HomeMy WebLinkAbout00-02581 NMANDRE K. SANDERS, IN THE COURT OF COMMON PLEAS
Plaintiff
CUMBERLAND COUNTY, PENNSX-4VANIA`=' ;
.
VS. NO. 00-2581 CIVIL TERM r?
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;Tim
ELIZABETH STOTLER
,
Defendant CUSTODY.
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PETITION FOR CONTEMPT AND MODIFICATION Plaintiff, Andre K. Sanders, by and through his counsel, MidPenn Legal Services, states
the following:
1. Plaintiff, hereinafter referred to as Father, resides at 32 North East Street - Apartment
2, Carlisle, Cumberland County, Pennsylvania 17013.
2. Defendant, also known as Elizabeth Stotler Sanders, hereinafter referred to as Mother,
has a last known address at 26 South East Street, Carlisle, Cumberland County,
Pennsylvania 17013. Mother has since moved to Mount Holly Springs and refuses to
provide Father with her new address.
3. The above-named parties are the natural parents of Chelsie Stotler, born February 25,
1999.
4. A custody order was entered in this case on April 25, 2000, by The Honorable Kevin
A. Hess. The Order, in pertinent part, gives the parties shared legal custody. Father
and Mother shared physical custody with Father having three overnights each week
and during the day while Mother was at work. Mother had physical custody at all
other times. (See attached Exhibit A)
5. Mother has willfully disobeyed the current Order, and is not acting in Ch.elsie's best
interests in ways including, but not limited to, the following:
a. Mother has unilaterally decided to limit Father's ability to have visits with
Chelsie and does not allow Father to exercise his periods of partial physical
custody with Chelsie.
b. Mother has refused to work cooperatively with Father to help ensure an
ongoing father/daughter relationship with Chelsie.
c. Mother has moved from Carlisle to Mount Holly Springs and claims to not
transportation to ensure Father has his visits with Chelsie. Despite Mother's
claims of no transportation, Mother has not withdrawn Chelsie from the
school she attended while living in Carlisle and is frequently seen in Carlisle.
d. Mother has refused to provide Father with her new address and has not
changed Chelsie's information on her school records, leaving Father unable to
have or maintain consistent contact with Chelsie.
e. Mother's behavior suggests an attempt to cause Father to become estranged
from Chelsie and she is deliberately interfering with the father/daughter
relationship Father had previously established with Chelsie.
6. Father is entitled to a modification of the current order, which is in Chelsie's best
interest, for reasons including but not limited to the following:
a. Father has sought to maintain a relationship with Chelsie, despite various
situations that have negatively impacted his own life.
b. Father has a safe and stable home environment in which to exercise periods of
partial physical custody with Chelsie. Moreover, when Mother and Chelsie
lived in Carlisle, Chelsie frequently walked to Father's house and was with
him on almost a daily basis.
c. Father is committed to maintaining establishing his father/daughter
relationship with Chelsie.
d. Father is willing to work with Mother to cooperatively co-parent Chelsie.
7. Counsel for Father has contacted the Family Law Clinic which previously represented
Mother. The Family Law Clinic no longer represents Mother and it is unknown
whether Mother would concur with the relief requested in this petition.
WHEREFORE, Father respectfully requests that this Court find the following:
a. Respondent is in contempt of the April 25, 2000, Custody Order.
b. This matter is scheduled for conciliation.
c. That the parties shall share legal custody of Chelsie.
d. Father's visits with the child shall immediately be reinstated in accordance with the
custody schedule and accommodating the child's school schedule. Receiving party
shall be responsible for providing transportation.
e. The parties shall have reasonable contact via telephone and written correspondence
with the child when she is in the other parent's custody.
f. Any other relief this Court finds just and proper.
