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Home My WebLink About05-2124 ," .. RECEIVED AUG 0 9 Z~5 DONNA CODER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-2124 CIVIL TERM DANIEL CODER, Defendant CIVIL ACTION - LAW CUSTODY ORDER AND NOW, thisl D ~ day of ~ 2005, upon presentation and consideration of the attached Custody Stipulation, it is hereby Ordered and Decreed that said Stipulation as submitted and executed by the parties shall b,: incorporated herein and made part hereof. IfINlftll,J.SNN:Jd A.1.Nf'iW n~:;n~;3m~n8 E: 2 : II \.IV 0 I anv SOOl AtlV10NOH1OOd 3Hl :10 3::l1:L-lQ-G3l1:l -" ,w,.>"" ..> DONNA CODER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-2124 CIVIL TERM DANIEL CODER, Defendant CIVIL ACTION- LAW CUSTODY CUSTODY STIPULATION THIS STIPULATION, made this L day of AW,~T=---, 2005, by and between DONNA R. CODER (hereinafter referred to as "Mother") and DANIEL S. CODER (hereinafter referred to as "Father"). WITNESSETH: WHEREAS, Mother, Donna R. Coder is an adult individual who resides at 5 Enck Drive, Boiling Springs, Cumberland County, Pennsylvania. WHEREAS, Father, Daniel S. Coder is an adult individual who resides at 115 Highland Avenue, Waynesburg, Greene County, Pennsylvania. WHEREAS, Mother and Father are the natural parents ofRY AN D. CODER, born December 25, 1988 and LAUREN R. CODER, born November 7, 1992. WHEREAS, Mother had filed a Complaint for Custody, a result of which a custody conference was held before Melissa P. Greevy, Esquire on June 3, 2005. WHERESAS, on June 15, 2005 a Temporary Order of Court was issued by the Honorable Edward E. Guido scheduling a hearing on August 10,2005 at 9:00 a.m. WHEREAS, the parties have reached an agreement and therefore desire to have same incorporated as an Order of Court. NOW, THEREFORE, the parties hereto mutually agree and stipulate as follows: 1. The parties shall share legal custody of the childnm as defined by 23 Pa. C.S.A. 95301 et seQ. 2. Mother, Donna R. Coder, shall have primary physical custody of Lauren R. Coder. 3. Father, Daniel S. Coder, shall have primary physical custody of Ryan D. Coder. 4. Mother and Father have liberal partial custody with the child not in her/his physical custody at mutually convenient times as the parties and children arrange between themselves. 5. The parent without custody of the children may have the ability to enjoy reasonable telephone calls, E-mail, and other types of communic:ation with the children. 6. The parent with custody has an absolute duty to provide the other parent with all information, copies of all documents and notice of all activities and/or meetings of and concerning the children. 7. The parent with custody may make emergency decisions in the best interests of the children. However, that parent has an absolute duty to contact the other parent as soon as reasonably possible, to share all information and enable that parent to have a part in the decision- making process. 8. The parties agree that neither will utilize his or h(~r rights with respect to the minor children to harass and interfere with the other party, including the scheduling of partial custody 8. The parties agree that neither will utilize his or h(:r rights with respect to the minor children to harass and interfere with the other party, including the scheduling of partial custody arrangements. The parties further agree that they will not harass or malign each other in the pres- ence of the minor children, as both parties recognize that such conduct is detrimental to the best interests and welfare of the children, 9. E"" ''''' ."J.,~..I",..' .... "" SOl,""'.' ;, ': ';~: rf d!(';, I!i!'0 (.,ltGIGd illtll .llhtntllfil), Ilnd tkllt it i~ ftllt lh~ le3tdtllfllfl) dtllGJ" I I~, fl. is' " Stipulation and its legal effect have been fully explained to Fath,:l!' by his legal counsel, MAX J. SMITH, JR., Esquire, and to Mother by her legal counsel, p, RICHARD WAGNER, Esquire. 