) weeks during July, 2011. Beginning in 2012, Mother shall have custody of Aslan for four (4) weeks each July. The parties may change the dates depending on Aslan's summer activities and Father's deployment and leave orders if they reach a mutual agreement. b. Mother shall provide paternal grandparents with specific dates for her summer period of custody no later than June 1st each year. Paternal grandparents will facilitate travel to and from BWI or any airport closer to them, and Mother shall be responsible for the costs of airfare or any other agreed upon form of travel. c. Holidays: Mother will have either Thanksgiving or Christmas each year with Aslan when he does not have school. Mother will also have one other holiday each year when Aslan is not in school, to be chosen from Easter, Memorial Day, Labor Day, or any other agreed upon school holiday. Mother and Paternal Grandparents will take into consideration Father's deployment and leave orders when deciding which holidays Mother will get each year. This document may be executed in multiple counterparts or any number of duplicate originals, but all of which shall constitute one in the same instrument. This parties consent to this Stipulation being entered as an Order of Court. Steven Ray Brewer, Plaintiff Debra Brewer, aintiff Steven Gregory Brewer, Plaintiff Jenn er .Spears, Esquire Attorney for Plaintiffs Rebecca Jolene Mock a/k/a Rebecca Osgood, Pro Se Defendant c~ t°'~ ~ ~. i :~ --~ -~ ~, -~ -~. -~. r- o ~ ~, ~ ~ a'~ ' l J .dws :~ p~ ~~ r~~~-- ~, ~ ~ ~~ ~rn - .r~~ _,., ~ ,~,r , N `~ BY E COURT: Date: IO ( ~ ~ '/ ~ean~~C/ L Spurs ~~ ,/ ~e~eeca I~to~~ C'~p; es w~..~ ~ed 1D~1 ja J. If?LG them, and Mother shall be responsible for the costs of airfaze or any other agreed upon form of travel. c. Holidays: Mother will have either Thanksgiving or Christmas each year with Asian when he does not have school. Mother will also have one other holiday each year when Asian is not in school, to be chosen from Easter, Memorial Day, Labor Day, or any other agreed upon school holiday. Mother and Paternal Grandparents will take into consideration Father's deployment and leave orders when deciding which holidays Mother will get each year. This document may be executed in multiple counterparts or any number of duplicate originals, but all of which shall constitute one in the same instrument. This parties consent to this Stipulation being entered as an Order of Court. Steven Ray Brewer, Plaintiff Rebecca Jolene Mock a/k/a Rebecca Osgood, Pro Se Defendant Debra Brewer, Plaintiff ~~.~ Steven Gregory Brewer, Plaintiff Jennifer L. Spears, Esquire Attorney for Plaintiffs BY THE COURT: Date: J. them, and Mother shall be responsible for the costs of airfare or any other agreed upon form of travel. c. Holidays: Mother will have either Thanksgiving or Christmas each year with Aslan when he does not have school. Mother will also have one other holiday each year when Aslan is not in school, to be chosen from Easter, Memorial Day, Labor Day, or any other agreed upon school holiday. Mother and Paternal Grandparents will take into consideration Father's deployment and leave orders when deciding which holidays Mother will get each year. This document may be executed in multiple counterparts or any number of duplicate originals, but all of which shall constitute one in the same instrument. This parties consent to this Stipulation being entered as an Order of Court. Steven Ray Brewer, Plaintiff Re ecca Jolene ck Rebecca Osgood, Pro Se Defendant Debra Brewer, Plaintiff Steven Gregory Brewer, Plaintiff Jennifer L. Spears, Esquire Attorney for Plaintiffs Date: BY THE COURT: J.