Resp ctfully submitted,
J Ad 'At, Esquire
idPenn Legal Services
401 East Louther Street
Carlisle, PA 17013
(717) 243-9400
VERIFICATION
The above-named PLAINTIFF, ANDRE K. SANDERS, verifies that
the statements made in the above Petition for contempt and
modification are true and correct. PLAINTIFF understands that
false statements herein are made subject to the penalties of 18
Pa. C.S. §4904, relating to unsworn falsification to
authorities.
Date: ? oZ0 /1
ANDRE K. SANDERS
ANDRE K. SANDERS,
Plaintiff
:1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO.2000-CIVIL TERM
ELIZABETH STOTLER,
Defendant :CUSTODY
TEMPORARY CUSTODY ORDER
AND NOW, this 25' day of April, 2000, upon consideration of the parties' Consent
Agreement, the following Order is entered with regard to custody of the parties' child, Chel.sie
Ann Stotler, D.O.B. February 25, 1999.
Plaintiff, hereinafter referred to as the ?, and Defendant, hereinafter referrednr'
to as the fa, shall share legal custody of the child. ?
2. The mother and father shall share physical custody of the child according to the
following schedule:
a. The father shall have custody three days (including overnights) each week
at times to be agreed upon by the father and mother.
b. The father shall have custody from 8:30 p.m. until 2:30 a.m. on days when
the mother is working; these periods of custody shall be at the mother's
residence.
C. The mother shall have custody those periods when the father.is not
scheduled to have custody in paragraphs 2a and 2b above.
3. The father and mother shall share custody on holidays and the child's birthday at
mutually agreed upon times.
4. The mother and father shall each have the right to take the child on a vacation of
three days (including to places outside Cumberland County or the state of Pennsylvania);
each shall give the other the address and phone number where the child can be reached in
case of an emergency.
5. The mother and father, by mutual agreement, may vary from this schedule at any
time, but the Order shall remain in effect until further order of court.
6. The mother shall not take the child to the home of her Aunt Fran on Pitt Street
during evenings when the mother is working.
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7. There shall be reasonable notice given to the other party if a scheduled period of
partial custody needs to be cancelled or modified and a make-up period shall be offered
within a reasonable time frame.
8. The mother and father agree that each shall notify the other immediately of
medical emergencies which arise while the child is in that parent's care.
9. :Neither party shall do anything which may estrange the child from the other
parent, or injure the opinion of the child as to the other parent or which may hamper the
free and natural development of the child love or respect for the other parent.
By the Court,
Judge
If entered pursuant to the consent of Plaintiff and Defendant:
Andre Kelvin Sanders, Pl
Joan Carey
Attorney for Plainti f
LEGAL SERVICES, INC.
J
E zabeth Stotler, Defendant
Attorney for Defendant pfd jr
FAMILY LAW CLINIC `?
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ANDRE K. SANDERS, IN THE COURT OF COMMON PLEAS
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 00-2581 CIVIL TERM
ELIZABETH STOTLER,
Defendant CUSTODY
CERTIFICATE OF SERVICE
I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for Plaintiff, Andre K. Sanders,
hereby certify that I have served a copy of the forgoing Petition for Contempt and Modification
by: USPS First Class Mail, Certified Mail, Electronic Receipt Requested:
Elizabeth Stotler (Sanders)
26 South East Street
Carlisle, PA 17013
Date: *I../# • ((
Je a olst, Esquire
MidPenn Legal Services
401 East Louther Street
Carlisle, PA 17013
(717)243-9400
L
ANDRE K. SANDERS,
Plaintiff
VS.
ELIZABETH STOTLER,
Defendant
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-2581 CIVIL TERM
CUSTODY
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Andre K. Sanders, Petitioner, to proceed in forma ap uperis.
I, Jessica Holst, attorney for the party proceeding in forma au eris, certify that I believe
the party is unable to pay the costs and that I am providing free legal services to the party.
3Midienn ols , Esquire
Legal Services
401 East Louther Street
Carlisle, PA 17013
(717) 243-9400
ANDRE K. SANDERS IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V
.
2000-2581 CIVIL ACTION LAW
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A70
ELIZABETH STOTLER nr_ m
_ -0rn
IN CUSTODY _<)> ,.