10. The parties will seek the assistance of this Honorable Court in resolving any difference which may arise, and which differences cannot be amicably resolved, concerning custody matters herein. II. Father and Mother agree that a Court Order encompassing the provisions herein set forth shall be entered by the Court of Common Pleas of Cumberland County, Pennsylvania. IN WITNESS WHEREOF, the Parties hereto, intending to be legally bound hereby, affix :z ~d 'M' OC:W' ili, M, &ill '_fi~;:~c~ I WITNESS DONNA R. CODER vn~ me jJJ) ~ DANIEL S. CODER 0 ..., = ~ c: = :? CJ" -00'; ~ ~:n 1J;t'r\ ~_L G'"> -( I -o~ .;.(:: :n ex) 0 ~"Ic . ,,-,~ } "" ~c, ".. :I: +I ::;: QB j;Cl (3m c 'P. ~ -" &' ?.is ex) '< ~~ DONNA CODER, Plaintiff IN THE COURT OF COMMON PL AS OF CUMBERLAND COUNTY v. NO.: O~ - ;;l.l~! CIVIL ACTION - CUSTODY C;0d~ ~........, DANIEL CODER, Defendant COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, by and through her attorneys and files the following Complaint for Custody: 1. Plaintiff, Donna Coder, is an adult individual residing at 5 Enck Drive Boiling Springs, Cumberland County, Pennsylvania. 2. Defendant is Daniel Coder, an adult individual residing at 380 Pheasa t Lane, Carlisle, Cumberland County, Pennsylvania. 3. The parties are the natural parents of Ryan Coder born 12/25/88 and Lauren Coder born 1117/92. 4. The children were born during wedlock. 5. Plaintiff is the natural mother of the aforementioned children; Defend tis the natural father of the aforementioned children. 6. The aforementioned children have resided in a shared legal and shared . . custody arrangement for approximately the last three years alternating between the Plaintiffs address contained in Paragraph I and the Defendant's address contained i Paragraph 2. 7. From approximately the time the parties separated in January of 2000 til approximately the fall of 2002, the children resided with the Plaintiff at the address contained in Paragraph I who was primary custodian of the children. 8. Plaintiff believes and therefore avers that it is in the best interest of th children to grant primary physical custody of the children unto the Plaintiff, in that t e Defendant has indicated that he is removing himself from the jurisdiction of Cumbe land County and the jurisdiction of the Boiling Springs School District, where both child en have attended since beginning school, and because Plaintiff can otherwise care for t e day to day needs of the children. WHEREFORE, Plaintiff prays for the Court to grant primary physical custo y of the children unto the Plaintiff subject to periods of partial custody unto the Defend t. Respectfully submitted: p, Richard Wagner, Esquire ID #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 . VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. .S. Section 4904, relating to unsworn falsification to authoriti s. ~ ~ ~~ DATE: (') ~-, 0 c.::::> -lQ f"-. C::::' "-<;1 0 ,n ..-' p >.- ~~; ~~11\ i -- ~ -- ;.-.J ~.~ \}::~ ,... f"'':l ,.j vt r-.:l W () g w .. ~ \.>J c...v c...,? ~ r- -~ vo ~ -J:- DONNA CODER, Petitioner v. IN THE COURT OF COMMON PEAS OF CUMBERLAND COUNTY NO.: 0:; - J.,)..'f c.~-uc' ~~ CIVIL ACTION - CUSTODY DANIEL CODER, Respondent PETITION FOR SPECIAL RELIEF AND NOW, comes your Petitioner, by and through her attorneys, and fil s the following Petition for Special Relief: I. Petitioner, Donna Coder, is an adult individual residing at 5 Enck Driv , Boiling Springs, Cumberland County, Pennsylvania. 2. Respondent, Daniel Coder, is an adult individual residing at 380 Pheas nt Lane, Carlisle, Cumberland County, Pennsylvania. 3. Petitioner has filed a Complaint in Custody in the Court of Common PIe s of Cumberland County seeking primary physical custody of the parties two children, yan Coder, bom December 25,1988 and Lauren Coder born November 7,1992. 4. The parties, since approximately fall of2002, have resided in the same sc 001 district and have enjoyed a shared legal and shared physical custody arrangement by and between themselves as it relates to the two children. 