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HomeMy WebLinkAbout02-4397 NM C C= LAMONT L. MAHONEY,JR. IN THE COURT OF COMMON PLEAS `na w —+ Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA C= N3 Z� V. NO. 2002—4397 CIVIL TERM tom- . I� DEANA MURLATT, �• Defendant CUSTODY PETITION FOR SPECIAL RELIEF REGARDING VACATION AND CRUISE ` 1. Plaintiff Lamont L. Mahoney,Jr., (hereinafter"Father") resides at 209%2 Reno Street, New Cumberland,Cumberland County, Pennsylvania 17070. 2. Defendant Deana Murlatt(hereinafter"Mother") resides at'325 Third Street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. The parties are the natural parents of Lamont L. Mahoney, III (DOB 9/17/2001;Age 11). 4. The parties are subject to an Order of Court dated June 20, 2003 which is attached hereto as Exhibit"A". 5. Mother desires to take Lamont on a vacation from Thursday,August 15, 2013 to Sunday,August 25, 2013. The precise itinerary is attached as Exhibit "B" (Airline Travel to Florida)and Exhibit "C" (Cruise Information showing departure.from Port Canaveral, Florida with stops in Cozumel, Mexico, Belize,and Honduras). 6. The child will be in the company of his Mother, his older brother(Kelvin—Age 18), and Father's own step mother(Terry Lee Mahoney). 7. Father, however, has refused to execute the notarize permission form required by the cruise line to permit Lamont to enjoy the vacation. A true and correct copy of the permission form required by the cruise line is attached hereto as Exhibit"D". 8. The proposed vacation will only eliminate one (1)three (3) hour Tuesday night visit (August 20th) and one (1) weekend with Father. 99-3 7 f 3 9. Mother is incomplete agreement with swapping the missed Tuesday overnight and Father may enjoy another weekend in August (August 3-4 or August 31-September 1 plus Monday, September 2nd) at his discretion. If August does not suit then a weekend in September 2013 would be fine as well. 10. Mother notified Father on March 26, 2013 that she was planning another vacation for"Bigger" [the parties use the affectionate name of"Big" for their son] but the dates were not yet fixed. 11. In 2012 Father was fine with Mother and "Big"traveling on a cruise from June 7—June 16 to Bermuda,St. Maarten, Puerto Rico and Haiti and he executed the notarized permission form. 12. In 2013 Father's response when provided the itinerary was: Section 4 of our custody order reads: "Each party shall be entitled to one week of exclusive custody of the child in the summer commencing the summer of 2004.The parties shall notify each other of the dates he or she intends to exercise such custody prior to May 1 of each year." If I agree and sign I am breaking the custody order. I don't think it's in my interest to break the custody order. See Exhibit"E". 13. Father has provided no other explanation other than not wanting to "break the custody order" in refusing to execute the permission slip. 14. Father's refusal is unreasonable since it only hurts the child for no apparent purpose. 15. This is the last family vacation prior to Kelvin (Big's older brother)joining the U.S.Air Force at the end of his senior year in high school (2013-2014). 16. The vacation will also permit"Big"to visit Father's own Step Uncle Eddie in Florida. 17. Father was represented many years ago in 2003 by Jeanne B.Costopoulos, Esquire but Father is believed to be unrepresented at this time.Attorney Howell called Attorney Costopoulos at 11:05 AM EST on July 25, 2013 to inquire as to whether she continued to represent Father and he provided a brief explanation of the nature of the.Attorney Costopoloulos responded on Friday morning and does not represent Father at this time. 18. It should be assumed that Father does not concur with the requested relief. WHEREFORE, Mother respectfully requests this Honorable Court to direct Father to execute before a Notary Public the:permission form attached hereto as Exhibit"D" no later than August 8, 2013 and grant him make up time for the missed Tuesday evening visit and one (1)weekend at his discretion in August 2013 or September 2013. Respectfully submitted, By: Steve owell, Esquire H ell Law Firm 619 Bridge Street New Cumberland, PA 17070 (717)770-1277 Voice Supreme Court ID 62063 Attorney for the Defendant Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the above document was served by postage prepaid,first class United States Mail addressed as follows: Lamont L. Mahoney,Jr. 209% Reno Avenue New Cumberland, PA 17070 By: S ven H well, E quire Date: July 29, 2013 Verification I verify that the statements made in the foregoing document are true and correct. I understand that false statemens herein are made subject to the penalties of 18 Pa.C.S.A.Section 4904 relating to unsw Isification to authorities. By: Deana r att Date: July 25,2013 LAMONT L. MAHONEY, JR. , IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY; PENNSYLVANIA V. NO. 2002-4397 CIVIL TERM CIVIL ACTION - LAW DEANA MURLATT, , Defendant CUSTODY B ORDER OF COURT AND NOW, this 20th day of June, 2003 , we enter the .following Order which shall replace any prior Order entered in this matter: 1 . The parties shall have shared legal custody of their child, Lamont L. Mahoney, III, born September 17, 2001 . Each parent shall have equal right, to be exercised jointly with the other .parent, to make all major non-emergency decisions affecting the child' s generate well being, including, but not limited to, all decisions regarding his health, education, religion, and welfare. .Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the child, including, but not limited to, school and medical records and information. .2 . The Mother shall have primary physical custody of the child. 3 . Father shall have periods of partial physical custody with his child as follows: A. On Saturday, June 21, 2003 , from 10 : 00 a.m. until` 8 : 00' p.m. B. On Sunday,_ June 291 . 2003, from 10: 00 a.m. until 8 : 00 p CC 1 A C. On Thursday,, July 3 , 2003 , from after work W until Friday, July -4, 2003, at noon. �`�°"eiapwn18 D. Every other weekend from Friday at 6 : 00 p.m. ' until Sunday at 6 : 00 p.m. commencing Friday, July 11, 2003 . E. Every Tuesday, from after work at 5 : 00 p.m. until 8 : 00 p.m. 4 . Each party shall be entitled to one week of exclusive custody of the child in the summer commencing the summer of 2004 . The parties shall notibfy each other of the dates he or she intends to exercise such custody prior to May 1 . of each year.. 5 . Father shall have partial physical custody of the child on the following holidays: A. Every Thanksgiving from 3 : 00 p.m. until 8 : 00 P.M. B. From noon Christmas day until 8 : 00 p.m. Christmas night in odd numbered years. C. From after work on Christmas eve, or if he is not working from 3 : 00 p.m. Christmas eve until noon Christmas day. D. The following holidays on an alternating basis from 9 : 00 a.m. until 8 : 00 p.m. : Labor Day, New Years Day, Easter, Memorial Day, July 4 . It is 'our intention that Mother shall have the child. on those holidays upon which Father does not have him. The above holiday schedule shall supersede any regularly scheduled visitation. 