DEFENDANT
ORDER OF COURT --
AND NOW, Friday, February 11, 2011 upon consideration of the attached Co mplai nt,
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 Wednesday, March 23, 2011 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/ john J. Mangan, -&, 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 infonnation 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
07 ?? tp? 32 South Bedford Street
?/ Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
ANDRE K SANDERS,
Plaintiff
IV.
ELIZABE?H STOTLER,
Defendant
Prior Judge: Kevin A. Hess, P.J.
I
IN THE COURT OF COMMON PLIS ' .p_
CUMBERLAND COUNTY, PENI L N I€ I .--=
.
No. 00-2581 CIVIL ACTION LA% v PO I-
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IN CUSTODY',
ORDER OF COURT
1.
the
NOW this 24' day of April 2011, upon consideration of the attached Custody
Report, it is Ordered and Directed as follows:
s Petition for Contempt is hereby DISMISSED without prejudice and all prior Orders in
ant custody matter are replaced with the instant Order absent agreement otherwise.
2. Legal Custod : The Father, Andre Sanders, and the Mother, Elizabeth Stotler, shall have
shared legal custody of Chelsie Stotler, born 02/25/1999. The parties shall have an equal right
to make all major non-emergency decisions affecting the Child's general well-being including,
but of 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 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 pies thereof, with the other parent within such reasonable time as to make the records and
inf rmation of reasonable use to the other parent.
3. Ph ical Custod : Mother shall have primary physical custody of the Child subject to Father's
partial physical custody as follows:
5. Hol?days: The parents shall arrange a holiday schedule as mutually agreed upon.
a. During the school year, Father shall have physical custody of Chelsie every
Friday from after school until 10:00 pm. Father shall pick Chelsie up from
school and Mother shall pick Chelsie up from Father's residence at 10:00 pm.
'b. Father shall have physical custody of the Child at such other times as the parties
?I may mutually agree.
4. Th non-custodial parent shall have liberal telephone/email/text contact with the Child on a
rea onable basis.
6. Neither 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 the other
par nt in the presence of the Child.
7. In the event of a medical emergency, the custodial party shall notify the other party as soon as
possible after the emergency is handled.
8. Dulring any periods of custody or visitation, the parties shall not possess or use 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.
9. A
10. Thi 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,
x4L
Distributio : J
? The Famil Law Clinic AAa1?e11
Jessica Ho st, Esquire COPT es I ", I11
? John J. M gan, Esquire #01100
P.J.
V
ANDRE K. SANDERS,
Plaintiff
V.
ELIZABETH STOTLER,
Defendant
Prior Judge: Kevin A. Hess, P.J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 00-2581 CIVIL ACTION LAW
IN CUSTODY
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.
Date
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
Chelsie Stotler 02/25/1999 Primary Mother
A stipulated Order of Court was issued April 25, 2000, a petition for contempt and
modification was filed by Father and a Conciliation Conference was held with regard to
this matter on March 22, 2011 with the following individuals in attendance:
The Mother, Elizabeth Stotler, with her counsel, The Family Law Clinic
The Father, Andre Sanders, with his counsel, Jessica Holst, Esq.
2
The parties agreed to the entry of an Order in the form as attached.
3.
Y/Izz?l
JohegannA
, Esquire
Cus Y on
ciliator
V
ANDRE K. SANDERS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 00-2581 CIVIL ACTION LAW
ELIZABETH STOTLER, IN CUSTODY
Defendant
Prior Judge: Kevin A. Hess, P.J.
ORDER OF COURT
AND NOW this R day of October 2011, upon consideration of the attached Custody
Conciliation Report, it is Ordered and Directed as follows:
The prior Orders of Court are hereby superseded and replaced with the instant'Order.
2. Legal Custody: The Father, Andre Sanders, and the Mother, Elizabeth Stotler, shall have
shared legal custody of Chelsie Stotler, born 02/25/1999. 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 her 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 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.
