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HomeMy WebLinkAbout10-0539BAYLEY & MANGAN Mark Bayley, Esquire Attorney I.D. #: 87663 17 West South Street Carlisle, PA 17013 (717) 241-2446 STEVEN SITES, VS. JAMIE SITES, Plaintiff Defendant t +? = ? - CJl - -n " f•J : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 10 - CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 "v436;a -D6 '*? " ?p# //// lC,W J3 71,/1 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common :Pleas of Cumberland County, Pennsylvania, is required by law to comply with the Americans with Disabilities 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. STEVEN SITES, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JAMIE SITES, NO. lo- 6 3,? CIVIL TERM Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Steven Sites, an adult individual, who resides at 8018 Roxbury Rd., Logan, PA 17232. 2. Defendant is Jamie Sites, an adult individual, who resides at 7889 Roxbury Rd., Shippensburg, PA 17257. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 1, 2008 in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: Respectfully submitted, BAYLEY & MANGAN Uk4 Mark F. Bayley, Esq re 17 West South St. Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 STEVEN SITES, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JAMIE SITES, NO. 10 - CIVIL TERM Defendant IN DIVORCE VERIFICATION I, STEVEN SITES, verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: J/O--D/io?? _ STEVEN SITES, Plaintiff F . STEVEN SITES, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. r..ry r. : CIVIL ACTION - LAW f - JAMIE SITES, : NO. 10 - 51301 CIVIL TERM' q Defendant : IN DIVORCE . ...A ., co +-D { DEFENDANT'S ANSWER AND COUNTERCLAIM TO PLAINTIFF'S COMPLAINT AND NOW, comes Jamie Sites, Defendant, by and through her counsel, Robert A. Kulling, Esquire, and in support of her Answer and Counterclaim to Plaintiff s Complaint, submits the following: 1. Admitted. 2. Denied. Defendant resides at 229 Middle Road, Newville, Pennsylvania 17241. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. rct w a ?? a % ass, S _J ?I'7[ilrl COUNTERCLAIM COUNT I. REQUEST FOR CONFIRMATION OF CUSTODY 1. The plaintiff is Steven D. Sites, residing at 8018 Roxbury Road, Lurgan, Pennsylvania 17232. 2. The defendant is Jamie Sites, residing at 229 Middle Road, Newville, Pennsylvania 17241. 3. Defendant seeks custody of the following child: Name Present Residence DOB Age Collin Bonru Sites 229 Middle Road 11/14/06 4 yrs 3 mths Newville PA 17241 4. The child was born out of wedlock 5. The child is presently in the custody of Jamie Sites who resides at 229 Middle Road, Newville, Pennsylvania 17241. 6. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Jamie Sites 7514 Roxbury Road Birth to 8 mths of age Lurgan, PA 17232 Jamie Sites & Parents 7889 Roxbury Road 8 mths to 2 yrs 2 mths Shippensburg, PA Jamie & Steven Sites 8019 Roxbury Road 2 yrs 2 mths to 3 yrs 2 mths Lurgan, PA Jamie Sites & Parents 7889 Roxbury Road January 2010 to August 2010 Shippensburg, PA Jamie Sites & 229 Middle Road August 11, 2010 to Current Shawn Baker Newville, PA 7. The mother of the child is Jamie Sites residing at 229 Middle Road Newville Pennsylvania 17241. , , 8. She is married. 2 9. 10. 11. 12. 13. 14. 15. 16. The father of the child is Steven Sites, currently residing at 8418 Roxbury Road, Lurgan, Pennsylvania 17232. He is married. The relationship of plaintiff to the child is that of Father. The defendant currently resides with the following persons. Name Relationship The relationship of defendant to the child is that of Mother. The defendant currently resides with the following persons. Name Shawn Baker Relationship Boyfriend Defendant 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. Defendant has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 17. Defendant does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 18. The best interest and permanent welfare of the child will be served by granting the relief request because: Defendant has undertaken and performed the primary parental responsibilities for her child; Defendant is best able to provide the care and nurture which the child needs for healthy development; Defendant desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child; and The continuing welfare of the child will be assured if custody is awarded to the Defendant pending the hearing on this petition subject to such partial custody for purposes of visitation as may be mutually agreed between the parties. 19. Defendant has undertaken and performed the primary parental responsibilities for the child. 20. A Court Order of custody and structured visitation is desired so that the Defendant and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. 21. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Defendant requests this Honorable Court to grant Defendant physical and legal custody of the minor child. COUNT II. REQUEST FOR EQUITABLE DISTRIBUTION OF MARTIAL PROPERTY 22. All previous paragraphs are incorporated herein as if set forth in full. 23. A Divorce action was filed by the Plaintiff on January 25, 2011. 