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HomeMy WebLinkAbout05-0908 '11, Jason Z. Slenker, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05- 1D1 CIVIL TERM : CIVIL ACTION - CUSTODY v. Denise A. Slenker , Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Jason Z. Slenker, an adult individual whose residence is at 24 Pine Ridge Circle, Enola, Cumberland County, Pennsylvania. 2. Defendant is Denise A. Slenker, an adult individual whose residence is at 24 Pine Ridge Circle, Enola, Cumberland County, Pennsylvania, 3. Plaintiff seeks custody of his child, Chase R. Slenker, born August 10, 2001, currently residing at 24 Pine Ridge Circle, Enola PA. 4, The child is presently in the custody of Plaintiff/Defendant. 5. Since the child's birth, the child has resided at the following address: Name Address Dates Chase R. Slenker 24 Pine Ridge Circle, Enola PA Birth to Present 6. The relationship of the Plaintiff to the child is that of natural father. 7. The relationship of the Defendant to the child is that of natural mother. 8. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other Court. 9, Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 10. Plaintiff and Defendant have been separated since January 25,2005 11. The best interest and permanent welfare of the child will be selVed by granting the relief requested because the Plaintiff is the primary care giver with respect to the child. A. It is the best interest that the father has primary physical custody because father has cared for and nurtured the child a predominant amount oftimes since the child's birth. Father provides nourishment for the child. B. .'1': c. Father bathes and places the child in bed after a bedtime story a predominant amount of time. From the child's twelve weeks of age to one year old, the father was the "home maker" while mother was employed out side the home and father has been "home maker" through January 5, 2005. From January 5th to the present the father was also the primary caregiver for the child and it appears that the child has a greater bond with his father than with the mother. Furthermore, the child requires the stability of the marital home where the father resides and it is believed and therefore averred that the mother is relocating outside the marital household, D. E. 12. 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 to have any right to custody or visitation of the child other than the parties to this action. II -, WHEREFORE, Plaintiff requests your Honorable Court provide shared legal custody of the minor Chase A. Slenker and that primary physical custody be awarded to the Plaintiff, Father with liberal agreed upon visitation awarded to the defendant, Mother. Respectfully Submitted TURO LAW OFFICES ~/~.> Date ---8 en R. Waltz, s 28 South Pitt Stre Carlisle, PA 17013 (717) 245-9688 ext 22 Attorney for Plaintiff II VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. ~JJ~!O} Datel J~;h.-sle~erl " CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint Fe Custody upon Denise A. Slenker, by depositing same in the United States Mail, fin class, postage pre-paid on the /7 fA day of /.:::.. J~2- ' 2005, from CarlislE Pennsylvania, addressed as follows: Denise A. Slenker 24 Pine Ridge Circle Enola, PA 17025 TURO LAW OFFICES c , alen R. 28 Sout Pitt treet Carlisle, PA 17013 (717) 245-9688; FAX 717.245.2165 Q-0~ \::.j "-- , ~~ C>(1 C> ~ :::: V - -~ (:::.~ - . '6? C' ~J (.J (~>, ,.,p\ " . PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASON Z. SLENKER V. 05-908 CIVIL ACTION LAW DENISE A. SLENKER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, Februal)'_2], 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqneline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, March 24. 2005 at 9:30 AM for a Pre-Hearing Custody Conference. At sllch conference, an effort will be made to resolve the isslles in dispute; or if this cannot be accomplished, to deline 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 conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties 10 furnish any and all existing Protection from Abuse orders, Special Relief orders. and Custody orders to the conciliator 48 hours prior to scbeduled hearing. FOR THE COURT. By: /s/ facqueline M. VemSbJisg. 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 arrangemcnts 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 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 (717) 249-3 166 ~ ~ $;w ~ ~ ~ 50-/i-e'.( ,~ ~ /'~ '0~ 50'/1C',/ ~{!l fiv~~-~,l;P9 YOAr.