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HomeMy WebLinkAbout05-0321 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; No. oj~:J..2.,. ROYG. SWANN, Plaintiff . Defendant : CIVIL ACTION - LAW : CUSTODY ANGELA MILLER, COMPLAINT IN CUSTODY AND NOW, the Plaintiff, ROY G. SWANN, by and through his attorney, Jeanne B. Costopoulos, Esquire, makes the following Complaint in Custody: I. The Plaintiff, Roy G. Swann (hereinafter referred to as Father), is an adult individual who currently resides at 604 North Baltimore Avenue, Apt. L, Mt. Holly Springs, Pennsylvania, 17065. 2. The Defendant, Angela Miller (hereinafter referred to as Mother), is an adult individual who is believed to reside at 604 North Baltimore Avenue, Apt. L, Mt. ,Holly Springs, Pennsylvania, 17065. 4. Father seeks primary physical custody of the following child: Name Present Residence Aile All E. Swann 604 N. Baltimore Ave. Mt. Holly Springs, PA 8 months DOB 5/9/04 5. The child named above is presently temporarily in the custody of Father at an undisclosed location in Cumberland County, Pennsylvania, pending review of his emergency petition filed simultaneously with this Complaint. 6. Since birth, the child has resided with the following perso1)S.at the following addresses: Name Address Dates Father Mother 605 North Baltimore Ave. Mt. Holly Springs, P A birth to present 7. The mother of the child is Angela Miller, Defendant, and the father of the child is Roy G. Swann, Plaintiff, both CUlTently residing at 604 North Baltimore Avenue, Apt. L, Mt. HoUy Springs, Cumberland County, Pennsylvania. 17065. Father is cunently holding the child temporarily at an undisclosed location in an effort to prevent Mother from absconding with the child to another jurisdiction pending a preliminary determination by this Honorable Court. 8. Father has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 9. Father does not know of a person not a party to the proceedings who has physical custody of the child or claims to have physical custody or visitation rights with respect to the child. 10. The best interests and permanent welfare of the child will be served by granting primary physical custody of the child to Father subject to specific periods of partial custody with Mother. , II. 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. No other persons are known to have or claim a right to custody or visitation of the child to be given notice of the pendency of this action and the right to intervene. WHEREFORE, PlaintiftlFather respectfully requests that he be granted primary physical custody of Ali' E. Swann. ,. Respectfully submitted, J~"':: ATTORNEY FOR PLAINTIFF 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Telephone: (717)7~9546 PA Supreme Ct. ID No. 68735 Dated: ,'07/df , Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYLV ANIA ROY G. .SW ANN, v. : No. Defendant : CIVIL ACTION - LAW : CUSTODY ANGELA MILLER, VERIFICATION I, Roy G. Swann, Plaintiff, hereby verify that the statementS made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~904, relating to unsworn falsification to authorities. Date: 1-) ?-c:>S- s;_ ~4/ o . Swann ("J r-" .r,-:::.l (') , c::;J -;-\ '''~ (;,of-' ....1 ~ ..A ....... ~t ,.. \' ..... :.;.; pl/1 '- -:-~ '..-, ~ crJ ~)-C-? ~ , " -2:~> :::'.. . - ~ , ~ \.,D n "^ :.:~ ~. ~ -,' ::'''' {-- :) ..s-:. ~-( " - " ~ ~. -.1::::. -------- ROY G. SWANN, Plaintiff : IN THE COURT OF COMMON PLEAS ; CUMBERLAND COUNTY, PENNSYLVANIA v. : No. ANGELA MILLER, Defendant : CIVIL ACTION - LAW : CUSTODY PLAINTIFF'S PETITION FOR EMERGENCY RELIEF AND NOW, the Plaintiff, Roy G. Swann, by and through his attorney, Jeanne B. Costopoulos, Esquire, avers the fOllowing in support of this Petition for Emergency Relief: I. The Plaintiff, Roy G. Swann (hereinafter referred to as Father), is an adult individual who currently teSides at 604 North Baltimore Avenue, Apt L, Mt Holly Springs, Pennsylvania, 17065. 2. The Defendant, Angela Miller. (hereinafter refelTed to as Mother), is an adult individual who is believed to reside at 604 North Baltimore Avenue, Apt L, Mt. . Holly Springs, Pennsylvania, 17065. 3. The Plaintiff has simultaneously filed a Complaint in Custody seeking primary physical custody of the following child: Name Present Residence Age AIi E. Swann 604 N. Baltimore Ave. Mt. Holly Springs, P A 8 months DOB 5/9/04 4. The child named above is presently temporarily in the custody of Father at an undisclosed location in Cumberland County, Pennsylvania, pending review of this emergency petition. Father took the child on January 16,2005 and has not returned since. 