HomeMy WebLinkAbout02-3403 nm AMY E. ADAMS, • IN THE COURT OF COMMON PLEAS
Plaintiff • CUMBERLAND COUNTY, PENNSYLVANIA
V. • CIVIL ACTION — LAW N•
O. 2681-3403 CIVIL ACTION/ �-- Tip
PAUL L. ADAMS, : Do z r - -c r
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Defendant • INd.).- r-cf) t.C. o
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PETITION FOR MODIFICATION OF CUSTODY =c
NOW COMES PAUL L. ADAMS, by and through his counsel, Marylou Matas,
Esquire, Saidis, Sullivan & Rogers, and petitions this Honorable Court as follows:
1. Petitioner (hereinafter referred to as "Father") is Paul L. Adams, who resides
at 2251 Pine Road, Newville, Cumberland County, Pennsylvania, 17241.
2. Respondent (hereinafter referred to as "Mother") is Amy Adams, nka Emlet,
whose last known address is 341 Old Slate Road, Gardners, Cumberland County,
Pennsylvania.
3. The parties are the parents of one child, Nicholas E. Adams, born
September 1, 2000, age 13.
4. On December 20, 2004, the parties executed an Agreement regarding
custody of the child, a copy of which is attached hereto as Exhibit "A".
5. The parties incorporated their custody Stipulation and Agreement into their
final Marital Settlement Agreement, dated December 30, 2004, with the intention of the
Stipulation being signed as a separate custody Order, but the custody Order was not
Law Offices of
Saidis presented separately to the Court and therefore not signed as a final Order.
Sullivan 5. Pursuant to the terms of the Agreement, the parents exercise shared legal
& Rogers
26 West High Street custody; the child resides primarily with Mother; Father is to exercise periods of custody on
Carlisle,PA 17013
alternating weekends from Saturday through Monday and two days during the week.
6. Since the execution of the Agreement, Father's work schedule has changed.
Cidt 1
7. Father's current work schedule permits him to exercise custody of the child
during the week.
8. Currently, the parties exchange custody so that Mother exercises primary
physical custody and Father exercises custody on alternating weekends from Friday
evening at 7pm through Sunday evening at 7pm.
9. Father desires to exercise parenting responsibilities for the child during the
week, during the school year and during the summer.
10. Mother does not permit weekday custodial exchanges.
11. Father believes it is in the child's best interest for him to spend more
significant periods of time with his father, including weekday periods, days off from school,
holidays and vacations.
12. Father is equally capable of caring the child at all critical times as he needs.
13. Father is interested in being involved in the child's medical care, religious
upbringing and education; he believes that greater involvement can be had if he spends
more periods of time with the child as well.
14. Mother has not been as willing to involve Father in the child's medical care
and educational needs, nor does she share important information regarding these matters.
Father believes that increased his increased involvement will permit him to receive the
information directly from care providers.
15. Father believes the child would like to spend more time with Father, as well.
Law Offices of
Saidis 16. Judge Oler signed the parties' prior custody Order, dated 2002.
Sullivan 17. No party in either parent's household is convicted of any offense enumerated
& Rogers
26 West High Street in 23 Pa. §5329.
Carlisle,PA 17013
WHEREFORE, Father requests your Honorable Court to modify the Custody
Agreement to provide for shared physical custody for the parents.
Respectfully submitted,
SAIDIS, SULLIVAN & ROGERS
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lGCt. i G ��2. . J
Ma ou A tas, Esqui
Attorney Id. 84919
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Petitioner/Defendant
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle,PA 17013
AMY E. ADAMS, • IN THE COURT OF COMMON PLEAS
Plaintiff • CUMBERLAND COUNTY, PENNSYLVANIA
•
v. : CIVIL ACTION— LAW
NO. 2U01-3403 CIVIL ACTION LAW
PAUL L. ADAMS, :
Defendant • IN CUSTODY
VERIFICATION
I understand that false statements herein are made subject to the penalties of 18
Pa. C. S. Section 4904, relating to unsworn falsification to authorities.