( \'1""'/1 LQ :r; "'J h't lf3::l9m ~\ MAR 2 B 2lJU5r- V. : IN THE COURT OF COMMON PLEA!S OF : CUMBERLAND COUNTY, P*NNSYLIv ANIA : NO. 2005-908 CIVIL TERM JASON Z. SLENKER, Plaintiff DENISE A. SLENKER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 30' day of ~~ ,2 05, upon consideration of the attached Custody Conciliation Report, it is ordered and direc ed as follows: I. The Father, Jason Z. Slenker and the Mother, Denise A, lenker, s all have shared legal custody of Chase R. Slenker, born August 10,2001. ach part shall have an equal right, to be exercised jointly with the other party, to mak all majo non- emergency decisions affecting the Child's general well-being including but not I mited to, all decisions regarding his health, education and religion. This me s that bot parents shall be entitled to all information from school and medical pro essionals 2. The parties shall have shared physical custody of the chi d on a w ek on/week off basis. The exchange day and time shall be Friday at 5:30 p.m. Fath r shall have the first week beginning March 25, 2005. 3. In the event that either party shall be in need of babysitti g servic s for more than two hours, they shall notifY the other party in a reasonable a ount of t me prior to the needed time and offer said time to the non-custodial parent. The tim that the child attends pre-school is excluded. 4. Holidays: A. Easter. Father shall have physical custody of the chi d on East r from 9:00 a.m. to 2:00 p.m. Mother shall have physical c stody of e child from 2:00 p.m. to 7:00 p,m. B. Mother's Day/Father's Day. Mother shall have phys cal custo yof the child on Mother's Day from 9:00 a.m. to 5:30 p. . Father shall have physical custody of the child on Father's Day fi m 9:00 .m. to 5:30 p,m. , Transportation shall be shared such that the receiving pa~y shall t sport. 5. ;",-" (~) ot> .(" v j --;.) "I h nC n;"" \l"r'i\'i'r':r'''J Ui:, (~t'i;i ~ljUt. )-bV..i{;i<C, itUdd 3Hl :lO :()l:::K}.(\::nU The parties shall have an appropriate car seat for the child 7. The parties shall have liberal telephone contact with th<r child. 8. This Order is entered pursuant to an agreement of the p~. ies at Custody Conciliation Conference. The parties may modifY the provisions ofth.s Order y mutual consent. In the absence of mutual consent, the terms of this Order sha I control. Another Conciliation Conference is scheduled for June 13,2005 at 8:30 a.m. BY THE COURT, ./14 J. cc:.2lllen R. Waltz, Esquire, Counsel for Father -:f:ifJ.e M. Alexander, Esquire, Counsel for Mother ~v'~ .~. ~M ~o .-----..) 03-31-05 T--- MAR 2 8 Z005 ~I'fi V. : IN THE COURT OF COMMON PLEk'\S OF : CUMBERLAND COUNTY, fENNSY,LV ANIA , I : I : 2005-932 CIVIL TERM I JASON Z. SLENKER, Plaintiff I>ENISE A. SLENKER, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None I \ \ I I I IN ACCORl>ANCE WITH CUMBERLAND COUNTY RU E OF dIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submit the folio .ng report: CUSTODY CONCILIATION SUMMARY REPO I. The pertinent information concerning the Child who is t e subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN USTOD OF Chase R. Slenker August 10, 2001 shared 2. A Conciliation Conference was held in this matter on Ma ch 24, 2 05, with the following individuals in attendance: Father, Jason Z. Slenker, ith his co nsel, Galen R. Waltz, Esquire and Mother, Denise A. Slenker, with her couns I, Jane Alexander, Esquire. 3. The parties agreed to the entry of an Order in the form as ttached. 3 -;J.'-!-C!,- Date 14.0- Q ac eline M. Verney, Esqu re r: Custody Conciliator 1\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA JASON Z. SLENKER, : NO. 2005-908 Civil Term Plaintiff VS. : Cf\ilL ACTION-LAW DENISE A. SLENKER, : IN CUSTODY Defendant AGREEMENT AND STIPULATION OF CUSTODY This Agreement and stipulation made this -l~ of by and between Jason Z. Slenker of24 Pine Ridge Circle, Enola, P sylvania (hereinafter referred to as "Father" and Denise A. Slenker of 42 QUeen Avenue, Enola, PA 17025, (hereinafter referred to as "Mother"), having reached an agreement to mutually settle and resolve the issues of custody of their minor child, Chase R. Slenker, age 3, born August 10, 2001, as herein after set forth in this agreement desi~ng to legally obligate themselves to the terms of said agreement: WHEREAS, Jason Z. Slenker is the natural father of said minor child; and WHEREAS, Denise A. Slenker is the natural mother of said minor child; and WHEREAS, there is a prior order of court in n:gard to this child entered March 30, 2005 by the Honorable Kevin A. Hess; and WHEREAS, under the terms of said order there was another conciliation conference scheduled for June 13,2005 and the parties, having reached an agreement and are desirous of avoiding further legal