5. Since birth, the child has resided with both parties at 604 North Baltimore Avenue, Apt. L, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 6. Father requests that an emergency order granting him primary physical custody of the child is in the best interests of the child for the following reasons: (a) On September 23, 2004, Father took the child with him when he took his grandmother to a massage therapy appointment. When he returned from the appointment, Mother was drunk and belligerent and started throwing things at Father. She forcibly removed the child from Father's arms and ran out of the apartment. He went to look for her and when he returned she was already back. She called her sister saying she had taken a whole bottle of Tylenol. Yellow Breeches ambulance service was summoned and she was taken to Carlisle Regional. While at the hospital, she admitted having attempted suicide three times prior. Nevertheless, she refused to speak to Crisis Intervention and was released against medical advice shortly thereafter. (b) At the end of October of 2004, Mother was giving the child a bath and was arguing with Father. When Father went to leave in an effort to stop the argument, Mother took the child out of the bathtub, put a diaper on her, set her in the hall and shut the door. Father stayed with the child at the apartment of his sister, Erin Swann, whose apartment is located on a lower floor of the same apartment building where Father resides with Mother and the subject child. (c) On January S, 2oo51Mo~ showed up at Father's job and ~ an argwnent '" . ,-. ' , I ,- . . , with him. Father locked himself in his office and Mother said if he did not come out she was taking his car and the child to Williamsport. (Mother has previously taken Father's car without his permission even though she does not have a driver's license.) Father's sister, Marybeth Ronemus, was babysitting the child so Mother went to her house. Father warned his sister, MaIybeth, and asked her to try to get his car keys from Mother. Mother arrived and Marybeth asked her for Father's keys and she refused to provide them. The police were called who allowed Mother to have the child but told her not to go near Father's car. (d) On January 14, 2005, Mother called Father at work and told him that he needed to come home because she could not handle the child. Father heard the child screaming loudly in the background. Father informed Mother that he cannot just leave work wherever he wants and Mother responded by saying that in any case she was leaving the child in her playpen while she went to lie down. Father immediately called his sister, Erin Swann, and asked her to check on the child. Erin went to the apartment together with a friend, Lynn MUlTllY, who is employed as a social ~orker in a Duncannon nursing home. Mother answered the door and told Erin everything was fine and let them both in. The child was crying and reached for Erin and Erin picked up the child. Mother then called Father at work again and threatened to run with the child so that he would never find her., She thenslw;nmed the phone down, $c::reamed out "asshole!" then started slamming doors. Mother then made repeated hang-up calls to Father at his work. When Father returned from work, both Mother and child were asleep. As is her custom after immature and explosive episodes, Mother acted like . nothing out of the ordinary had occurred when she woke up the next morning. (e) On the night of Saturday, Janwuy 15, 2005; Father's sister Erin had gone out and so Father's other sister, Marybeth Ronernus, together with her husband, Joseph Ronernus, were watching Father's grandmother at Erin's apartment. Since Erin had not yet returned home Marybeth requested Father to corne downstairs to watch his grandmother until Erin returned home. Mother objected, grabbed the phone and repeatedly swore at Marybeth and at one point threatened to kill her (which was the second time she made this threat). She was screaming so loudly that the subject child was immediately awakened and began crying. Marybeth called the police and Mother was issued a summary harassment