Date:
Paul L. Adams
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle,PA 17013
AMY E. ADAMS, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : CIVIL ACTION — LAW
•
NO. 2661-3403 CIVIL ACTION LAW
PAUL L. ADAMS, : .2.,f)J
Defendant : IN CUSTODY
CERTIFICATE OF SERVICE
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I hereby certify that on this 1 day of J i,._k;c_t , 2014, a true and correct
copy of the foregoing document was served upon the party listed below, via First Class
Mail, postage prepaid, addressed as follows:
Amy E. Adams, nka Emlet
341 Old State Road
Gardners, PA 17324
SAIDIS, SULLIVAN & ROGERS
- Th, C{A.1, .b.t,(1 L ?Cf tie'' ,J
Mary MOt , Esquire
Supreme Court ID No. 84919
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Petitioner/Defendant
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle,PA 17013
Barbara Sumple-Sullivan,Esquire
Supreme Court#32317
549 Bridge Street
New Cumberland,PA 17070
(717)774-1445
AMY E.ADAMS, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
v. : NO: 2002-3403
PAUL L.ADAMS, , : CIVIL ACTION-LAW
Defendant : CUSTODY
STIPULATION REGARDING CUSTODY
•
THIS AGREEMENT is made this day ofjetiVa/c-2-004,by and between
Amy E. Adams, (hereinafter referred to as "Mother") an adult individual residing at 5
Northview Drive, Carlisle, Cumberland County,Pennsylvania 17013, and Paul L.Adams,
(hereinafter referred to as"Father")an adult individual residing at 2251 Pine Road,Newville,
Cumberland County,Pennsylvania 17241.
WITNESSETH
WHEREAS, Mother and Father are the natural parents of one (1) minor child,
Nicholas E.Adams,born September 1,2000.
WHEREAS,a custody action was filled on July 18,2002 and following a conciliation,
an order was entered on September 9,2002 awarding Mother primary physical custody and
Father periods of partial physical custody;
1
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•
WHEREAS,the parties have mutually agreed upon the modification of this agreement
and desire to incorporate same into a revised order of court.
NOW THEREFORE,the parties intending to be legally bound, do agree as follows:
A. Legal Custody: It is in the best interest of the minor child for the continuation of
shared legal custody of the minor child. The parties agree that major decisions
concerning the child's health,welfare, education, religious training and upbringing
shall be made by the parents jointly, after discussion andconsultation with each
other,with a view towards obtaining and following a harmonious policy to arrive at a
decision that is in the child's best interest Each party agrees to keep the other
• informed of the progress of the child's education and social adjustments. Each party
agrees not to impair the other parties' right to share legal custody of the child.
Further,each party agrees to give support to one another in the role as parents and to
take into account the consensus of the other parent for the physical and emotional
well being of the child. The parties agree not to either attempt or alienate the
affections of the child for the other parent Each party shall notify the other of any
activity that could reasonably be expected to be of significant concern to the other.
The parties agree that the child will be encouraged to contact the other parent by
telephone and e-mail at all reasonable times.
B. Physical Custody:
1. Mother shall enjoy primary physical custody of the parties' minor child;and
2. Father shall enjoy periods of partial physical custody as follows:
a. On alternating weekends beginning on Saturday morning at 9:50 a.m.
until Monday at 2:50 p.m.;
b. On Tuesday and Thursday from 9:50 a.m.until 2:50 p.m.; and
c. Such other times as the parties shall mutually agree upon. •
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C. Holidays: The parties shall follow the custody schedule for the holidays as
set forth in the September 9, 2002 Order in paragraphs 4-8.
D. Ratification of Terms: All other terms of the Order dated September 9,2002
as contained in paragraphs 9-10 are hereby ratified and confirmed.