6 . If Mother' s Day falls on Father' s scheduled weekend, he shall return the child by 9 : 00 a.m. If Father' s Day falls on a weekend that Father does not have the child, he shall be entitled to visit with the child from 9 : 00 a.m. until 8 : 00 p.m. 7 . The parties shall share the child' s birthday as follows : A. In odd numbered years, Mother shall have the child from 4 : 00 p.m. until 6 : 00 p.m. , and Father shall have the child from 6 : 00 p.m. until 8 : 00 p.m. In even numbered years, Father shall have the child from 5 :30 p.m. until 7 :30 p.m. This section shall6supersede any other regularly. scheduled .visitation. 8 . Father shall pick the child up at the commencement of his periods of partial custody at daycare or Mother' s residence, as the case may be. He shall return the child to Mother' s residence at the conclusion of visitation. 9 . The parties shall keep each other informed of current addresses and phone numbers, both at work and at home. They shall also notify the party of any illness or accident or other serious circumstance affecting the welfare of the child while in said party' s care and custody. 10 . Both parties shall have the right to reasonable telephone contact with the child during the other party' s period of custody. 11 . Neither Father nor Mother shall make disparaging remarks regarding the other parent in the presence of the child. 12 . For the next 60 days, on the days that Father does not have visitation with the child, Mother shall e-mail him something positive about the child. Father must then respond to said e-mail . On the days when Father has the child, he shall e-mail something positive to Mother regarding the child. Mother must respond. Copies of the a-mails sent and received shall be filed to this term and number to be made part of the record so that we can refer to them if the matter comes before us in the future. By the Co , Edwar6 E. Guido, J. Jeanne B. Costopoulos, Esquire At rney for Plaintiff even Howell, Esquire ttorney for Defendant srs TRUE COPY FROM RECORD In Testimony whereof, I here unto set my ha�o and the seal of said C t at Carlisjo pa, Thi day aae.3 Prothonotary -7/23113 Fwd:AllegiantAir.com-Iti nerary#G685076-deanamurlatt@gmail.com-GmaiI t allegialnt'$ ravel is our deal, -:= Here is your Allegiant Airlines travel itinerary.The confirmation number for this reservation is sow 1 Customer Information Customer Name: TERRYMAHONEY Customer ID: Book Date: 6/27/2013 2 Flight Leg Date Right Depart Time Arrive Time 1A Thu,Aug 15 611 HARRISBURG,PA (MDT) 06:05 pm ORLANDO/SANFORD,FL(SFB) 98-20 pm 2A Sun,Aug 25 610 ORLANDO/SANFORD,FI_(SFB) 03:10 pm HARRISBURG,PA(MDT) 05 25 pm #Passengers Seat Flight 611 Seat Right 610 Checked Bags Carry-on Bags 1 MAHONEY,TH;RY 18C 33A 1 0 2 MURLATT, DEANA 19C 33C 1 0 3 MURLATT, KELVIN 18A 34A 1 0 4 MAHONEY,LAMONT 19A 34C 0 0 *Passengers who have not purchased a seat assignment-- "Not assigned"--will be assigned a seat b y our system at no cost upon check-in.if you would like to select your seats,simply log in to MvAllegiant before you check-in online or get to the airport. 3 Payment Here's your itinerary and receipt. Thank you for booking your travel w ith us!Above,you'll find all the information you need to know about your travel itinerary. Although you can alw,ays access your trip details by signing in to MvAllegiant,w e recommend printing a copy for your reference now. Remember,to save time and money,you can log in to MvAllegiant to make seat or bag reservations,change or cancel your itinerary, or to add hotel rooms,car rental or activity and show tickets to your travel package at savings you won't find anywhere else. Have a great tripl AIRFARE $ Click Continue to-claim your$25 Rebate FED EXCISE TAX: on today's resed'vatlon. SEGMENT FEES: --- PFC CQCltiolue SEPT 11 SECURITY FEE Er T PREPAID BAGS: $ Wiling terms and conditions apply.C9aim your SEAT SELECTION FEE $ Cash Back with enrollment in Travelers Advantage. CARRIER USAGE CHARGE TOTAL: PAYMENT: (VI 5933)$ TOTAL PAID: BALANCE DUE $0.00 EXHIBIT Things to know before you go. € V Check4n: https:/Imail.goog le.conVmail/u/0/?tab=wn#search/terrv+mahoneVl3FJcf9e92392568 1/4 `7/23113 Fwd:AllegiantAir.com-Itinerary#G685076-deanarrurlatt@gmail.com-Gmail You can check in online 24 hours before,and until 60 minutes prior to scheduled flight departure at www.alle-giantair.com. Allegiant recommends arriving at the airport at least tw o(2)hours prior to scheduled departure.Customers must check in no less than 60 minutes prior to scheduled flight departure. Please note:under the agreed Terms and Conditions of purchase,passengers who fail to check in for a scheduled flight will be designated a'No Shoe✓and all fares for that segment will be forfeited. Bags: Save money by reserving your carry-on and checked baggage before you check in. It's easy-just log in to M'Allegiant to add bag reservations to your itinerary. Baggage fees are higher at the airport.Please measure and weigh your bags carefully.Any checked bag weighing more than forty (40)pounds will be charged additional overweight fees. See the Baggage Fees section belowfor additional information. Seat Assignments: Passengers w ho have not purchased a seat assignment--"Not assigned"--w ill be assigned a seat by our system at no cost upon check-in.You can view your assigned seats during online check-in starting 24 hours before flight departure.Seats together cannot be guaranteed and seat assignments cannot be changed at airport check-in. V you would like to purchase reserved seats,simply log in to MvAllegiant to select seats before you check-in online or get to the airport. At the airport: Proof of age is required for all passengers, including passengers under the age of 18 w ho are traveling alone. Passengers w ho are unable to provide proof of age will not be permitted to board the aircraft. Passengers should be at the boarding gate at least one hour prior to flight departure.Flights w ill be closed out 10 minutes prior to scheduled departure. In accordance w ith federal regulations,any passenger w ho appears to be intoxicated may be denied boarding. Allegiant does not accept cash,checks or money orders at any airport location. IMPORTANT NOTICES Baggage Liability Limitations:For domestic(U.S.)flights,Allegiant Air's liability for provable direct or consequential damages resulting from the disappearance of,damage to,or delay in delivery of a passenger's personal property,including baggage,in Allegiant Air's custody is limited to$3,400 per passenger.