citation by Officer Byers of the Mt. Holly Police Department Immediately after Officer Byers left the apartment, Mother threw a pointsetta plant across the room which smashed against the stove and shattered everywhere. She also threw the citation and beat against the table. She then called her mother in Williamsport, Lycoming County, who told Mother not to let Father have the child. Mother responded to her mother by saying: "Before I'll let Roy and his sisters have this baby I will kill myself and Ali". Her mother told her not to say things like that and said she'd be over to pick her and the child up the next morning to take them both to Williamsport. Mother then went to bed. After Mother was asleep, Father put the child to bed in her basinet Mother woke up about half and hour later and pulled out a nightlight and threw it at Father telling him to come to bed. Father waS up with the child a few more times throughout the night When the child awoke at 8:30 a.m., Father fed her, changed her, and dressed her. He then left the house with the child while Mother was still sleeping and before her mother got there from Williamsport or Mother otherwise attempted to flee the jurisdiction with the child. (f) On Sunday, January 16,2005, and Monday, January 17, 2005, Mother called various police departments threatening to file kidnapping charges against Father ifhe did not return home with the child so she can take the child to her mother's home in Williamsport. . (g) Since the child's birth, Mother has used the child as a tool to get Father to do as she says. Practically every weekend since the child was born she has threatened to leave and take the child with her. On some occasions, Mother threatens to go to her mother's house in Williamsport. Other times, Mother says she'll stay with Father temporarily until she applies farlow-income housing at the WiIliamsport Village (where she has lived before). Mother previously called Williamsport Village for an application. Most recently, on Friday, January 14. 2005, Mother told Father that she was going to Williamsport with the child and that if he filed anything in court to seek custody rights to the child that she would take off, "live off the street", and not apply for benefits so that he could never find them. 7. As a result of the above, Father has not returned home since January 15,2005, because he fears that if given the opportunity Mother will immediately flee with the child as she has threatened numerous times in the past. In addition, Father fears for the safety of the child while in Mother's custody due to her statements regarding killing herself and the child and her previous suicide attempts. WHEREFORE, Plaintiff respectfully requests that he be granted temporary physical custody of AIi, E. Swann, pending the scheduling of a hearing or conference on the matter. Respectfully submitted, y ------------- Dated: ~ Jeanne B. Costopoulos, Esquire ATTORNEY FOR PLAINTIFF 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone: (717)790-9546 P A Supreme Ct. 10 No. 68735 . . Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ROY G. SWANN, v. : No. Defendant : CIVIL ACTION - LAW : CUSTODY ANGELA MILLER, VERIFICATION I, Roy G. Swann, Plaintiff, hereby verifY that the statements made in the foregoing 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: 1-/7-(7.,- s_~ oy . Swann ,~ '- ~. ~~ ~. ~ \ ~ ~ ~ 'l-... . ~ C> " .-' c:=' (::;C1 l~" ~ ~ .- ...,.-," -- / ~,--<. c.0 C) ...:''(1. ..... -r'. ~'{'\ ,"nf:::' _ ~..;:-r. . : ~-.:~) . \(?, -,~, \ .~~ ;:_~ l. ,: .-..-n " '''';' '~; ......;.. ....... "";J tS" (jt ROY G. SWANN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; No. V--5 - ...:JJ..1 v. ANGELA MILLER, Defendant CIVIL ACTION - LAW CUSTODY PLAINTIFF'S PETITION FOR EMERGENCY RELIEF AND NOW, the Plaintiff, Roy G. Swann, by and through his attorney, Jeanne B. Costopoulos, Esquire, avers the following in support of this Petition for Emergency Relief: 1. The Plaintiff, Roy G. Swann (hereinafterreferred to as Father), is an adult individual who currently resides at 604 North Baltimore Avenue, Apt. L, Mt. Holly Springs, Pennsylvania, 17065. 2. The Defendant, Angela Miller (hereinafter referred to as Mother), is an adult individual who is believed to reside at 604 North Baltimore Avenue, Apt. L, Mt. Holly Springs, Pennsylvania, 17065. 