proceedings and are desirous of entering into a Custody stipulation for entry as a Court Order without the necessity of attending another Conciliation Conference. NOW THEREFORE, it is hereby agreed and stipulated by and between Jason Z. Slenker and Denise A. Slenker as follows: Page 1 ofl0 II LEGAL CUSTOI[)Y The parties shall share legal custody of their minor child, Chase R. Slenker, age 3, born August 10, 2001. Each parent shall participate in the major decisions concerning the moral, physical, emotional, medical, educational and re:ligious aspects of the child's upbringing. These decisions shall not be made by eithl:r parent unilaterally. The parents agree that all major decisions shall be made by them jointly, after discussion and consultation with each other, with a view towards obtaining and following a harmonious policy in the child's best interest. Each parent agrees to keep the other parent informed of the progress of the child's education and social adjustments. Each parent agrees not to impair the other parent's right to share legal custody of the child. Each parent agrees to give support to one another in their role as parents and to take into account the consensus of the other for the physical and emotional well-being of the child. The parents agree not to attempt to or to alienate the affections of the child for the other parent. Each parent shall notifY the other of any activity that could reasonably be expected to be of significant concern to the other parent. The child will not be barred from contacting the non-custodial parent by telephone. Either parent may, during that parent's physical custody of the child, make decisions required by an emergency or sudden illness. Each parent shall irmnediately communicate to the other the existence of any medical, legal or educational emergency that may occur with respect to the child. Each parent shall also have the duty to immediately contact the other regarding the illness. For purposes of this Order, the word "illness" shall mean any disability that confines the child to bed under the direction of a lieensed physician for a period in excess of twenty-four (24) hours or any serious injury to the child that would require emergency room or other irmnediate treatment of which requires hospitalization. Each parent shall have equal right and access to visit the child if the child is confmed to a medical institution, consistent with medical advice. If the child is confined to home by reason of illness for a period of more than twenty-four (24) hours, the other parent shall have the opportunity to visit the child. Educational and legal emergencies shall include those situations where there is an . imminent threat to the child's well-being or any change of the current school or institution. Each parent shall, as soon as practicable, make full disclosure to the other of the facts and Page 2 oflO II circumstances pertinent to the child's upbringing and welfare of which that parent was knowledge or notice. Each shall provide the other with copies or duplicate originals of records pertaining to the child, including but not limited to: a. Medical Diagnosis and Treatment; b. Psychological/Psychiatric Diagnosis and Treatment; c. Dental and Orthodontic Records; d. School Records including Schedules of Events; e. Legal Records Each parent shall have the right to obtain such records directly from the school, health care providers or other entity keeping such records without the permission of the other and without further Order of this Court. JOINT PHYSICAL CUSTODY The parties shall have joint physical custody of the child with each having custody as set forth in the following schedule: SCHEDULEFORPART~LCUSTODY 1. Weekly schedule: The parties shall have shared physical custody of the child on a week on/week off basis. The exchange day and time shall be Friday at 4:00 P.M. The parent receiving custody shall pick up the child at home of parent having custody unless otherwise mutually agreed upon. In the event that either parent shall be in need of babysitting services for more than four (4) hours they shall notify the other pare:nt in a reasonable amount of time and offer the time to the non-custodial parent. Should the other parent be unable to provide babysitting they should be provided with the information as to the whereabouts of the child and information as to how the child can be contacted. Whenever a babysitter is used they shall be provided with information as to how and when both parents can be reached. Page 3 of 10 II 2. Holidavs and other soecial days: The parties shall have rights of partiial custody on holidays and other special days as follows: The parties shall have rights of partiial custody on the following holidays in an alternating schedule: Memorial Day, Independence Day, and Labor Day. Mother shall have custody on Memorial Day 2005 and Father shall have Independence Day 2005 and they will continue to alternate thereafter. 