(This limitation does not apply to wheelchairs or other mobility aids or assistive devices belonging to passengers w ith disabilities.)Please refer to Articles 75 and 76 of Allegiant's Contract of Carriage for additional information. E-Ticket Expiration:All travel involving funds from this itinerary number must be completed no later than one year from the date the original itinerary was booked.Any change to an itinerary,if permitted under Allegiant Air's Terms and Conditions,will involve a change fee.For additional information see Allegiant Air's Terms and Conditions. Overbooking of Flights:Allegiant Air does not intentionally overbook its flights.Nevertheless airline flights may be overbooked, and there is a slight chance that a seat w ill not be available on a flight for w hich a person has a confirmed reservation.If the flight is overbooked,no one w ill be denied a seat until airline personnel first ask for volunteers w illing to give up their reservation in exchange for compensation of the airline's choosing.If there are not enough volunteers,the airline will deny boarding to other persons in accordance w ith its particular boarding priority,With few exceptions,including failure to comply w ith the carrier's check- in deadline of 60 minutes prior to each flight segment,persons denied boarding involuntarily are entitled to compensation.The complete rules for the payment of compensation and each airline's boarding priorities are available at all airport ticket counters and boarding locations.Some airlines do not apply these consumer protections to travel from some foreign countries,although other consumer protections may be available.Check w ith your airline or your travel agent. Incorporated Terms:Air transportation provided by Alleglant Air is subject to the terms of Allegiant's Contract of Carriage,and all such terms are herein incorporated by reference. Incorporated terms may include but are not restricted to(1)limits on liability for personal injury or death;(2)limits on liability for loss,damage or delay of baggage, including fragile or perishable goods; (3)claims restrictions,including time periods w ithin w hich passengers must file a claim or bring an action against the air carrier;(4)rights of the air carrier to change terror of the contract;(5)rules about non-ref undability of air transportation,hotel,auto,activities or httos://maii.0000le.corrVmail/u/0f?tab--vxr earctVterrvi-rnahoneV I3Mcf9e92392568 214 7/23/13 Fved:AllegiantAir.com-Itinerary#G6B5076-deanamurlatt@gmail.com-Gmail services,baggage and seat fees,and related booking fees,carrier charges and taxes;reconfirmation of reservations,check-in times,and refusal to carry;(6)rights of the air carrier and limitations concerning delay or failure to perform service,including schedule changes,subs titution of alternate air carrier or aircraft,and rerouting.You can obtain additional information on items 1 through 6 above at any U.S.location w here Allegiant's tickets are sold.You have the right to inspect the full text of Allegiant's Contract of Carriage at its airport ticket counters or by clicking here.You also have the right,upon request,to receive free of charge by mail or other delivery service the full text of Allegiant's Contract of Carriage including the terms referenced above.Information on ordering the full text of the Contract of Carriage is available at any U.S.location w here Allegiant's tickets are sold. Please send comments to: Allegiant Travel Company ATM:Customer Relations Department 8360 S.Durango Dr. Las Vegas,W 89113 Or,customers may fill out our Feedback Form by clicking here. Baggage Fees: Save money by reserving your checked and carry-on bags before you get to the airport. Rease see the table below for applicable fees. You may travel w ith one Personal Rem that can fit under the seat in front of you free of charge. Please measure your bags carefully.All exterior measurements include wheels,pockets,handles and decorations. Airport bag fees will apply to: • Carry-on and checked bags w hich have not been reserved in advance. • Oversize Personal item(exceeding 7"H x 15"W x 16"D) • Excess or oversize Carry-on Bag(exceeding 9"H x 14"W x 22"D) • Unpaid carry-on baggage brought to the gate. Overweight and oversized checked bag fees apply to: • Overweight Checked Bags-between 41 and 70 pounds (18.6-31.8 kilos):$50.00 additional per segment. • Overweight Checked Bags-between 71 and 100 pounds(32.245.4 kilos):$75.00 additional per segment. • Oversize Checked Bags:height+width+depth in excess of 80 linear inches (203.2 cm):$75.00 additional per segment. Please note:passengers may bring car seats/strollers,mobility aids or assistive devices,medical equipment such as portable oxygen concentrators or diabetic supplies,food for consumption in flight,a coat,jacket,diaper bag,or an umbrella on board the aircraft w ithout charge. In accordance Wth FAW/TSA Security Directives,passengers are restricted to one(1)item of carry-on baggage that does not exceed external dimensions of nine inches by fourteen inches by twenty-two inches(9"H x 14"W x 22 7D) (e.g.,roll-aboard bag, garment bag, tote bag)and does not exceed 25 lbs. This item must be stored in the overhead compartment and is subject to applicable fees. In addition,passengers may bring on-board one(1)smaller personal-type item not to exceed external dimensions of seven inches high by fifteen inches wide by sixteen inches deep(7"H x 15"W x 16"D) (e.g.,purse,briefcase, laptop computer,small backpack,small camera),provided that such item is capable of being carried onboard the aircraft by one person without assistance and is capable of being stowed under a seat. Carrier reserves the right to further restrict the size and number of carry-on items whenever necessary. Qualified individuals with a disability will be provided assistance upon request to Carrier's Representatives in loading,stowing, and retrieving carry-on items,including authorized assistive devices. Baggage Fee Table.Fees for checked bags and carry-on bag are by route and apply per bag,per segment.Baggage pricing show n below applies for all new reservations made from the stated effective date onw ard. Route Price per bag, per segment 1st 2nd 3rd 4th Carry-on Harrisburg,PA(MDT)-Orlando/Sanford, FL(SFB) Prepaid $20.00 $20.00 $50.00 $50.00 $13.00 Effective April 4, 2012 for travel starting