IN WITNESS WHEREOF,the parties hereto acknowledge that they are entering in to
this Agreement with the full knowledge that this Agreement shall be entered as a court order
with the same force and effect as if a full hearing on this matter has been held,
SIGNED, SEALED AND DELIVERED
IN Tm:p'4 30.E 01E.OF:
WITNE •
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Barbara Sumple-Sullivan,Esquire Amy E.Adams
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Carol J.Lind **(quire Paul L.Adams
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SEP 0 5 2002
AMY E.
ADAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. • :NO.2002-3403 CIVIL TERM
PAUL L.ADAMS, : CIVIL ACTION-LAW
Defendant
:IN CUSTODY
ORDER OF COURT
•
AND NOW,this 91Y, day of S e p1 e T ,2002,upon
consideration of the attached Custody Conciliatibn Report, it is ordered and directed as
follows:
1. The Mother,Amy E. Adams,and the Father,Paul L. Adams,shall have
shared legal custody of Nicholas E. Adams,born September 1,2000. Each parent shall
have an equal right,to be exercised jointly with the other parent,to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding his health,education and religion.
2. Mother shall have primary physical custody of the Child.
3. Father shall have periods of partial physical custody as follows:
A. Beginning September 5,2002,every Monday,Tuesday and Thursday
from 9:00 a.m. to 2:00 p.m.and continuing on said schedule until
October 17,2002.
B. Beginning September 22,2002,alternating weekends, Sundays after
church to Mondays at 2:00 p.m.
C. Beginning October 19,2002, alternating weekends, Saturdays at 9:00
a.m.to Mondays at 2:00 p.m.and continuing thereafter on said
alternating schedule.
D. Beginning the week of October 20,2002,every Tuesday and Thursday
from 9:00 a.m.to 2:00 p.m.
E. Father also has the option of 9 additional weekends during a one year
period beginning October 19,2002 from Saturday at 9:00 a.m.to
Monday at 2:00 p.m.provided he gives Mother two weeks prior notice
of exercising said times,
4. Christmas shall be divided into two Blocks. Block A shall be from •
Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from
Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have physical
custody of the Child for Block A in even numbered years and Block B in odd numbered
.........._ _ ..,...____ ______......_____ ......., ___.
, . .
years. Father shall have physical custody of the Child for Block A in odd numbered
years and Block B in even numbered years.
5. Mother shall have physical custody of the Child on Mother's Day from
9:00 a.m.to 5:00 p.m.Father shall have physical custody of the Child on Father's Day
from 9:00 a.m.to 5:00 p.m.
6. The Thanksgiving holiday shall be split such that Father shall always have
physical custody of the Child from 9:00 a.m.to 3:00 p.m. Mother shall always have
physical custody of the Child from 3:00 p.m.to 9:00 p.m.
7. The Easter holiday shall be split such that Mother shall always have
physical custody of the Child from 9:00 a.m.to 3;00 p.m. Father shall always have
physical custody of the Child from 3:00 p.m.to 9:00 p.m.
8. The parties shall alternate the following holidays from 9:00 a.m.to 5:00
p.m.:Memorial Day,July 4th and Labor Day,with Father having Memorial Day in 2003.
9. Each party shall be entitled to two (2)non-consecutive weeks every year
with the Child provided they give the other party 30 days prior notice. When Father
exercises his vacation periods,he will attempt to have his weeks coincide with his regular
alternating weekend schedule.
10. During Father's periods of custody he will insure that the Child is properly
fed,diapered,and supervised. Father agrees to keep the Child's environment a
comfortable temperature for the Child.
11. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent,the terms of this Order shall control.