3. Mother's Dav and Father's Dav: Mother shall always have the right to custody on Mother's Day. The right of custody shall be exercised by Mother for the Mother's Day holiday beginning at 6:30 p.m. Saturday to Sunday at 7:00 p.m. Father shall always have the right of custody on Father's Day. The right of custody shall be exercised by Father for the Father's Day holiday beginning at 6:30 p.m. Saturday to Sunday at 7:00 p.m. 4. Easter Vacation: Mother shall always have custody for Easter Sunday beginning on Saturday at 6:30 p.m. to Sunday at 7:00 p.m. 5. Thanksgiving Dav: Father shall always have custody for Thanksgiving beginning at 6:30 p.m. Wednesday to 7:00 p.m. on Thanksgiving Day. 6. Halloween: Parties shall alternate this holiday with whichever parent has custody this year shall have the child and every odd numbered year thereafter but custodial parent shall bring child to other parent's home for a short trick or tr,eat. In 2006 the other parent shall have the holiday and every even numbered year thereafter. If Halloween falls in the week it is the non custodial parent's year to have the child the non custodial parent shall pick up the child from school and return to custodial parent's home: by 9:00 P.M. 7. Birthdavs: Page 4 of 10 II On child's birthday the non-custodial parent shall have a two (2) hours visit. On either of the parent's birthdays if the child is not in their custody the non custodial parent shall have a two hour visit with the child. 8. Christmas Holidav: Mother shall have custody of the cl1~ld from noon on December 24th until 12:00 P.M. on Christmas Day. Father shall have custody of the child from 12:00 P.M. on Christmas Day until 12:00 P.M. on December 26th. 9. New Years: Whoever has custody on December 31, 2005 shall have custody New Year's Eve. The parent who does not have custody that week shall have the child New Year's Day from 9:00 A.M. to 7:00 P.M. 10. Holidav Priority: The periods of partial custody for holidays, vacations, or other special days set forth in this order shall be in addition to, and shallltake precedence over, but shall not alter the schedule or sequence of regular periods of partial (:ustody for that parent set forth previously in this order. 11. Summer Vacation: Summer vacation is defined by the Court as the first Friday evening following the last day of School and if Friday is the last day of school that evening is the beginning of the summer vacation which continues to the Friday evening which concludes the last full week preceding the first day of school. During the summer months each pllJrty shall have one (1) week of vacation. If taken during a scheduled week the other parent is to be notified at least two (2) weeks prior to the week to be taken and to provide the information of where and contact phone number. If to be taken by parent in other's scheduled week advanee notice of thirty (30) days must be given and custody information. Page 5 of 10 II TRANSPORTATION The transportation shall be provided at all time by both parties as the circumstances indicate. At all times, the child shall be secured in an appropriate passenger restraint. No person transporting the child shall consume alcoholic beverages prior to or while transporting the children. No person transporting the child shall be under the influence of any alcoholic beverage or controlled substance while transporting thle child. LATE EXCHANGE In the event any party is more than 20 minutes late for scheduled custody exchange, in the absence of a telephone call or other communication from the party, the other party may assume that the parent who is late has chosen not to exercise that period of custody, the period will be forfeited, and the other party will be free to make other plans with the child. EXTRACURRICULAR ACTMTIES Each party shall provide to the other at least forty-eight (48) hours advance notice of school or other activities, whenever possible. Both parties shall agree to honor and participate in the activities that the child wishes to engage in. During the times that the parents have custody of the child, they will make certain that the child attends any extracurricular activities. The parties agree that they will be supportiv,e of the activities and will transport the child to and from such activities and the preparations