5. Recently the Respondent herein indicated to the Petitioner herein, that bec use of a relocation of his job, he will be moving to Greene County, Pennsylvania, and inte ded , to take the older child, Ryan, with him. 6. Petitioner has not agreed to permit such a relocation with the child, a objects to any such relocation. 7. Petitioner has been advised by the Respondent that settlement on his ome, address contained in Paragraph 2 above, is scheduled for the 27th of the mont , and Petitioner fears that at that point the Respondent will attempt to take physical cust dy of Ryan and move to Greene County. 8. Petitioner believes and therefore avers that because of the immediate irreparable harm that is confronting the children, that pending the underlying C stody Complaint that Petitioner has filed that the Court should enter an Order preventi g the Respondent from removing the children from the primary jurisdiction of Cumb rland County . WHEREFORE, Petitioner seeks Court intervention in granting a Petition for S ecial Relief directing that the Respondent may not move out ofthe jurisdiction with the ch ldren until such time that the underlying Complaint is decided. fully submitted: P. Richard Wagner, Esquire ID #23103 2233 North Front Street Harrisburg, P A 17110 (717) 234-7051 .. . VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authoriti s. \} !J?M4~P-:e 'lA' DATE: ~ 79~B I ~ ~ ~~~ )-l E r "---- , -"1 ~ <-' r:;;.: '"::~,., ,-M Ql :-:;1 [';1 ~~-"'. :::'\] ;;U f'~) 1"""'-:'1 --, '~ -' <.':: l~ ..,.. - D01A CODER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 05-2124 CIVIL ACTION LA W DANIFL CODER DEFENDANT IN CUSTODY ORDER OF COURT A DNOW, Thursday, April 28, 2005 , upon consideration of the attached Complaint, it is hereb ' directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. . the conciliator, at D Manlove's, 1901 State St., Camp Hill, PA 17011 on Friday, Juue 03, 2005____ at 11:00 AM for a Prc- earing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this can ot be accomplished. to deline and narrow the issues to be heard by the court. and to enter into a temporary order. Al children age five or older may also be present at the conference, Failure to appear at the conference may provide glOunds for entry of a temporary or penn anent order. T e court hereby directs the parties to furnish any and all existing Protection from Ahuse orders, Special R lief orders, and Custody orders to the coneiliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Melissa P. Greevy, Esq. Custody Conciliator y The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with isabilites Act of 1990, For information about accessible facilities and reasonable accommodations avail ble to disabled individuals having business before the court, please contact our ot'tice, All arrangements must be made at least 72 hours prior to any hearing or business beJ{"e the court. You must attend the scheduled conf rence or hearing, i YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT HA ~E AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORfH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, , Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~)J?S ,pr .;' n~' ~7 j(;l "f,(1, ,/;7 ,* "2 pP~ ~K, 5<7 }e'.>7 ~ -fr' z ~?J~;;~:' )7~9)i/ k~/J V:t\;'~;,/\l\:;i',:!";! J~LNrl~e:t'\;~" -~~'CJ',rnJ i; 0 :21 ~Id 92 tldV SOOZ IC"I'"" "-" "", 'd :JiJ' '0 ^O~_v,V~:'jJ...vc ::'11J,.:1 301:HO-G3ll:J .. 