24. Defendant seeks economic relief of various issues of personal property and liabilities which are subject to equitable distribution. WHEREFORE, Defendant requests this Honorable Court to grant Defendant resolution of the economic issues. Respectfully submitted, R I GER & ASSOCIATES Date: a. -?$- By: Robert A. Kulling, Esquire Attorney for Defendant 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 308874 4 VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. rarnie Sites, Defendant STEVEN SITES, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW JAMIE SITES, : NO. 10 - CIVIL TERM Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Robert A. Kulling, Esquire, do hereby certify that I served a copy of the Counterclaim and Answer upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 Attorney for Plaintiff Respectfully submitted, ROMINGER & ASSOCIATES Dated _195? Robert A. Kulling, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 308874 Attorney for Defendant 6 STEVEN SITES, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLGN0j '-n 3 -? fry w VS. =tin ; ry 72 r- : CIVIL ACTION -LAW JAMIE SITES, : NO. 10 - 539 CIVIL TERM rte- ° - Defendant : IN DIVORCE _ aC - AMENDED ?- DEFENDANT'S ANSWER AND COUNTERCLAIM TO PLAINTIFF'S COMPLAINT AND NOW, comes Jamie Sites, Defendant, by and through her counsel, Robert A. Kulling, Esquire, and in support of her Answer and Counterclaim to Plaintiff s Complaint, submits the following: 1. Admitted. 2. Denied. Defendant resides at 229 Middle Road, Newville, Pennsylvania 17241. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. 1 COUNTERCLAIM COUNT I. REQUEST FOR CONFIRMATION OF CUSTODY 1. The plaintiff is Steven D. Sites, residing at 8018 Roxbury Road, Lurgan, Pennsylvania 17232. 2. The defendant is Jamie Sites, residing at 229 Middle Road, Newville, Pennsylvania 17241. 3. Defendant seeks custody of the following child: Name Present Residence DOB Age Collin Bonru Sites 229 Middle Road 11/14/06 4 yrs 3 mths Newville PA 17241 4. The child was born out of wedlock 5. The child is presently in the custody of Jamie Sites who resides at 229 Middle Road, Newville, Pennsylvania 17241. 6. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Jamie Sites 7514 Roxbury Road Birth to 8 mths of age Lurgan, PA 17232 Jamie Sites & Parents 7889 Roxbury Road 8 mths to 2 yrs 2 mths Shippensburg, PA Jamie & Steven Sites 8019 Roxbury Road 2 yrs 2 mths to 3 yrs 2 mths Lurgan, PA Jamie Sites & Parents 7889 Roxbury Road January 2010 to August 2010 Shippensburg, PA Jamie Sites & 229 Middle Road August 11, 2010 to Current Shawn Baker Newville, PA 7. The mother of the child is Jamie Sites residing at 229 Middle Road, Newville, Pennsylvania 17241. 8. She is married. 2 9. 10. 11. 12. 13. 14. 15. 16. The father of the child is Steven Sites, currently residing at 8018 Roxbury Road, Lurgan, Pennsylvania 17232. He is married. The relationship of plaintiff to the child is that of Father. The defendant currently resides with the following persons. Name Relationship The relationship of defendant to the child is that of Mother. The defendant currently resides with the following persons. Name Shawn Baker Relationship Boyfriend Defendant 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. Defendant has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 17. Defendant does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 18. The best interest and permanent welfare of the child will be served by granting the relief request because: Defendant has undertaken and performed the primary parental responsibilities for her child; Defendant is best able to provide the care and nurture which the child needs for healthy development; Defendant desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child; and The continuing welfare of the child will be assured if custody is awarded to the Defendant pending the hearing on this petition subject to such partial custody for purposes of visitation as may be mutually agreed between the parties. 19. Defendant has undertaken and performed the primary parental responsibilities for the child. 20. A Court Order of custody and structured visitation is desired so that the Defendant and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. 21. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Defendant requests this Honorable Court to grant Defendant physical and legal custody of the minor child. COUNT II. REQUEST FOR EQUITABLE DISTRIBUTION OF MARTIAL PROPERTY 22. All previous paragraphs are incorporated herein as if set forth in full. 23. A Divorce action was filed by the Plaintiff on January 25, 2011. 24. Defendant seeks economic relief of various issues of personal property and liabilities which are subject to equitable distribution. WHEREFORE, Defendant requests this Honorable Court to grant Defendant resolution of the economic issues. Respectfully submitted, ROMINGER & ASSOCIATES Date: 3-L5- By: *bejrrS--tA. Kulling, Esquire Attorney for Defendant 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 308874 4 VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unworn falsification to authorities. 