and practice for the activities that are scheduled, in such time so that the child is able to partidpate in those events. Neither parent, however, shall sign up the child for any activity unless the child definitely desires to attend that activity. Participation in activities which take place during the school year is contingent upon the child maintaining passing grades in school. Neither parent shall sign up the child for activities that fall on the other parent's period of custody, without the consent of the other parent, which consent shall not be unreasonably withheld. If the child is involved in an activity which occurs during both parents' periods of custody, both parents shall cooperate in providing transportation of the child to the activity. However, the custodial parent shall not be required to take the child to that activity if the Page 6 of 10 II custodial parent and child are out of town during that activity, for a previously scheduled vacation. In the event that the custodial parent is unable to deliver the child to the particular activity, the parent who has custody of the child at that time shall notifY the non-custodial parent, who shall be entitled to pick up and deliver the child to the designated activity. The custodial parent shall make certain that the child is ready for pickup in time sufficient to enable the child to timely attend the activity. TELEPHONE CALLS Both parties are urged to use common sense in scheduling telephone calls to talk to the child. Both parties are hereby directed to refrain from preventing the parent who may be calling from talking to the child, or preventing the child from calling the other parent, provided that the phone calls are not excessively frequent, nor too long in duration that they disrupt the child's schedule. Phone calls should be kept to a maximum of twenty (20) minutes. DISPARAGING REMARKS Each of the parties and any third party in the p"esence of the child shall take all measures deemed advisable to foster a feeling of affection between the child and the other party. Neither party shall do nor shall either parent permit any third person to do or say anything which may estrange the child from the other parent, their spouse or relative, or injure the child's opinion of the other party or which may harnper the free and natural development of the child's love and respect for the other parent. The parties shall not use the child to convey verbal messages to the other parent about the custody situation or changes in the custody schedule. FINANCIAL CARE OF' CHILD In the event that a significant matter arises with respect to the medical care, education, or financial care of a child, such as a change in occupation, health insurance, educational Page 7 of 10 II expenses, or residence of a party, those matters shall be discussed with the other parent before any change is made by either parent. MUTUAL CONSULTATION Each party shall confer with the other on all matters of importance relating to the child's health, maintenance, and education with a view towards obtaining and following a harmonious policy in the child's education and sociallldjustments. Each party agrees to keep the other informed of his or her residence and telephone number to facilitate communication concerning the welfare of the child and visitation. Eac:h party agrees to supply the name, address and phone numbers of any persons in whose care the child will be for a period in excess of seventy-two hours (72), and for each person or entity which may provide day care for the child. ILLNESS OF CIDLDREN Emergency decisions regarding the child shalllbe made by the parent then having custody. However, in the event of any emergency or s,erious illness of the child at any time, any party then having custody of the child shall immed~ately communicate with the other party by telephone or any other means practical, infonning the other party of the nature of the illness or emergency, so the other parent can become involved in the decision making process as soon as practical. During such illness, each party shall have the right to visit the child as often as he or she desires, consistent with the proper medical care ohhe child. The term 'serious illness' as used herein shall mean any disability which confines a child to bed in for a period in excess of twenty-four (24-) hours and which places the child under the direction of a licensed physician. WELFARE OF CHILD TO BE CONSIDERED The welfare and convenience of the child shall he the prime consideration of the parties in any application of the provisions of this Order. Both parents are directed to listen Page 