'i RECEIVED APR 2 5 2005 ~ ... v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: OS- - ;Z/;)..Y Cl-U~(~<i/L~ CIVIL ACTION - CUSTODY DONNA CODER, Petitioner DANIEL CODER, Respondent And now this ORDER p,t. A..._~ J-t day of~, 2005, upon Petition of Donna Coder, a Rule is hereby issued upon the Respondent to show cause why, if any, the reliefrequested should not be granted. Rule returnable I D days after service. Pending outcome of this Petition and the underlying Complaint for Custody, neither party shall remove the children from the primary jurisdiction of Cumberland County or remove them from the Boiling Springs School JDistrict. J. ;'l~.!fr~:<J "";~' f'~ -:.;':.:'Of1~nJ B2:IIH~ 82tldVSnOl At!V10>DluOUd 3Hl dO :!OL-i:lO-Q31Ij DONNA CODER, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 05-2124 CIVIL TERM DANIEL CODER, Respondent CIVIL ACTION - LAW CUSTODY RESPONDENT'S ANSWER TO PETITION FOR SPECIAL RELIEF AND NOW comes the Respondent, DANIEL CODER, by his attorney, MAX J. SMITH, JR., Esquire, and respectfully responds to such Petition for Special Relief as follows: 1.-3. Admitted. 4. Admitted. By way of clarification, the parties' son, Ryan, has actually spent more time in the custody of his father than with his mother in recent months. 5, Admitted. By way of further answer, Ryan has expressed a desire to relocate to western P A with Respondent. 6, Admitted. 7, Admitted in part and denied in part. It is admitted that Respondent is expecting settlement of the home he is purchasing to occur on May 27, 2005. It is denied that Respondent shall take Ryan with him pending further disposition of these proceedings. 8. Denied. There is no "immediate irreparable harm that is confronting the children," and therefore Petitioner should be denied the relief that has been requested, WHEREFORE, Respondent respectfully requests that the Petition for Special Reliefbe dismissed with prejudice. Respectfully submitted, Date: May \ ' 2005 Qn~~~ MAX J. SMITH, JR, squire I.D. No. 32114 JARAD W, HANDELMAN, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly LLP P.O, Box 650 Hershey, P A 17033 (717) 533-3280 I verify that the statements made in this Answer are true and correct. 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. - /~ MAUf:;~qwre"' b'MIf of DANIEL 'CODER DONNA CODER, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-2124 CIVIL TERM DANIEL CODER, Respondent CIVIL ACTION - LA W CUSTODY CERTIFICATE OF SERVICE AND NOW, this l day of May, 2005, 1, MAX J. SMITH, JR., Esquire, Attorney for Respondent, hereby certify that I have this day sent a copy of Respondent's Answer to Petition for Special Relief by depositing a certified copy of same in the United States, mail, postage pre- paid, at Hershey, Pennsylvania, addressed to: Mancke, Wagner & Spreha Attn: P. Richard Wagner, Esquire 2233 N, Front Street Harrisburg, PA 17110 MAX J. SMITH, J LD, No. 32114 JARAD W, HANDELMAN, Esquire I.D, No. 82629 James, Smith, Dietterick & Conne\1y LLP P.O. Box 650 Hershey,PA 17033 (717) 533-3280 ~~,; C) (.':'> "ll ,::.J"l. , \.0 (.) c:~ C. :,1 ',\1 -,' '. --, RECEIVED JUN 07 20115.;r'" Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-2124 CIVIL TERM DONNA CODER, v. DANIEL CODER, CIVIL ACTION - LAW IN CUSTODY Defendant '\ GUIDO, J --- TEMPORARY ORDER OF COURT AND NOW, this I ~~ day of June, 2005, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Leaal Custody. The parties, Donna Coder and Daniel Coder, shall have shared legal custody of the minor children, Ryan Coder, born December 25, 1988, and Lauren Coder, born November 7, 1992. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children'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. 95309, 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 children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have physical custody of the children until June 18, 2005. Commencing June 18, 2005, the parties will alternate periods of custody pending hearing each two (2) weeks with the custodial exchange to occur at Noon on Saturdays. Father's first custodial period shall commence on June 18, 2005 at Noon, which will be followed by Mother's next custodial period to commence on July 2, 2005 at Noon. 3. Transportation. Transportation will be shared by the parent relinquishing custody providing transportation incident to that custodial exchange. 