04, , Jamie Sites, Defendant 5 STEVEN SITES, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW JAMIE SITES, : NO. 10 - CIVIL TERM Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Robert A. Kulling, Esquire, do hereby certify that I served a copy of the Counterclaim and Answer upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 Attorney for Plaintiff Dated& Respectfully submitted, ROMINGER & ASSOCIATES Robert A. Kulling, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 308874 Attorney for Defendant 6 STEVEN SITES IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. C-) C cam', = -a 2010-539 CIVIL ACTION LAW rnCa 2 JAMIE SITES IN CUSTODY oC C DEFENDANT .,0 z- D C W ORDER OF COURT AND NOW, Monday, Ap ril 04, 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, May 10, 2011 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, Esq. OA Custody Conciliator F, 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 STEVEN SITES, Plaintiff V. JAMIE SITES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2010-539 : IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW,,,, c ao rn c„ =rn C= r- ? > ? -0 3Z AND NOW, this day of r"OVJQ_ 2011 u on consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Steven Sites and the Mother, Jamie Sites, shall have shared legal custody of Collin Bonru Sites, born November 14, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor 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. Father shall have the following periods of physical custody: A. Beginning June, 2011, and alternating months thereafter, three weekends per month and 2 weekends per month, from Friday at 11:00 a.m. to Sunday at 5:00 p.m. M_ r- ? m :p B. Every Tuesday and Friday from 11:30 a.m. to 5:30 p.m. 3. Mother shall have physical custody when Father does not have physical custody except as set forth hereinafter. 4. Holidays: A. Thanksgiving and Easter shall be shared as agreed with the exchange time being 2:00 p.m. B. Christmas shall be divided into two Blocks. Block A shall be from 2:00 p.m. Christmas Eve to 2:00 p.m. Christmas Day. Block B shall be from 2:00 p.m. Christmas Day to 2:00 p.m. December 26. Mother shall have physical custody of the child for Block A in odd numbered years and Block B in even numbered years. Father shall have physical custody of the child for Block A in even numbered years and Block B in odd numbered years. C. Mother shall have physical custody of the child for Mother's Day from 9:00 a.m. to 5:00 p.m. Father shall have physical custody of the child on Father's Day from 9:00 a.m. to 5:00 p.m. D. Memorial Day, July 4th and Labor Day shall be alternated with Father having July 4th in 2011. Times shall be from 5:00 p.m. the day of the holiday to 5:00 p.m. the day after the holiday. E. The parties shall have two non-consecutive, uninterrupted weeks of physical custody in the summer provided they give the other party 30-days prior notice. 5. Transportation shall be shared such that the parties shall meet at B&B grocery store in Newburg, Pennsylvania. 6. 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 Conciliation Conference is scheduled for July 6, 2011 at 10:30 a.m. BY T ? ogle" . cc: Mark F. Bayley, Esquire, Counsel for Father 00 & . '? Robert A. Kulling, Esquire, Counsel for Mother t01 41011A V STEVEN SITES, Plaintiff V. JAMIE SITES, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2010-539 CIVIL ACTION - LAW : IN CUSTODY 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 Collin Bonru Sites November 14, 2006 Mother 2. A Conciliation Conference was held in this matter on June 3, 2011, with the following in attendance: The Father, Steven Sites, with his counsel, Mark F. Bayley, Esquire, and the Mother, Jamie Sites, with her counsel, Robert A. Kulling, Esquire. The parties agreed to an Order in the form as attached. Date: Jac eline M. Verney, Esquire Custody Conciliator STEVEN SITES, Plaintiff V. JAMIE SITES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2010-539 : IN CUSTODY ORDER OF COURT CIVIL ACTION - L&W N c rrIm cnr -<> W C ?C-) J Zo y,, c ca -_j AND NOW, this S day of V u , 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated June 7, 2011 shall remain in full force and effect with the following modifications. 2. Father shall have the following periods of partial physical custody: A. Alternating months, three weekends per month and two weekends per month, from Friday at 11:00 a.m. to Sunday at 5:00 p.m. B. On the weekends that Father does not have physical custody for the entire weekend, he shall have physical custody from Friday at 11:00 a.m. to Saturday at 11:00 a.m. C. During the summer, every Tuesday from 11:00 a.m. to 5:00 p.m. D. During the school year, every Tuesday from 1:30 p.m. to 7:30 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. BY THE C , ? J. cc: Mark F. Bayley, Esquire, Counsel for Father ?Robert A. Kulling, Esquire, Counsel for Mother cow w"- =-n rn73m a CD .?y 04-! R. STEVEN SITES, Plaintiff V. JAMIE SITES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2010-539 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, 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 Collin Bonru Sites November 14, 2006 Mother 2. A Conciliation Conference was held in this matter on July 7, 2011, with the following in attendance: The Father, Steven Sites, with his counsel, Mark F. Bayley, Esquire, and the Mother, Jamie Sites, with her counsel, Eric David, Esquire, substituting for Robert A. Kulling, Esquire. 