•
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BY THE COURT
J.
cyRebecca R.Hughes,Esquire,Counsel for Mother
/*Carol J.Lindsay,Esquire,Counsel for Father
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AMY E.ADAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. :2002-3403 CIVIL TERM
PAUL L.ADAMS, : CIVIL ACTION-LAW
Defendant
:IN CUSTODY
PRIOR JUDGE: None
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8,the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Nichols E.Adams September 1,2000 Mother
2. A Conciliation Conference was held in this matter on September 4,2002,
with the following individuals in attendance:The Mother,Amy E.Adams,with her
counsel,Rebecca R.Hughes,Esquire and Father,Paul L.Adams,with his counsel,Carol
J. Lindsay,Esquire.
3. The parties agreed to the entry of an Order in the form as attached.
•
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Date JaccAe1ineVerney,Esquire
Custody Conciliator
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MYLVANA
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•
AMY E. ADAMS, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
•
v. : CIVIL ACTION — LAW
•
NO. 29941-3403 CIVIL ACTION LAW c
PAUL L. ADAMS, : -03 rn
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Defendant : IN CUSTODY rni-
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u•Jo
us•CRIMINAL RECORD/ABUSE HISTORY VERIFICATION <c 3
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I, Paul L. Adams, hereby swear or affirm, subject to penalties of law gudi 17&4"'
Pa.C.S.§ 4904 relating to unsworn falsification to authorities that: rso
1. Unless indicated by my checking the box next to a crime below, neither I nor any other
member of my household have been convicted or pled guilty or pled no contest or was
adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act 42
Pa.C.S. § 6307 to an of the following crimes in Pennsylvania or a substantially equivalent crime
in any other jurisdiction, including pending charges:
Check Crime Self Other Date of Sentence
all that household conviction,
apply member guilty plea, no
contest plea or
pending charges
❑ 18 Pa.C.S. Ch.25 ❑ ❑
(relating to criminal
homicide)
❑ 18 Pa.C.S. §2702 ❑ ❑
(relating to aggravated
assault)
❑ 18 Pa.C.S. §2706 ❑ ❑
(relating to terroristic
threats)
❑ 18 Pa.C.S. §2709.1 ❑ ❑
(relating to stalking)
❑ 18 Pa.C.S. §2901 ❑ ❑
(relating to kidnapping)
❑ 18 Pa.C.S. §2902 ❑ ❑
(relating to unlawful
restraint)
❑ 18 Pa.C.S. §2903 ❑ ❑
(relating to false
imprisonment)
❑ 18 Pa.C.S. §2910 ❑ ❑
(relating to luring a
child into a motor
vehicle or structure)
❑ 18 Pa.C.S. §3121 ❑ ❑
(relating to rape)
❑ 18 Pa.C.S. §3122.1 ❑ ❑
(relating to statutory
sexual assault)
❑ 18 Pa.C.S. §3123 ❑ ❑
(relating to involuntary
deviate sexual
intercourse)
❑ 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)
❑ 18 Pa.C.S. §3127 ❑ ❑
(relating to indecent
exposure)
❑ 18 Pa.C.S. §3129 ❑ ❑
(relating to sexual
intercourse with animals)
❑ 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)
❑ 18 Pa.C.S. §4303 ❑ ❑
(relating to concealing
death of child)
❑ 18 Pa.C.S. §4304 ❑ ❑
(relating to endangering
welfare of children)
❑ 18 Pa.C.S. §4305 ❑ ❑
(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)
❑ 18 Pa.C.S. §6301 ❑ ❑
(relating to corruption
of minors)
❑ 18 Pa.C.S. §6312 ❑ ❑
(relating to sexual
abuse of children)
❑ 18 Pa.C.S. §6318 ❑ ❑
(relating to unlawful
contact with minor)
❑ 18 Pa.C.S. §6320 ❑ ❑
(relating to sexual
exploitation of children)
❑ 23 Pa.C.S. §6114 ❑ ❑
(relating to contempt for
violation of Protection
order or agreement)
❑ Driving under the ❑ ❑
influence of drugs
or alcohol
❑ Manufacture, sale, ❑ ❑
delivery, holding,
offering for sale or
possession of any
controlled substance or
other drug or device
2. Unless indicated by my checking the box next to an item below, neither I nor any other
member of my household have history of violent or abusive conduct including the following:
Check Self Other Date
all that household
apply member
❑ A finding of abuse by 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
❑ Involvement with a Children &Youth ❑ ❑
Agency or similar agency in Pennsylvania
or another jurisdiction.