3. The Plaintiff has simultaneously filed a Complaint in Custody seeking primary physical custody of the following child: Name Present Residence Age Ali E. Swann 604 N. Baltimore Ave. Mt. Holly Springs, P A 8 months DOB 5/9/04 4. The child named above is presently temporarily in the custody of Father at an undisclosed location in Cumberland County, Pennsylvania, pending review of this emergency petition. Father took the child on January 16, 2005 and has not returned since. 5. Since birth, the child has resided with both parties at 604 North Baltimore Avenue, Apt. L, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 6. Father requests that an emergency order granting him primary physical custody of the child is in the best interests of the child for the following reasons: (a) On September 23, 2004, Father took the child with him when he took his grandmother to a massage therapy appointment. When he returned from the appointment, Mother was drunk and belligerent and started throwing things at Father. She forcibly removed the child from Father's arms and ran out of the apartment. He went to look for her and when he returned she was already back. She called her sister saying she had taken a whole bottle of Tylenol. Yellow Breeches ambulance service was summoned and she was taken to Carlisle Regional. While at the hospital, she admitted having attempted suicide three times prior. Nevertheless, she refused to speak to Crisis Intervention and was released against medical advice shortly thereafter. (b) At the end of October of 2004, Mother was giving the child a bath and was arguing with Father. When Father went to leave in an effort to stop the argument, Mother took the child out of the bathtub, put a diaper on her, set her in the hall and shut the door. Father stayed with the child at the apartment of his sister, Erin Swann, whose apartment is located on a lower floor of the same apartment building where Father resides with Mother and the subject child. (c) On January 5, 2005, Mother showed up at Father's job and sHtrted an argument '1'- ,'" ' . , . , with him. Father locked himself in his office and Mother said if he did not come out she was taking his car and the child to Williamsport. (Mother has previously taken Father's car without his pennission even though she does not have a driver's license.) Father's sister, Marybeth Ronemus, was babysitting the child so Mother went to her house. Father warned his sister, Marybeth, and asked her to try to get his car keys from Mother. Mother arrived and Marybeth asked her for Father's keys and she refused to provide them. The police were called who allowed Mother to have the child but told her not to go near Father's car. (d) On January 14, 2005, Mother called Father at work and told him that he needed to come home because she could not handle the child. Father heard the child screaming loudly in the background. Father infonned Mother that he cannot just leave work wherever he wants and Mother responded by saying that in any case she was leaving the child in her playpen while she went to lie down. Father immediately called his sister, Erin Swann, and asked her to check on the child. Erin went to the apartment together with a friend, Lynn Murray, who is employed as a social worker in a Duncannon nursing home. Mother answered the door and told Erin everything was fine and let them both in. The child was crying and reached for Erin and Erin picked up the child. Mother then called Father at work again and threatened to run with the child so that he would never find her. She then slaguned the phone down, screamed out "asshole!" then started slamming doors. Mother then made repeated hang-up calls to Father at his work. When Father returned from work, both Mother and child were asleep. As is her custom after immature and explosive episodes, Mother acted like . nothing out of the ordinary had occurred when she woke up the next morning. (e) On the night of Saturday, January IS, 2005, Father's sister Erin had gone out and so Father's other sister, Marybeth Ronemus, together with her husband, Joseph Ronemus, were watching Father's grandmother at Erin's apartment. Since Erin had not yet returned home Marybeth requested Father to come downstairs to watch his grandmother until Erin returned home. Mother objected, grabbed the phone and repeatedly swore at Marybeth and at one point threatened to kill