3. The Honorable Edward E. Guido previously entered an Order of Court dated June 7, 2011 providing for shared legal custody, Mother having primary physical custody and Father having periods of partial physical custody three weekends for alternating months, two weekends on alternating months and every Tuesday and Friday. 4. The parties agreed to an Order in the form as attached. Date: '?. Jacq linMe erney, Esquire Custody Conciliator STEVEN SITES IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAN V' 2010-539 CIVIL ACTION LAW n cam`,' rs.) JAIME SITES s- t = " IN CUSTODY -" DEFENDANT C7 ORDER OF COURT AND NOW, Friday, June 22, 2012 , 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 Wednesday, July 25, 2012 at 1:30 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/ acgueline M. Verney, 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 ?li?? D Telephone (717) 249-3166 STEVEN SITES, Plaintiff V. JAMIE SITES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2010-539 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this At ay of y , 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated July 8, 2011 and June 7, 2011 are hereby vacated, effective August 26, 2012. 2. The Father, Steven Sites and the Mother, Jamie Sites, shall have shared legal custody of Collin Bonru Sites, born November 14, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor 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. Father shall have the following periods of physical custody: A. During the school year alternating weekends from Friday after school to Sunday at 8:00 p.m. and every Tuesday from after school to 8:00 p.m. i B. During the summer, three weekends in June and August and two weekends in July, from Friday at 4:00 p.m. to Sunday at 8:00 p.m. and every Tuesday at 2:00 p.m. overnight to Wednesday at 2:00 p.m. 4. Mother shall have physical custody when Father does not have physical custody except as set forth hereinafter. 5. Holidays: A. Thanksgiving and Easter shall be shared as agreed with the exchange time being 2:00 p.m. B. Christmas shall be divided into two Blocks. Block A shall be from 2:00 p.m. Christmas Eve to 2:00 p.m. Christmas Day. Block B shall be from 2:00 p.m. Christmas Day to 2:00 p.m. December 26. Mother shall have physical custody of the child for Block A in odd numbered years and Block B in even numbered years. Father shall have physical custody of the child for Block A in even numbered years and Block B in odd numbered years. C. Mother shall have physical custody of the child for Mother's Day from 9:00 a.m. to 5:00 p.m. Father shall have physical custody of the child on Father's Day from 9:00 a.m. to 5:00 p.m. D. Memorial Day, July 4`h and Labor Day shall be alternated with Father having July 4th in 2011. Times shall be from 5:00 p.m. the day of the holiday to 5:00 p.m. the day after the holiday. E. The parties shall have two non-consecutive, uninterrupted weeks of physical custody in the summer provided they give the other party 30-days prior notice. F. New Years shall be divided into two Blocks. Block A shall be from 12:00 noon on New Year's Eve to 12:00 noon on New Year's Day. Block B shall be from 12:00 noon New Year's Day to 12:00 noon on January 2. Mother shall have Block A in even numbered years and Block B in odd numbered years. Father shall have Block A in odd numbered years and Block B in even numbered year. New Year's Eve date shall determine odd/even years. 6. Transportation shall be shared such that the parties shall meet at B&B grocery store in Newburg, Pennsylvania, except when Father picks up at school. 7. RELOCATION: No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C. S. § 5337. 8. 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 Edward E. Guido, J. Mark F. Bayley, Esquire, Counsel for Father Lee Mandarin, Esquire, Counsel for Mother P, e s m4 ,'la 7?3o?ia kn m rn C G A w 0 a 3 rv rn_ r" STEVEN SITES, Plaintiff V. JAMIE SITES, Defendant PRIOR JUDGE: Edward E. Guido, 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: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2010-539 CIVIL ACTION - LAW : IN CUSTODY 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 Collin Bonru Sites November 14, 2006 Mother 2. A Conciliation Conference was held in this matter on July 25, 2012, with the following in attendance: the Mother, Jamie Sites, with her counsel, Lee Mandarino, Esquire and the Father, Steven Sites, with his counsel, Mark F. Bayley, Esquire. 3. The Honorable Edward E. Guido previously entered Orders of Court dated July 8, 2011 and June 7, 2011 providing for shared legal custody, Mother having primary physical custody and Father having alternating months three weekends and two weekends and every Tuesday. 4. The parties agreed to an Order in the form as attached. Date: 7 -2 S ' Jac eline M. Verney, Esquire Custody Conciliator