80f10 II carefully and consider the wishes of the child in addressing the custodial schedule, any changes to the schedule, and any other parenting issues. SMOKEIDRINK Neither party shall smoke in confined area whl:n the child is present and neither party shall permit another person to smoke in a confined area when the child is present. Further, neither party shall use non-prescribed controlled substllllces or excessively use alcohol while the child is in their custody and control. REMOVAL FROM AREA Neither parent shall transport the child to a point more than 150 miles from home of the other parent for any reason without notification to 1he other parent. Party removing child shall provide to the other parent an address and/or phone number where the child can be reached. MOVING OF RESmENCE Neither party shall move their place of residence without giving the other party at least thirty (30) days written notice of the new residence. If the new residence is more than 100 miles from the current residence appropriate adjustments in custody, visitation schedules should be made prior to the move. MODIFICATION OF ORDER The parties are free to modifY the terms of this Order but in order to do so the Court makes it clear that both parties must be in complete agr,eement to any new terms. That means both parties must consent on what the new terms of the custody arrangement or visitation schedule shall be. The parties further stipulate and agree that this agreement and stipulation of Custody shall be presented to the court of Common Pleas of Cumberland County, Commonwealth of Page 9 of 10 II Penosylvania with the understanding and request that the Court approve this agreement and stipulation and enter the same as an Order of Court. IN WITNESS WHEREOF, the parties hereto have hereunto set their hands and seals the day and year first 0\1wt4~ ~e A. Sle er, Defendant COMMONWEALTH OF PENNSYLVANIA Galen R. Waltz, Esquir Attorney for Plainti : SS COUNTY OF CUMBERLAND On this ~ fs1 day of 3 , 2005, before me, the undersigned officer, a Notary Publi , onally appeared Jason Z. Slenker known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. r . ~~4 I~, Public "011II"'''' .-:AA. NO< - I IIl4 tlIIDY NIlIC Ql)J'-~1(JIC ~ CUllln~ PIlIfC I....... Ole 21. My Commission COMMONWEALTH OF PENNSYL VANIA : SS COUNTY OF YORK : On this /.3yJ day of (1,( I-A ,2005, before me, the undersigned officer, a Notary Public, pe~ppeared Demse A. Slenker known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose My Commission Expires: Notarial Leslie K. NeIdig, Notary Public Wan1nglon T"1l. YOlk County M'fc.....- expr..Feb. 4, 2OoT! _. Nlllllfn t:~ Rt (-":' t;j~ ::1 ~.::: j-;i l"-,J \.;:::: -:..\ c:.? 0' _.llIl7~ l<....~~" ~...".-,.. I:) -"'" --. .- WIUO~)" ......A · toOS .Ss :lIIO 1'1 Jason Z. Slenker, Plaintiff v. Denise A. Slenker, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-908 CIVIL TERM : CIVIL ACTION - CUSTODY PRAECIPE TO TRANSMIT CUSTODY ORl>ER AND AGREEMENT AND STIPULATION OF CUSTODY TO THE PROTHONOTARY: AND NOW this, 29th day of July, 2005, the Plaintiff submits a mutually agreed upon Agreement and Stipulation of Custody and request that this Honorable Court enter an Order granting the acceptance thereof. 7/<t/or Date Galen R. Waltz, Esquire 28 South Pitt Street Carlisle, P A 17013 (717) 245-9688 Attorney for Plaintiff 0 ...., ~ ,~ ~:. c:.~ <.n -.... .. ~ -;'I .- H1 r -'J r-;-: r--.) .~ -'-", ~" \i,) , C,l . -,-, <"'.-., :i:: -:~~ C':; o. rn C') -..:~\ 0- ':> -J ~ -, O~ - II "\ RECEIVED AUG 01 05 Jason Z. Slenker, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 05-908 CIVIL TERM Denise A. Slenker, Defendant : CIVIL ACTION - CUSTODY Order of Court AND NOW, this '4 lei day of August, 2005 the Agreement an Stipulation of Custody dated July 13,2005 and signed by both parties is entered and effective the date of this Order. Modification of the Agreement and Stipulation of Custody can be obtained pursuant to the applicable law at the time of filing. FOR THE COURT J J. c.~en R. Waltz, Esquire ~ne M. Alexander, Esquire " . ",'.'YJ " ,,~~ Q S .~ I ~H "'"lG- (l,n~~J CO. n~? .. . iJ : ',I ,~; 1 ~ ..i vlJ JASON Z. SLENKER, Plaintiff R.r::Ct-,',':-n c~c ^ C '0"" .... . .~.J "~, v 'U~r : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-908 CIVIL TERM DENISE A. SLENKER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 6th day of September, 2005, as the parties have not contacted the Conciliator to request a Conciliation Conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, Conciliator (") c~ \ I' ,..., = ~ (/) fj I en ~ ..... :I:-T' rnc -..OI,J-j .:'-r '-?l<;:?: r~I~7, ',~ ~~ - ~ -- 0'