before April 30, 2013 Airport $50.00 $50.00 $100.00$100.00 $35.00 Effective November 15, 2012 for travel starting May 1, 2013 Airport $50.00 $50.00 $100.00$100.00 $50.00 Orlando/Sanford, FL(SFB)-Harrisburg, PA(MDT) Prepaid $20.00 $20.00 $50.00 $50.00 $13.00 Effective April 4, 2012 for travel starting before April 30, 2013 Airport $50.00 $50.00 $100.00$100.00 $35.00 Effective November 15, 2012 for travel starting May 1, 2013 Airport $50.00 $50.00 $100.00 $100.00 $50.00 httns://rnaii.cimale.corrVmail/u/0/?tab--wT isearchtterry+.mahrnev/13fgcfgeg2392568 3/4 7/ 13 Vacations To Go Confirmation Vacations To Go Home Page Dear Mrs. Mahoney, Please review each section of your confirmation below to ensure that all of the information shown is correct. Each passenger's name should be their legal first and last name as it appears on a certified or original (state-issued) copy of their birth certificate or passport. If you find a discrepancy, please contact me immediately. Prior to departure you must provide additional information to the cruise line for all passengers. See the information in the Cruise Tickets Section below, for specific instruction. Have a fantastic cruise and thanks for booking with Vacations To Gol Sincerely, Judy Hastings Alan Fox Travel Counselor Chairman & CEO Confirmation Vacations To Go Agent: Judy Hastings 5851 San Felipe Street, Suite 500 Phone: 800-338-4962 ext. 7152 Houston, TX 77057 Email: jhastinasCa.vacationstog_o.com www.vacationstocio.com Hours: Mon-Fri: 9:30am-3:30pm (CST) Customer Travel Details Mrs. Terry Lee Mahoney Line: Carnival 4425 Fargreen Rd Ship: Camiyal Dream Harrisburg, PA 17110 Destination: Caribbean Departs: August 17, 2013 Daytime: (717) 233-5200 Nights: 7 Email: teny4425cDcom cast.net Cabins and Passengers Cabin # Category Names DOB Citizenship Booking # 6406 Cat 8B Mrs. Terry Lee Mahoney 904AM United States 68TLR9 6406 Cat 8B Mr. Kelvin D Murlatt United States 68TLR9 6406 Cat 8B Mr. Lamont L Mahoney United States 68TLR9 6406 Cat 8B Ms. Deana L Murlatt United States 68TLR9 Description of assigned cabin(s): 6406-Balcony Charges Payments Cruise (includes port charges) Paid To Type Amount CSA Insurance Govemment Taxes* Camival wlll . CSA Insurance "(..4") Total Sale (US$) so Total Payments (US$) 1"ft Balance Due (US$) 0.00_ https://secure.m3cgonstogo.comhAg/emNew.cfm7 uid=866ACA4C13724831058484971578AE17 1/6 7/23113 Vacations To Go Confirmation *subject to change by the cruise line. Cruise Tickets Camival requires passengers to use an electronic cruise document so no paper tickets will be delivered to you for this cruise. To board the ship, simply present proper ID and your electronic cruise document, called a Boarding Pass, at the pier. Carnival provides passengers with the option to complete their registration process, called FunPass, online, within 21 days of departure. Upon completing your FunPass, you may print your documents, including the Boarding Pass, baggage tags and a general summary of your cruise booking. To register online, print your Boarding Pass and purchase shore excursions, go to Carnival's secure site by clicking here. Then, click on Booking Quick Access, enter your booking number, last name, date of birth, ship and sail date and click Submit. To register, select the arrow next to View Details, then select Online Check-in and complete the required fields. To print your boarding pass and baggage tags, go back to My Cruise Manager, select View Cruise Documents. Use the check-boxes to designate the documents you want to print and click Submit. To resettle shore excursions and spa treatments, go back to My Cruise Manager, select Plan Activities and complete the required fields. You can return to My Cruise Manager using the My Cruise Home link in the upper right-hand comer. You must log in and print boarding passes and baggage tags for each unique booking number. In order to view your boarding pass, your cruise must be paid in full and you must have completed the FunPass online registration. If you have any questions, please call me at 800-338-4962 ext. 7152, or visit Carnival's FAQs page by clicking here. Air Schedules No air purchased from Vacations To Go Mrs. Terry Lee Mahoney Mr. Kelvin D Mudatt Mr. Lamont L Mahoney Ms. Deana L Mudatt Carnival -Carnival Dream, departs 8/17/13, 7 nights Day Date Port or Activity Arrive Depart Sat Aug 17 Port Canaveral, FL 4:00pm Sun Aug 18 At Sea Mon Aug 19 Cozumel. Mexico 10:00am 6:00pm Tue Aug 20 Belize Cityy, Belize 8:00am 6:00pm Wed Aug 21 Roatan, Honduras 10:00am 7:00pm Thu Aug 22 Costa Maya,Mexico 7:00am 2:00pm Fri Aug 23 At Sea Sat Aug 24 Port Canaveral, FL 8:00am Travel Documentation Requirements EXHIBIT C https://secure.vacabonstw o.corMq/confNew cfm?uid--866ACA4C 13724B31058484971578AE17 � 216 7/231'13 Vacations To Go Confirmation Requirements for(U.S. Citizens): Mrs. Terry Lee Mahoney, Mr. Kelvin D Murlatt, Mr. Lamont L Mahoney, Ms. Deana L Murlatt For closed-loop cruise itineraries that begin and end in the same U.S. port and include ports in the Bahamas, Bermuda, Canada, the Caribbean, Mexico and/or select ports in Central America*, but that visit no other foreign ports: For U.S. citizens passports are not required for this sailing but passengers must provide proof of U.S. citizenship. To board without a passport, adult passengers need a valid government-issued photo identification AND a U.S. state-issued original or certified copy of their birth certificate (hospital certificates are not acceptable)or a Consular Report of Birth Abroad, or a Certificate of Naturalization. If a woman has different last names on her photo identification and birth certificate she must also bring an original or certified copy of a marriage license and/or divorce papers to bridge the difference between the two names. Children under the age of 16 may board with a U.S. state-issued original or certified copy of their birth certificate(hospital certificates are not acceptable)or a Consular Report of Birth Abroad, or a Certificate of Naturalization as proof of citizenship. Photocopies of required documentation are not acceptable. *If your closed-loop cruise visits Belize, Honduras or Panama passports are not required. If your closed- loop cruise visits any other country in Central or South America passports are required for all travelers, including travelers under 16 years of age. For cruise itineraries that ONLY include ports in the lower 48 United States and/or Hawaii: A valid government issued photo identification or a state certified birth certificate is required for all passengers. Photocopies of required documentation are not acceptable. For all other cruise itineraries. Valid passports are required