3. Physical Custody: Mother shall have primary physical custody of the Child subject to Father's
partial physical custody as follows:
a. Father shall have custody of Chelsie on alternating weekends from Friday until
Sunday, the times to be by agreement of the parties. It has been agreed by the
parties that Father's current paramour, Wanda Campbell, not be unsupervised
while Chelsie is in Father's care.
b. Father shall have physical custody of the Child at such other times as the parties
may mutually agree.
4. The non-custodial parent shall have liberal telephone/email/text contact with the Child on a
reasonable basis.
5. Holidays: The parents shall arrange a holiday schedule as mutually agreed upon. In the
absence of agreement, the parties shall adhere to the schedule as attached.
6. Vacation: Each parent shall have one week of vacation with the Child per year. The requesting
parent shall give the other parent 30 days advance notice of the requested time and this vacation
week shall supersede the regular physical custody schedule. In the event the parties schedule
conflicting vacations, the party first providing written notice shall have the choice of vacation.
Prior to departure, the parties will provide each other with information regarding the intended
vacation destination and a telephone number at which they can be reached during their
9
vacation. The parties may expand this vacation time by mutual agreement.
7. Neither 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 the other
parent in the presence of the Child.
8. In the event of a medical emergency, the custodial party shall notify the other party as soon as
possible after the emergency is handled.
9. During any periods of custody or visitation, the parties shall not possess or use 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.
10. 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.
Distribution:
/The Family Law Clinic
?Jessica Holst, Esquire
V John J. Mangan, Esquire
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By the Court,
TIMES EVEN ODD
HOLIDAYS AND YEARS YEARS
SPECIAL DAYS
Easter Day 1St Half From 9 am until 3 m Father Mother
Easter Da 2n Half From 3 m until 9 m Mother Father
Memorial Day From 9 am until 9 pm Mother Father
Independence Day From 9 am until 9 m Father Mother
Labor Da From 9 am until 9 m Mother Father
Halloween From one hour before trick or Father Mother
treating to one hour after trick or
treating
Thanksgiving Pt From 8 am Thanksgiving Day to 2 Father Mother
Half m on Thanksgiving Day
Thanksgiving 2° From 2 pm on Thanksgiving Day to Mother Father
half noon the day after Thanksgiving Day
Christmas 1' Half From noon on 12/24 to noon on Father Mother
12/25
Christmas 2n Half From noon on 12/25 to noon on Mother Father
12/26
New Year's From 6 pm 12/31 until noon January Mother Father
1St (with the 12/31 year to control the
even/odd determination)
Mother's Day From 9 am until 9 m Mother Mother
Father's Da From 9 am until 9 pm Father Father
ANDRE K. SANDERS,
Plaintiff
V.
ELIZABETH STOTLER,
Defendant
Prior Judge: Kevin A. Hess, P.J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY., PENNSYLVANIA
No. 00-2581 CIVIL ACTION LAW
IN CUSTODY
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:
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
Chelsie Stotler 02/25/1999 Primary Mother
2. A stipulated Order of Court was issued April 25, 2000, a petition for contempt and
modification was filed by Father and a Conciliation Conference was held with regard to
this matter on March 22, 2011, an Order issued April 26, 2011 and a conference was
held June 10, 2011 with the following individuals in attendance:
The Mother, Elizabeth Stotler, with her counsel, The Family Law Clinic
The Father, Andre Sanders, with his counsel, Jessica Holst, Esq.
3. The parties agreed to the entry of an Order in the form as attached.
Date John J. ansquire
Custody Co ciliator
.ANDRE K. SANDERS,
Petitioner
vs.
ELIZABETH STOTLER,
Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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NU. 00-2581 CIVIL TERM _X ~
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PETITION FOR CONTEMPT AND MODIFICATION :' ~a .:
_q.