Where?
❑ Other: ❑ ❑
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 members of the party's household has or have a
criminal/abuse history, please explain:
I verify that the information above is true and correct tot eh best of my knowledge
information or 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.
r;
Date: i%`d/l
Signature, Paul L. Adams
L,
Printed Name, Paul L. Adams
AMY ADAMS
PLAINTIFF
V.
PAUL L. ADAMS
DEFENDANT
• ▪ IN THE COURT OF COMMON PLEAS OF
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CUMBERLAND COUNTY, PENNSYLVANIA
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2002-3403 CIVIL ACTION LAW zfri
IN CUSTODY r�-z
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ORDER OF COURT
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AND NOW, Thursday, July 31, 2014 , upon consideration of the attached Complaint, it is
hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, August 27, 2014 8:30 AM
for a Pre -Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this
cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure
to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief
orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
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/ Jacqueline M. Verney, Esgl
Custody Conciliator tt''
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.
c3 Icod LCumberland County Bar Association QPI es 32 South Bedford Street
O Ai'a-$ Carlisle, Pennsylvania 17013
7� Telephone (717) 249-3166
o ,4dams,
Veil°j, 6-1 iti
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Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
AMY E. ADAMS, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. CIVIL ACTION — LAW
NO. 20 3403 CIVIL ACTION LAW
PAUL L. ADAMS,
Defendant IN CUSTODY
AFFIDAVIT OF SERVICE
I, Marylou Matas, Esquire, being duly sworn according to law, hereby
deposes and says that on August 11, 2014, she served a true and correct
copy of the conciliation rescheduling notice upon Amy (Adams) Emlet, by
mailing those documents to the her address at 341 Old State Road,
Gardners, PA 17324 by Certified U.S. Mail, Restricted Delivery, Return
Receipt Requested, as evidenced by the attached U.S. Postal Service Form
3811, Domestic Return Receipt, the latter of which is signed by the recipient,
Amy Emlet.
Dated: $ 13 //y
Respectfully submitted,
SAIDIS, SULLIVAN & ROGERS
a/A 717da //7
Marylou Matas, Esquire
ID No. 84919
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Defendant
SENDER: COMPLETE THIS SECTION
• Complete items 1. 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
• Print your name and address on the reverse
so that we can return the card to you.
• Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
gdafit reta gad
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fddS/C(7 dad
6aatisi fI /z501:'
COMPLETE THIS SECTION ON DELIVERY
A. S';ur,ure
X
❑ Agent
Addressee
C. Date of Delivery
D. Is delivery address different from item 1? 0 Yes
If YES, enter delivery address below: 0 No
3. fSerice Type
ggiCertlfied Mall® 0 Priority Mall Express"'
0 Registered Wetum Receipt for Merchandise
.0 Insured Mall 0 Collect on Delivery
4. Restricted Delivery? (Extra Fee)
Ages
2. Article Number
(Transfer from service label)
7014;0510M 0002;:3751 8105th
PS Form 3811. July 2013
Domestic Return Receipt
AMY E. ADAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2002-3403 CIVIL TERM
•
PAUL L. ADAMS, : CIVIL ACTION - LAW rn
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Defendant (n I—
: IN CUSTODY -<>
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ORDER OF COURT =c)
AND NOW, this 114‘ day of 45iftlenitit. , 2014, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
C")