for all passengers, regardless of age. Passports must be valid for six (6) months after the day you re-enter the U.S. Photocopies of required documentation are not acceptable. U.S. documentation requirements Legal permanent residents (non-citizens) of the U.S. need a valid passport and a valid Alien Resident Card to re-enter the U.S. For all other travelers, if your country participates in the Visa Waiver Program with the U. S., the following rules apply by country: Citizens of Andorra, Australia, Austria, Belgium, Brunei, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Hungary, Iceland, Ireland, Italy, Japan, the Republic of Korea, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Monaco, the Netherlands, New Zealand, Norway, Portugal, San Marino, Singapore, Slovakia, Slovenia, Spain, Sweden, Switzerland and the United Kingdom are required to have valid, machine-readable passports and to obtain a travel authorization via the Electronic System for Travel Authorization (ESTA) prior to boarding a carrier to travel by air or sea to the U.S. under the visa waiver program. ESTA is accessible online at https: /esta.cbp.dhs.govfor citizens and eligible nationals of visa waiver program countries. If your country does not participate in the Visa Waiver Program with the U.S., you must provide a valid passport and a valid U.S. visa to enter the U.S. for cruises departing the U.S., and a valid passport and a valid multiple-entry visa to re-enter the U.S. for roundtrip cruises departing the U.S. I Visas and Documert(ation requirements for all other countries besides the U.S. All non-U.S. citizens must verify proof of citizenship and visa requirements with the embassy, consulate or immigration office of the countries in their cruise itinerary. Minors Anyone under the age of 18 wishing to go ashore unaccompanied will be required to have a consenting parent, guardian or other responsible adult with them at the gangway to.provide their signature as authorization. Photocopies of required documentation are not acceptable. https://secure.v acationst000.carMo/oonNew.dm?uid=866ACA4C13724B31o58484971578AE17 3/6 7/23113 Vacations To Go Confirmation Minors traveling to any foreign country must be accompanied by both parents, or have a notarized permission form signed by the parent(s) not accompanying them. Click here for a parental consent form. If the other parent is deceased or the child has only one legal parent, a notarized statement must be presented as proof. Special Air Travel Notice: Passports are required for all air travel that begins or ends outside of the U.S., even if passports are not required for the cruise portion of your vacation. Important Note: Vacations To Go assumes no responsibility for passengers that are denied boarding for failure to present proper documentation. Additional Travel Details Departure Guidelines The cruise line requires passengers to be onboard the ship at least one hour prior to departure. Vacations To Go strongly recommends that you arrive at the pier at least two (2) hours before the scheduled departure of your cruise so you will have ample time to check-in and board. Dining Open Dining. Bed Configuration Cabin 6406: Two twin beds non-converting Insurance Mrs. Terry Lee Mahoney: CSA Insurance, confirmation number. 1#j11j0tAft (Comfort plan) Mr. Kelvin D Murlatt: CSA Insurance, confirmation number (Comfort plan) Mr. Lamont L Mahoney: CSA Insurance, confirmation number: (Comfort plan) Ms. Deana L Murlatt: CSA Insurance, confirmation number: (Comfort plan) Past Passenger Numbers Mrs. Terry Lee Mahoney: 71833893 Age Requirements Camival Cruise Line requires all passengers in each cabin to be 21 or older. If anyone in the cabin is younger than 21, at least one person must be 25 or older. Ages of guests will be verified at embarkation. Any guests determined to be in violation of this policy will be denied boarding and no refund will be issued. Cancellation Charges If you cancel, the following charges will be assessed by the cruise line (per guest): Days Prior To Cruise Length Sailing Cancellation Charge 2, 3, 4 & 5 nights 61 days or more None (except for Early Saver*, Easy Saver* and Super Saver fares**) 60 to 46 days Entire deposit 45 to 30 days 50% of total fare or deposit, whichever is greater 29 to 15 days 75% of total fare or deposit, whichever is greater 14 days or less 100% of total fare 6 nights and longer(including 76 days or more None (except for Early Saver*, Easy Saver` Alaska & Hawaii) and Super Saver fares**) 75 to 56 days Entire deposit 55 to 30 days 50% of total fare or deposit, whichever is greater 29 to 15 days 75% of total fare or deposit, whichever is greater 14 days or less 100% of total fare httns://secure.vecationstoao.comMa/conk+ewcfm?uid=866ACA4C13724B31058484971578AE17 4/6 • PARENT/GUARDIAN CONSENT FORM FOR MINORS Name of child: Child's birth date: Ship/Tour/Property: Departure date: Number of days to travel: Return date: Name of parent or guardian: Phone number: Please list the countries the minor will visit during his or her travel: I/We hereby give my permission for the above named minor to travel. I/we understand and accept the conditions for our minor to travel. I/We hereby designate (chaperone)who is traveling with our child and whose relationship to the child is , to be responsible for our child during their travel. Furthermore, should my child require routine or emergency medical attention during their travel, I specifically authorize the above named person to make any and all necessary parental decisions concerning any and all medical treatment that my child may require. Signature of Parent or Guardian: Date: Signature of Chaperone: Date: Name of Notary: Signature of Notary: Date: Please stamp notary seal above EXHIBIT E m 7/23/13 Gmail-Cruise Cruise Deana Murlatt<deanamudatt @gmail.com> Thu, Jul 18, 2013 at 4:48 PM To: Lamont Mahoney <lamont.mahoney @ gmail.com> Hello, We just paid for our vacation, a cruise, for mid August. Like last year, Lamont will need a notorized form of your consent. When can this be complete? Thank you, Deana Lamont Mahoney <lamont.mahoney @gmail.com> Fri, Jul 19, 2013 at 9:55 AM To: Deana Murlatt <deanamudatt @gmail.com> Section 4 of our custody order reads: "Each party shall be entitled to one week of exclusive custody of the child in the summer commencing the summer of 2004. The parties shall notify each other of the dates he or she intends to exercise such custody prior to May 1 of each year." If I agree and sign I am breaking the custody order. I don't think it's.in my best interest to break the custody order. [Quoted text hidden] EXHIBIT a Z m httpsl/mail.goog le.com/mail/uV?ui=2&iIF