Petitioner, Andre K. Sanders, by and through his counsel, MidPenn Legal Services, states
the following:
1. Petitioner, hereinafter referred to as Father, resides at 32 North East Street -
Apartment 2, Carlisle, Cumberland County, Pennsylvania 17013.
2. Respondent, hereinafter referred to as Mother, resides at 600 North Baltimore Street,
Mount Holly Springs, Cumberland County, Pennsylvania 17065.
3. The above-named parties are the natural parents of Chelsie Stotler. born February 25,
1999.
4. A custody order was entered in this case on October 11, 2011 by The Honorable
Kevin A. Hess. The Order, in pertinent part, gives the parties shared legal custody.
Mother has primary physical custody and Father has periods of partial physical
custody on alternating weekends with times to be agreed upon by the parties. (See
attached Exhibit A)
5. Father is entitled to a modification of the current Order, which is in the child's best
interests, for reasons including, but not limited to, the following:
a. Mother has not enforced the terms of the current Order and has allowed the
child to determine whether nr not. she wants to go with Father for his
weekends of custody. This frequently results in the child choosing to other
activities and Father loses his periods of custody.
b. As a result of Mother's refusal to communicate with Father, the parties have
difficulty agreeing on a time for custody exchanges to take place which also
result in Father's periods of partial custody being decreased or taken away
entirely.
c. Father learned that Mother had been looking in to living arrangements in
Texas and had not discussed the possibility of relocation with Father. Father
is concerned that Mother may. make a unilateral decision to relocate with the
child without Father's agreement or a court order allowing such a move.
d. Within the past two months, Mother has left the area to travel with an over-
the-road truck driver and left the child in the supervision of an older sibling.
Father was unaware that Mother was leaving the area and has concerns that
Mother left the child in the care an older sibling who lost custody of her own
children in the state of Ohio.
e. It is Father's position that if/when Mother chooses to take these long trips, the
child should stay with Father who will be responsible for getting her to school
and seeing to her daily needs.
f. Despite the positive start ' in creating the most recent Order, the
communication between Father and Mother has disintegrated to the point that
'. Mother does not accept Father's calls and the cooperative co-parenting no
longer exists.
g. ~ Father has sought to maintain a relationship with the child, despite various
situations that have negatively impacted his own life and despite the current
issues that have ariaen between Father and Mother.
h. Father has a safe and stable home environment in which to exercise periods of
partial physical custody with Chelsie.
i. Father is committed to maintaining establishing his father/daughter
relationship with Chelsie.
j. Father is willing to work with Mother to cooperatively co-parent Chelsie.
b. Counsel for Father has contacted the Family Law Clinic which previously represented
Mother. The Family Law Clinic no longer represents Mother and it is presumed that
Mother would not concur ~,vith the relief requested in this petition.
WHEREFORE,, Father respectfully requests that this Court schedule a conciliation conference
for purposes of modifying the current custody Order.
Respec ubmitted,
;~_ ~
Jessic st, Esquire
MidPenn Legal Services
401 East Louther Street.
Carlisle, PA 17013
(717) 243-9400
VERIFICATION
The above-named PETITIONER, ANDRE K. SANDERS, verifies that
the statements made in the above Petition for Modification are
true and correct. PETITIONER understands that false statements
herein are made subject to the penalties of 18 Pa. c::.s. X4904,
relating to unsworn falsification to authorities.
Date . ~~ ~ ~~ , .
ANDRE K. SANDERS
EXHIBIT
A
ANDRE K. SANDERS, IN THE COURT OF CO1~~IMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PEN`N`SYLVANIA
v. No. 00-281 CIVIL ACTION LAW
ELIZABETH STOTLER, IN CUSTODY
Defendant
Prior Judge: Kevin A. Hess, P.J.
ORDER OF COURT
AND NOW this ~ ~~' day of October 201 1, upon consideration of the attached Custody
Conciliation Report, it is Ordered and Directed as follows:
l . The prior Orders of Court are hereby superseded and replaced with the instant Order.