her (which was the second time she made this threat). She was screaming so loudly that the subject child was immediately awakened and began crymg. Marybeth called the police and Mother was issued a summary harassment citation by Officer Byers of the Mt. Holly Police Department. Immediately after Officer Byers left the apartment, Mother threw a pointsetta plant across the room which smashed against the stove and shattered everywhere. She also threw the citation and beat against the table. She then called her mother in Williamsport, Lycoming County, who told Mother not to let Father have the child. Mother responded to her mother by saying: "Before I'll let Roy and his sisters have this baby I will kill myself and Ali". Her mother told her not to say things like that and said she'd be over to pick her and the child up the next morning to take them both to Williamsport. Mother then went to bed. After Mother was asleep, Father put the child to bed in her basinet. Mother woke up about half and hour later and pulled out a nightlight and threw it at Father telling him to come to bed. Father was up with the child a few more times throughout the night. When the child awoke at 8:30 am., Father fed her, changed her, and dressed her. He then left the house with the child while Mother was still sleeping and before her mother got there from WilIiamsport or Mother otherwise attempted to flee the jurisdiction with the child. (f) On Sunday, January 16,2005, and Monday, January 17,2005, Mother called various police departments threatening to file kidnapping charges against Father ifhe did not return home with the child so she can take the child to her mother's home in Williamsport. . (g) Since the child's birth, Mother has used the child as a tool to get Father to do as she says. Practically every weekend since the child was born she has threatened to leave and take the child with her. On some occasions, Mother threatens to go to her mother's house in Williamsport. Other times, Mother says she'll stay with Father temporarily until she applies for low-income housing at the Williamsport Village (where she has lived before). Mother previously called WilIiamsport Village for an application. Most recently, on Friday, January 14, 2005, Mother told Father that she was going to Williamsport with the child and that if he filed anything in court to seek custody rights to the child that she would take off, "live off the street", and not apply for benefits so that he could never fmd them. 7. As a result of the above, Father has not returned home since January 15, 2005, because he fears that if given the opportunity Mother will immediately flee with the child as she has threatened nwnerous times in the past. In addition, Father fears for the safety of the child while in Mother's custody due to her statements regarding killing herself and the child and her previous suicide attempts. WHEREFORE, Plaintiff respectfully requests that he be granted temporary physical custody of Ali E. Swann, pending the scheduling of a hearing or conference on the matter. Respectfully submitted, ~ ~ Dated: ~ Jeanne B. Costopoulos, Esquire ATTORNEYFORPLAlNT~F 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Telephone: (717) 790-9546 P A Supreme Ct. ID No. 68735 .........~, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ROY G. SWANN, v. : No. Defendant : CIVIL ACTION - LAW : CUSTODY ANGELA MILLER, VERIFICATION I, Roy G. Swann, Plaintiff, hereby verify that the statements made in the foregoing 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: / -/ l-,f~ Siwm- ~f oy . Swann ,~ '- ~. ~ ~ ~ ~ ~ ~ ~ ~ " . ~ ~~ ~~; ~A CJ' _--\ ( -r:" -.. 111 :'x.: _ __~ c', ,-.~ , _.I_ \..c.: '.;,) (,., -< '--'-' JAN 1 8 2005 ~ f ROY G. SWANN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. t!.)- 3d. ( 6tJ ANGELA MILLER, Defendant : CIVIL ACTION - LAW : CUSTODY ORDER OF COURT AND NOW, this /9 r day of 9tt..u~ , 2005, upon consideration of Plaintiffs Petition for Emergency Relief, it is hereby ordered and decreed that temporary primary physical custody of the parties' minor child, Ali E. Swann, born May 9, 2004, shall be with -I/.... ';;'),;., of .... Q.,. rCorlJ' ~ hi Plaintiff, Roy G. Swann, pending !l i1.ellFiRg te take fllaee 8ft the_ allY 8f , :;?'iJQ$, ~"1.....h.''f (J. ~\..;. at .1t~. ill Ce1::HiIaaftl ~ro. uf dlt; CWllUCllwld Cuwuy C\Jw(huu;jc, OlI~ Ce'tlf1ft6tiSG S<tucuc;;, CarlISle, rCJlIl~Jl~ania.