ifeO3ebfgd&Vev.c--pt&search=inbox&th=13fP38846b46a1b5 1/1 LAMONT L. MAHONEY,JR. IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2002—4397 CIVIL TERM DEANA MURLATT, Defendant CUSTODY ORDER OF COURT A / L/ 2013 a Rule is issued upon the AND NOW,thisI0"day of Y.!pfd 6 ! p Plaintiff to show cause at a hearing ata'0e PM.on 2013 in Courtroom Number of the Cumberland County Courthouse,One Courthouse Square,Carlisle, PA 17013 why the relief requested in Mother's Petition regarding the Florida vacation/cruise from August 15,2013—August 25,2013 should not be granted. By tta e--C- U Edward E. Guido,Judge Certified Copies To: Steven Howell, Esquire Howell Law Firm 619 Bridge Street New Cumberland, PA 17070 tt ,/Lamont L. Mahoney,Jr. V 3 209%z Reno Avenue New Cumberland, PA 17070 f C= ~:f Z; , O Cz ..t r -CCD t° 3 C) >C- " Q E` LAMONT L. MAHONEY, JR. , IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2002-4397 CIVIL TERM DEANA MURLATT, Defendant CUSTODY ORDER OF COURT AND NOW, this 9th day of August, 2013 , the Plaintiff is directed to sign the permission slip in front of a Notary within the next 90 minutes and deliver it to the Defendant . By the Court, Edward E. Guido, J. - Lamont L. Mahoney, Jr. 209 1/2 Reno Avenue New Cumberland, PA 17070 Plaintiff, Pro se /Plaintiff, Howell , Esquire 619 Bridge Street New Cumberland, PA 17070 Attorney for Defendant srs C") M ;;W-7-1 CJ)r- > LAMONT L. MAHONEY, JR., : IN THE COURT Petitioner /Plaintiff : CUMBERLAND v. : No. 2002 -4397 DEANA MURLATT, : CIVIL ACTION Respondent/Defendant : IN CUSTODY OF COMMON PLEAC COUNTY, PENNS jANI\ r't �. l' G� c:) - LAW PETITION FOR CONTEMPT AND MODIFICATION OF CUSTODY AND NOW, comes Lamont L. Mahoney, Jr., by and through his attorney, Kristopher T. Smull, of Colgan & Associates, LLC, and files the instant Petition for Contempt and Modification of Custody, and in support thereof, avers as follows: 1. The Petitioner is Lamont L. Mahoney, Jr. (hereinafter "Father "), an adult individual and the natural father of the minor child. 2. The Respondent is Deana Murlatt (hereinafter "Mother "), an adult individual and the natural mother of the minor child. 3. The minor child is Lamont L. Mahoney, III, born on September 17, 2001 (age 12). 4. By Order dated June 20, 2003, the parties share legal custody of the child while Mother has primary physical custody of the child subject to Father's periods of partial custody on alternating weekends and from Friday at 6:00 p.m. until Sunday at 6:00 p.m. and every Tuesday from 5:00 p.m. until 8:00 p.m. A true and correct copy of said Order is attached hereto, made a part hereof and marked Exhibit "A." 5. Mother has violated said June 20, 2003 Order of Court in the following ways: a. Mother has refused to allow Father his periods of partial physical custody for the past sixty (60) days. Lig? oo po/ e?g gm7. 3o.e 50.3 b. To date Father has missed the following scheduled periods of custody: - January 10, 2014 through January 12, 2014 - January 14, 2014 - January 21, 2014 - January 24, 2014 through January 26, 2014 - January 28, 2014 - February 4, 2014 - February 7, 2014 through February 9, 2014 - February 11, 2014 - February 18, 2014 - February 21, 2014 through February 23, 2014 - February 25, 2014 - February 28, 2014 through March 1, 2014 - March 4, 2014 c. At the beginning of the period of missed custody with the child Mother did allow Father telephone contact with the child; however, Mother is currently not allowing Father any telephone or other contact with the child. 6. The relationship Mother to the child is that of natural mother. 7. The relationship of Father to the child is that of natural father. 8. Father has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 9. Father does not know of a person not a party to the proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 10. The best interest and permanent welfare of the child will be served by modifying the existing Order of Court to granting Father shared physical custody of the minor child. 11. In addition, Father seeks that Mother be found in contempt of the June 20, 2003 Order of Court and be ordered to pay his reasonable attorney fees in the amount of $1,500 for the preparation and presentation of this Petition. 12. Father also seeks make-up time with the child for all of the missed periods of partial custody over the last sixty (60) days. 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Petitioner respectfully requests This Honorable Court find Mother in contempt of the June 20, 2003 Order of Court and modify the Order as requested by Father. Dated: By: Respectfully submitted, COLGAN --ASSOCIATES, LLC stsj er Smull, Esquire Attorney ID # 69140 130 West Church Street Suite 100 Dillsburg, PA 17019 Phone: (717) 502-5000 Fax: (717) 502-5050 LAMONT L. MAHONEY, JR., : IN THE COURT OF COMMON PLEAS Petitioner/Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2002-4397 DEANA MURLATT, : CIVIL ACTION - LAW Respondent/Defendant : IN CUSTODY VERIFICATION I, Lamont L. Mahoney, Jr., verify that the statements made in this Petition 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: a )3))1)) q EXHIBIT "A" LAMONT L. MAHONEY, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2002-4397 CIVIL TERM CIVIL ACTION - LAW DEANA MURLATT, Defendant : CUSTODY ORDER. OF COURT AND NOW, this 20th day of June, 2003, we enter the following Order which shall replace any prior Order entered in this matter: 1. The parties shall have shared legal custody of their child, Lamont L. Mahoney, III, born September 17, 2001. Each parent shall have 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, religion, and welfare. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the child, including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody of the child. 3. Father shall have periods of partial physical custody with his child as follows: A. On Saturday, June 21, 2003, from 10:00 a.m. until 8:00 p.m. B. On Sunday, June 29, 2003, from 10:00 a.m. until 8:00 p.m. C. On Thursday, July 3, 2003, from after work until Friday, July A, 2003, at noon. D. Every other weekend from Friday at 6:00 p.m. until Sunday at 6:00 p.m. commencing Friday, July 11, 2003. E. Every Tuesday, from after work at 5:00 p.m. until 8:00 p.m. 4. Each party shall be entitled to one week of exclusive custody of the child in the summer commencing the summer of 2004. The parties shall notify each other of the dates he or she intends to exercise such custody prior to May 1 of each year. 5. Father shall have partial physical custody of the child on the following holidays: A. Every Thanksgiving from 3:00 p.m. until 8:00 p.m. B. From noon Christmas day until 8:00 p.m. Christmas night in odd numbered years. C. From after work on Christmas eve, or if he is not working from 3:00 p.m. Christmas eve until noon Christmas day. D. The following holidays on an alternating basis from 9:00 a.m. until 8:00 p.m.: Labor Day, New Years Day, Easter, Memorial Day, July 4. It is our intention that Mother shall have the child on those holidays upon which Father does not have him. The above holiday schedule shall supersede any regularly scheduled visitation. 