2. Legal Custody: The Father, Andre Sanders, and the Mother, Elizabeth Stotler, shall have
shared legal custody of Chelsie Stotler, born 02/25/1999. 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 her 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 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.
3. Physical Custody: Mother shall have primary physical custody of the Child subject to Father's
partial physical custody as follows:
a. Father shall have custody of Chelsie on alternating weekends from Friday until
Sunday, the times to be by agreement of the parties. It has been agreed by the
parties that Father's current paramour, Wanda Campbell, not be unsupervised
while Chelsie is in Father's care.
b. Father shall have physical custody of the Child at such other times as the parties
may mutually agree.
~. The non-custodial parent shall have liberal telephone/email/text contact with the Child on a
reasonable basis.
5. Holidays: The parents shall arrange a holiday schedule as mutually agreed upon.. In the
absence of agreement, the parties shall adhere to the schedule as attached.
6. Vacation: Each parent shall have one week of vacation with the Child per year. T'he requesting
parent shall give the other parent 30 days advance notice of the requested time and this vacation
week shall supersede the regular physical custody schedule. In the event the parties schedule
conflicting vacations, the party first providing written notice shall have the choice of vacation.
Prior to departure, the parties will ,provide each other with information regarding the intended
vacation destination and a telephone number at which they can be reached during their
vacation. The parties may expand this vacation time by mutual agreement..
Neither 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 the other
parent in the presence of the Child.
8. In the event of a medical emergency, the custodial party shall notify the other party as soon as
possible after the emergency is handled.
9. During any periods of custody or visitation, the parties shall not possess or use ialegal
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.
1(). 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,
P.J.
Distribution:
The Family Law Clinic
Jessica Holst, Esquire
John J. Mangan, Esquire
TRUE COPY FROM RECORDand
In Testimony whereof, I here unto set my
end the seal of said Co~~u~~r~~t af~t Carliste2,~P/~-
This ~ daY ofProthonotary
---_-- T I=VIES EVEN ODD ~'
HOLI)AYS AND YEARS YEARS
SPECIAL DAYS ;
Easter Day 1St Half From 9 am until. 3 m Father _ ____
]Mother
Easter Day 2° Half
From 3 pm until 9 pm
Mother ___
Father
Memorial Day
From 9 am until 9 pm
Mother _____
Father
Independence Day
From 9 am until 9 pm
Father ____
Mother
Labor Day _
From 9 am until 9 pm
Mother __
Father
'
Halloween
From one hour before trick or
Father _
__
Mother
treating to one hour after trick or
treatin
Thanksgiving 1St
From 8 am Thanksgiving Day to 2
Father _ _
Mother
Half pm on Thanksgiving Day
Thanksgiving 2"
From 2 pm on Thanksgiving Day to
Mother __
Father
half noon the day after Thanksgivin Day
Christmas 1St Half
From noon on 12/24 to noon on
Father _ _
Mother'
1.2/25
Christmas 2° Half
From noon on 12/25 to noon on
Mother _
Father
_ 12/26
New Year's From 6 pm 12/31 until noon January Mother Father
1St (with the 12/ ~ 1 year to control the
_ even/odd determination)
Mother's Day
From 9 am until 9 m
Mother _
Mother
Father's Day _ _
From 9 am until 9 pm
Father __
Father
~~NDRF, K. SANDERS,
Plaintiff
v.
ELIZABETH STOTLER,
:Defendant
Prior Judge: Kevin A. Hess, P.J.
1N THE COURT OF CCN1_'V10N PLEAS OF
CUl~iBERLAND COUNTY, PENNSYLVANIA
No. 00-2581 CIVIL ACTION L,AW
IN CUSTODY
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
(:helsie Stotler 02/25/1999 Primary Mother
2. A stipulated Order of Court was issued Apri125, 2000, a petition for contempt and
modification was filed by Father and a Conciliation Conference was held with regard to
this matter on March 22, 2011, an Order issued Apri126, 2011 and a conference was
held June 10, 2011 with the following individuals in attendance:
The Mother, Elizabeth Stotler, with her counsel, The Family Law Clinic
The Father, Andre Sanders, with his counsel, Jessica Holst, Esq.