I. The prior Order of Court dated September 9, 2002 is hereby vacated.
2. The Mother, Amy E. Adams, and the Father, Paul L. Adams, shall have
shared legal custody of Nicholas E. Adams, born September 1, 2000. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding their health, education and religion. Pursuant to the terms of
23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining
to the children including, but not limited to medical, dental, religious or school records,
the residence address of the child and the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent. Both parents shall be
entitled to full participation in all educational and medical/treatment planning meetings
and evaluations with regard to the minor child. Each parent shall be entitled to full and
complete information from any physician, dentist, teacher or authority and copies of any
reports given to them as parents including, but not limited to: medical records, birth
certificates, school or educational attendance records or report cards. Additionally, each
parent shall be entitled to receive copies of any notices which come from school with
regard to school pictures, extracurricular activities, children's parties, musical
presentations, back -to -school nights, and the like.
Mother shall have primary physical custody of the Child.
4. Father shall have periods of partial physical custody as follows:
A. Alternating weekends from Friday at 4:00 p.m. to Sunday at 8:00 p.m.
In the event that Father's weekend coincides with a Monday school
holiday, then Father shall return the child on Monday at 8:00 p.m. In
the summer the return time on Sundays is 9:00 p.m. When a Monday
holiday does not coincide with Father's weekend, Father shall have
physical custody from Sunday at 4:00 p.m. to Monday at 8:00 p.m.
B. During all other school breaks, such as, but not limited to,
Thanksgiving, Christmas, Easter, Father shall have physical custody
either overnight or from 4:00 p.m. to 8:00 p.m. at Father's discretion,
provided he give Mother 14 days prior notice.
C. During the summer, Father shall have physical custody every
Wednesday from 4:00 p.m. to 8:00 p.m.
5. Mother shall email Father a contact list of all professionals treating the
child by September 12, 2014.
6. Both parties shall meet with the child's Behavioral specialist, Diane
Dayton, as soon as possible to discuss additional contact between Father and child.
7. Transportation shall be shared such that the relinquishing party shall
transport.
8. Both parties shall insure that the child is transported to all of his
appointments.
9. Holiday/vacations take precedence over the regular custody schedule.
A. Thanksgiving and Easter shall be alternated with times as agreed by
the parties. Mother shall have Thanksgiving and Easter in odd numbered
years and Father shall have Thanksgiving and Easter in even numbered
years.
B. Christmas shall be divided into two Blocks. Block A shall be from
Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B
shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon.
Mother shall have physical custody of the Child for Block A in even
numbered years and Block B in odd numbered years. Father shall have
physical custody of the Child for Block A in odd numbered years and
Block B in even numbered years.
C. Mother shall have physical custody of the Child on Mother's Day from
9:00 a.m. to 5:00 p.m. Father shall have physical custody of the Child on
Father's Day from 9:00 a.m. to 5:00 p.m.
D. The parties shall alternate the following holidays from 9:00 a.m. to
5:00 p.m.: Memorial Day, July 4th and Labor Day.
E. Each party shall be entitled to three (3) non-consecutive weeks every
year with the Child provided they give the other party 14 days prior notice.
Said weeks shall coincide with their regular alternating weekend schedule.
10. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
J.
1
cc: Y lou Matas, Esquire, uire Counsel for Father
-/Michael A. Scherer, Esquire, Counsel for Mother tier filaVitCA-
AMY E. ADAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : 2002-3403 CIVIL TERM
PAUL L. ADAMS,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: J. Wesley Oler, Jr., J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Nichols E. Adams September 1, 2000 Mother
2. A Conciliation Conference was held in this matter on September 3, 2014,
with the following individuals in attendance: The Father, Paul L. Adams, with his
counsel, Marylou Matas, Esquire and Mother, Amy E. Adams, with her counsel, Michael
A. Scherer, Esquire.
3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court.
dated September 9, 2002 providing for shared legal custody, Mother having primary. -
physical custody and Father having periods of partial physical custody on alternating_
weekends.
4. The parties agreed to the entry of an Order in the form as attached.
Date
acqne M. Verney, Esquire
Custody Conciliator