6. If Mother's Day falls on Father's scheduled weekend, he shall return the child by 9:00 a.m. If Father's Day falls on a weekend that Father does not have the child, he shall be entitled to visit with the child from 9:00 a.m. until 8:00 p.m. 7. The parties shall share the child's birthday as follows: A. In odd numbered years, Mother shall have the child from 4:00 p.m. until 6:00 p.m., and Father shall have the child from 6:00 p.m. until 8:00 p.m. In even numbered years, Father shall have the child from 5:30 p.m. until 7:30 p.m. This section shall supersede any other regularly scheduled visitation. 8. Father shall pick the child up at the commencement of his periods of partial custody at daycare or Mother's residence, as the case may be. He shall return the child to Mother's residence at the conclusion of visitation. 9. The parties shall keep each other informed of current addresses and phone numbers, both at work and at home. They shall also notify the party of any illness or accident or other serious circumstance affecting the welfare of the child while in said party's care and custody. 10. Both parties shall have the right to reasonable telephone contact with the child during the other party's period of custody. 11, Neither Father nor Mother shall make disparaging remarks regarding the other parent in the presence of the child. 12. For the next 60 days, on the days that Father does not have visitation with the child, Mother shall e-mail him something positive about the child. Father must then respond to said e-mail. On the days when Father has the child, he shall e-mail something positive to Mother regarding the child. Mother must respond. Copies of the e-mails sent and received shall be filed to this term and number to be made part of the record so that we can refer to them if the matter comes before us in the future. Jeanne B. Costopoulos, Esquire Attorney for Plaintiff Steven Howell, Esquire Attorney for Defendant srs LAMONT L. MAHONEY, JR., : IN THE COURT OF COMMON PLEAS Petitioner/Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2002-4397 DEANA MURLATT, : CIVIL ACTION - LAW Respondent/Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Kristopher T. Smull, Esquire, do hereby certify that on this date, I served a true and correct copy of Plaintiff s Petition for Contempt and Modification upon the following individual, via facsimile, addressed as follows: Dated: Steven Howell, Esquire 619 Bridge Street New Cumberland, PA 17070 By: COLGAN ASSOC ATES, LLC opt' . 11, ire Supreme Court I.D. #69140 130 West Church Street, Suite 100 Dillsburg, PA 17019 (717) 502-5000 Attorney for Plaintiff LAMONT L. MAHONEY, JR., : IN THE COURT OF COMMON PLEAS Petitioner /Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2002 -4397 DEANNA MURLATT, : CIVIL ACTION - LAW Respondent /Defendant : IN CUSTODY CRIMINAL RECORD /ABUSE HISTORY VERIFICATION I, Lamont L. Mahoney, Jr., hereby swear or affirm, subject to penalties of law including 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities that: 1. Unless indicated by my checking the "YES" box next to a crime below, neither I nor any member of my household has been convicted or has pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to Juvenile Act, 42 Pa.C.S. § 6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Answer Crime Self Other Date of Yes or No household conviction, member guilty plea, no contest plea or pending charges YES NO ❑ 18 Pa.C.S. Ch. 25 ❑ (relating to criminal homicide) ❑ Lt3" 18 Pa.C.S. §2702 (relating to aggravated assault) ❑ Ii 18 Pa.C.S. §2706 ❑ (relating to terroristic threats) 18 Pa.C.S. §2709.1 �/ (relating to stalking) • Lid' 18 Pa.C.S. §2901 (relating to kidnapping) ❑ 18 Pa.C.S. §2902 (relating to unlawful restraint) Sentence ❑ rte- <c� ▪ -'C) `r ' -'--1 ❑ -- C-- gip{ 1 0 ❑ Answer Crime Self Other Date of Yes or No household conviction, member guilty plea, no contest plea or pending charges YES / NO ❑ u 18 Pa.C.S. §2903 ❑ ❑ (relating to false imprisonment). ❑ Li 18 Pa.C.S. §2910 (relating to luring a child into a motor vehicle or structure} ❑ LJ 18 Pa.C.S. §3121 ❑ (relating to rape) ❑ Rr 18 Pa.C.S. §3122.1 ❑ (relating to statutory sexual assault) ❑ I vd' 18 Pa.C.S. §3123 (relating to involuntary �/ deviate sexual intercourse) ❑ Ii 1 18 Pa.C.S. §3124.1 ❑ (relating to sexual assault) ❑ 18 Pa.C.S. §3125 ❑ (relating to aggravated indecent assault) ❑ 18 Pa.C.S. §3126 ❑ ❑ / (relating to indecent assault) ❑ E i 18 Pa.C.S. §3127 ❑ ❑ (relating to indecent exposure) ❑ 18 Pa.C.S. §3129 ❑ (relating to sexual intercourse with animal) ❑ [Dr 18 Pa.C.S. §3130 ❑ (relating to conduct relating to sex offenders) ❑ 18 Pa.C.S. §3301 ❑ ❑ (relating to arson and related offenses) ❑ 18 Pa.C.S. §4302 ❑ ❑ (relating to incest) ❑ ❑ ❑ Answer Yes or No Crime YES NO R" 18 Pa.C.S. §4303 (relating to concealing death of child) 18 Pa.C.S. 54304 (relating to endangering welfare of children) o 18 Pa.C.S. 54305 (relating to dealing in infant children) 18 Pa.C.S. §5902(b) (relating to prostitution and related offenses) 18 Pa.C.S. §5903(c) or (d) (relating to obscene and other sexual materials and performances) Self Other Date of household conviction, member guilty plea, no contest plea or pending charges 0 0 18 Pa.C.S. 56301 0 {relating to corruption of minors) 18 Pa.C.S. §6312 0 (relating to sexual abuse of children) 18 Pa.C.S. §6318 0 (relating to unlawful contact with minor) 18 Pa.C.S. 56320 (relating to sexual exploitation of children) 23 Pa.C.S. § 6114 (relating to contempt for violation of protection order or agreement) Driving under influence of drugs or alcohol E7( Sentence Answer Yes or No YES NO Crime Manufacture, sale or delivery, holding, offering for sale or possession of any controlled substance or other drug or device Other Date of household conviction, member guilty plea, no contest plea or pending charges Sentence 2. Unless indicated by my checking the "YES" box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Answer Yes or No YES NO ❑ f Self A finding of abuse by a Children & Youth Agency or similar agency in Pennsylvania or similar statute in another jurisdiction. Abusive conduct as defined under the Protection from ❑ Abuse Act in Pennsylvania or similar statute in another Jurisdiction. Other: Other household member Date 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child. 