3. The parties agreed to the entry of an Order in the form as attached.
--.~...~3 ~__
Date -7-- John J. Mangan, squire ,~
Custod /Conciliator ,/'~
t~
.ANDRE K. SANDERS, 1N THE COURT OF COMMON PLEAS
Petitioner
CUMBERLAND COUNTY, PI~NNSYLVANIA
vs. NO. 00-2581 CIVIL TERM c ~ ~`~
--~ ~ N
ELI7_ABE"I'H STOTLER, • ~ cc1
~ m p
~ ~- z;
mar=
Respondent :CUSTODY ~~~~`- N x~t;
~,
J '~
.~ .• ei
• ' 1
W Y ~
~• fy.
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Andre K. Sanders, Petitioner, to proceed in forma pau~eris.
I, Jessica Holst, attorney for the party proceeding in forma au eris, certify that I believe
the pariy is unable to pay the costs and that I am providing free legal services to the party.
„~
~-
i F
,~ ----
Jessica 1st, Esquire
MidPen Legal Services
401 East Louther Street
Carlisle, PA 17013
(717) 243-9400
ANDRE K. SANDERS IN THE COURT 01= COMMON PLEAS (_)F
PLAINTIFF CUMBERLAND COUNTY', PENNSYLVANIA ~~ =~; '=
`
,
`
• 2000-2581 CIV11. ACTION 1_AW
tV.!) r..
~ '' ~r
~' t
~1
_.~ wP i
'+'ti
1 ~~
~
ELIZABf~:TH STOTLER .
~, `R'' .. _
"'°~-~'
IN CUSTODY ~~'
'= cj ~ '_~~;_
-_~
"r" C.7 . '~
ORDER OF COURT
AND NOW, - Friday, October 26, 2012 _, upon consideration of the attached Compl aint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator,
at_ _ _ 4th Floor, Cumberland_Coun ~ Courthouse, Carlisle on Friday, November 30, 2012
___~-~_-- ~-. -_-_ _ _ _ at 10_00 AM
for aPre-Hearing Custod}~ Conference. At such conference, an effort will he made to resolve the L~sues in dispute; or
if this cannot be accomplished, to define and narro«° 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/ __ , johns 11~Iangan, jr., Esg. /
~- __ _
Custody Conciliator i
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 olu- office. A,11 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
I-(AVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BE LO~~' TO E IND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
>? South Bedford Street
Carlisle, Pennsylvania 17013
v ~I~I~/ ~~ ~~ ~~ Telephone (717) 249-3166
~~~~
o J tin ~ /~d~~c ~/I, ~-~,~' ~~bire~ 1~~,.-
~~ ~ es ~~~ % o~
'~
ANDRE k:. SANDERS, IN THE COURT OF COMMON PLEAS
Petitioner
: CUMBERLAND COUNTY, PENNSYLVANI A
vs. .
NO. 00-2581 CIVIL TERM "~ ,--.,
`~'
: ~-~ Q' _~ ~- _~-
ELIZAB>=;TH STOTL,ER, .~Mt~-=
` -^~ -~ ----
Respondent =~
:CUSTODY .
r c:~ ;;~,~--~
_
6.__ ~, ._...a ~~
^~ ~ !~'?'~Yi
t.. ~~
CERTIFICATE OF SERVICE
I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for Petitioner, Andre K. Sanders,
hereby certify that I have served a copy of the forgoing Petition for Contempt and Modification
by: LISPS First Class Mail, Certified Mail, Electronic Receipt Requested:
Elizabeth Stotler
61)0 North Baltimore Street
Mount Holly Springs, PA 17065
,~ -,
Date: ~d li,~/iZ- --
Jessica H sit, squire
MidPenn Legal Services
401 East Louther Street
Carlisle, PA 17013
(7'.7)243-9400
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