\. BY THE COURT: 4;1 1. N -},t ~ ~-{;~ . r' " f. ~\(p ~ -)\\ , ~ i. ~ ~ 1;.1 (~:[l11,:1} t} i uvr ~;JOZ I,"", .:Jv ROY G, SWANN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, 05-321 CIVIL ACTION LAW ANGELA MILLER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, January 21, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. . the conciliator, at DJ Manlove's, 1901 State St., Camp Hill, PA 17011 on "Friday, March. 04, 2005 at 9:30 AM for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the eon ference, 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 h.ours prior to scheduled hearing. FOR THE COURT. By: ~_ Melissa P. GreelY, Esq. vt-l__ Custody Conciliator ~- The Court of Common Pleas of Cumberland County is requin,d by law to comply with the Americans with Disabilites Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business be/ore the court. You must attend the scheduled conference or hearing, YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (7 I 7) 249-3166 ~#f UiJ (lv-fiE.! "~~. fr'/ 1ff~ 1'~tlvt, }{I-fit' ( ,'Z L>( , ~ kH/f"? jd^' ~?1r' ;< , ",,0,. ,-; , ,-c. ""~ ." '- \ .... ~o Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROY G. SWANN, v. No. 05-321 CIVIL ANGELA MILLER, Defendant CIVIL ACTION - LAW IN CUSTODY CUSTODY AGREEMENT THE FOLLOWING AGREEMENT, made this 1 st day of February, 2005, between Plaintiff, Roy G. Swann (Father), and Defendant, Angela Miller (Mother), concerns the custody of their child, Ali E. Swann (Child), born May 9, 2004. Mother and Father agree to the following: 1. Mother and Father shall enjoy shared legal custody of the Child. Each parent shall have an equal right to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's well-being including, but not limited to, all decisions regarding the Child's health, education and religion. 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. Mother and Father shall share physical custody of the Child as follows: Mother shall have custody beginning every Monday at 2 p.m. through Saturday at 8 a.m.; Father shall have custodial periods every Monday through Friday during the hours of 10:00 a.m. until 2:00 p.m. Father shall have physical custody of the Child every Saturday beginning at 8 a.m. through Monday at 2:00 p.m. Mother shall have visitation with the Child on Saturdays from 12:00 p.m. through 5:00 p.m. 3. Mother and Father shall share physical custody ofthe Child on holidays at times mutually agreed to by the parties. 4. Father and Mother agree to attend parenting counseling together. Mother will also seek individual counseling. 5. Neither party shall consume alcohol to point of intoxication or use illegal drugs during their periods of custody. 6. Father shall be responsible for all transportation associated with the custodial exchanges. 7. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 8. Mother and Father agree that a custody conciliation will no longer be necessary based on the terms of this Custody Agreement. 9. Mother and Father desire that this Custody Agreement be made an Order of Court. / ! ~~:/ci / oy~. Swann Plaintiff ) / ,././ ,,~ -. J(anne B. Costopoulos, Esq. Counsel for Plaintiff The Executive Offices at Rossmoyne 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 f . ~e JWtt:: L'nda E. LeFever Certified Legal Intern C{~~i.c)~1 "Lucy 0 non-Walsh Anne acDonald-Fox Robert E. Rains Thomas M. Place Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 (717) 243-2968 (717) 243-3639 '. .... ~ 1"~,. r:J c.;) C.J't -'1 rS"l v~) 1 , -" - .,.,,- L'" r-,.) 0" FEB 0 8 200t v\ ROY G. SWANN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA v. : No. 05-321 CIVIL ANGELA MILLER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT And now on this /(1' day of February, 2005, the attal;hed Custody Agreement is approved and entered as an Order of Court. A'i , \., . (u. ~ j:,f , , ~s :O\~ \ \ 93J_ Plaintiff fEa 1 8 2005 ,/ P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-321 CIVIL TERM ROY G. SWANN, v. CIVil ACTION - lAW ANGELA MillER, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 4th day of February, 2005. the parties having reached an agreement which has been memorialized in a Stipulation and filed with this Court, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. FOR THE M~;,.. pe!'Gre&~ Custody Conciliator :244270 ~