5. If you are aware that the other party or member of the other party's household has or have a criminal /abuse history, please explain: I verify that the statement made in this Criminal Record /Abuse History Verification are true and correct to the best of my knowledge. information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities and can be punishable by fine or imprisonment. Date Printed Name LAMONT L. MAHONEY, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF V. DEANA MURLATT DEFENDANT CUMBERLAND COUNTY, PENNSYLVANIA 2002 -4397 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, March 07, 2014 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, April 08, 2014 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in- person contact with the court (including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT. By: /s/ Dawn S. Sunday, Esq.tll(' 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. twl goc.4)Eit A-1441. S'Llxisy 3frofrf Cumberland County Bar Association r-, 32 South Bedford Street c -n Carlisle, Pennsylvania 17013 rrr CZ = ' rn Telephone (717) 249 -3166 rn 22. ch LAMONT L. MAHONEY JR IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. DEANA MURLATT 2002-4397 CIVIL ACTION LA Defendant IN CUSTODY ORDER OF COURT AND NOW, this /6 day of flAriL , 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall make arrangements to engage in therapeutic family counseling with Vivian Blanc or other professional selected by agreement between the parties. The parties shall also make arrangements for the Child to participate in the counseling based upon the recommendations of the counselor as to timing. The purpose of the family counseling shall be to assist the parties in resolving conflicts which have arisen in the family, assess the Child's emotional wellbeing, provide guidance to the parents in an effort to establish a close relationship between the Father and Child, and to resume the custodial schedule as soon as possible. All costs of the counseling shall be shared equally between the parties. 2. After the parties have completed three joint sessions with the counselor and the Child has had three sessions with the counselor, in the event either party feels at that point that no progress is being made toward reuniting the Father and Child, the parties and counsel shall make arrangements to work together to address those concerns. If that process is unsuccessful, counsel for either party may contact the conciliator to either schedule a follow-up custody conciliation conference or a hearing. Edward E. Guido J. cc: Xristopher T. Smull Esquire — Counsel for Father agteven Howell Esquire — Counsel for Mother 3 LAMONT L. MAHONEY JR IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. DEANA MURLATT Defendant Prior Judge: Edward E. Guido 2002 -4397 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 BIRTH YEAR CURRENTLY IN CUSTODY OF Lamont L. Mahoney III 2001 Mother 2. A custody conciliation conference was held on April 8, 2014, with the following individuals in attendance: the Father, Lamont L. Mahoney Jr., with his counsel, Kristopher T. Smull Esquire, and the Mother, Deana Murlatt, with her counsel, Steven Howell Esquire. 3. The Father filed this Petition for Contempt and Modification. The Mother's counsel prepared and presented a Petition to Modify Custody, which had not been filed as the Father's Petition was filed first. The parties agreed to attempt to resolve their conflicts and concerns with regard to the Child and the custody arrangements through therapeutic family counseling. However, in light of the fact that the Father has not had his periods of custody with the Child since January, 2014, it was agreed that counsel for either party could contact the conciliator to request the scheduling of a hearing after attending a minimum number of counseling sessions. 4. The conciliator recommends an Order in the form as attached. Dawn S. Sunday, Esquire Custody Conciliator LAMONT L. MAHONEY, JR., Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-4397 DEANA MURLATT, : CIVIL ACTION - LAW Defendant : IN CUSTODY CUSTODY STIPULATION AND AGREEMENT = -Q- co x vn ter; v <© -0 -71 -r, THIS STIPULATION AND AGREEMENT entered into the day and year Rina ter s t , forth, by and between LAMONT L. MAHONEY, JR., (hereinafter referred to as "Fahey aifd, DEANA MURLATT (hereinafter referred to as "Mother"). WHEREAS, the parties are the natural parents of one (1) child, namely: Lamont L. Mahoney, III, born on September 17, 2001 (age 12); and WHEREAS, the parties live separate and apart, and wish to enter into a new stipulation and agreement relative to physical and legal custody of their child. NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: 1. LEGAL CUSTODY: Legal custody of the minor child shall be vested solely in Mother. 2. PHYSICAL CUSTODY: Physical custody of the minor child shall be vested solely in Mother. The child shall be free to visit with Father at any time that he chooses and Mother shall cooperate and accommodate any request for visits made by the child. 3.. JURISDICTION: The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor child. 4. RELOCATION: No party shall relocate the child if such relocation will significantly impair the ability of the non -relocating party to exercise the other party's custodial rights unless (a) every person who has custodial rights to the child consents to the proposed relocation or (b) the Court approves the proposed relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337. 5. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other Ply. 6. The parties acknowledge that they have read and understand the provisions of this Agreement. WHEREFORE, the parties agree that this Agreement and Stipulation of Custody shall be submitted to the Cumberland County Court of Common Pleas for entry as a Custody Order. Both parties acknowledge that they have entered into this Agreement and Stipulation of Custody voluntarily. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. Witness DEANA MURLATT LAMONT L. MAHONEY, JR., : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2002-4397 DEANA MURLATT, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW this 1 day of f ��,t6 tl,,C1- , 2014, the attached Custody Stipulation and Agreement is hereby made an Order of Court. Distribution: ✓ Kristopher T. Smull, Esquire Attorney for Plaintiff 130 West Church Street Suite 100 Dillsburg, PA 17019 Steven Howell, Esquire Attorney for Defendant 619 Bridge Street New Cumberland, PA 17070 ccri.e.s PaitecL 4V 1 BY THE URT, J. 3