4. It shall be permissible for Father to enroll Ryan in the school district where he resides so that educational arrangements do not have to be made at the last minute should he attend school from Father's residence this Fall. It is noted that this will mean that the . NO. 05-2124 CIVIL TERM child will be dually enrolled in both the South Middletown School District and the school district he will be attending in Greene County, Pennsylvania. 4. A hearing is scheduled in ~ Number 5 of the Cumberland County Courthouse, on the ( b 111 day of , 2005, at 't ,',i) o'clock ~.M., at which time testimony will be taken. For the purposes of the hearing, the Mother, Donna Coder, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least ten days prior to the hearing date. Edward E. Guido, J. Dis!: AichardWagner, Esquire, 2233 North Front Street, Harrisburg, PA 17110 .)erad W, Handelman. Esquire, PO Box 650, Hershey. PA 17033 oJ I 2 : I Hd S I Nnr ~DOZ 'iJ'N"'-"l"'''' "Hl 10 ^ '. t,..LlA\:,.iI"\_I"~_iCO:::' :. 3:)i.{-JO-'Q311j ~._.".., .. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-2124 CIVIL TERM CIVIL ACTION - LAW DONNA CODER, v. DANIEL CODER, IN CUSTODY Defendant 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 children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Ryan Coder Lauren Coder December 25, 1988 November 7, 1992 Mother and Father Mother and Father 2. Mother filed a Complaint for Custody on April 22, 2005. A Custody Conciliation Conference was held on June 3, 2005. Mother filed a Petition for Special Relief which resulted in an Order of April 28, 2005 prohibiting either party from removing the children from the primary jurisdiction of Cumberland County or removing them from the South Middleton School District. Present for the June 3, 2005 Custody Conciliation Conference were: the Mother, Donna Coder, and her counsel, P. Richard Wagner, Esquire; the Father, Daniel Coder, and his counsel, Jarad W. Handelman, Esquire. 3. Mother's position on Custodv is as follows: Mother opposes the children relocating with Father to Greene County, near Pittsburgh. She represents that the children were in her primary custody from January 2000 through Fall of 2002 and that commencing in Fall of 2002 until the filing of the Petition, the parties shared custody on an alternating basis. Both children are presently enrolled in the South Middleton School District where they have attended throughout their school years. Mother reports that the older child has been acting differently lately. She indicates that friends have contacting her asking "what is up with him." Ryan participates in the school band. However, he did not attend the Memorial Day parade with the band, apparently because he spent time with his Father over that weekend. She does not see it as typical of Ryan's behavior for him to skip a band performance. She also reports that his grades are not as good as they had been. ..,....- _# . NO. 05-2124 CIVIL TERM While she recognizes that he needs to spend time with his Father, she does not see it in his best interest to relocate at this time. Mother's counsel waives objection to Father enrolling Ryan in the school district where Father resides so that last minute arrangements will not need to be made for Ryan's education should a decision be made for Ryan to remain in Greene County, Pennsylvania during the school year. 4. Father's position on custodv is as follows: Father relocated to Greene County which he reports to be the area of Pennsylvania where both sets of the children's Grandparents reside. Father settled on a new home purchase on May 27,2005. Father is employed by Highmark in the Pittsburgh area. Father claims that Mother previously agreed to allowing Ryan to move and that Ryan wants to move to live with him. Father does not want to force Lauren to spend time with him over her objection. Accordingly, it seems that Father is content to allow the children to decide where they reside and how much contact they have with the parents. 5. Because the parties do not have an agreement as to custody of Ryan, counsel have jointly agreed to a half day hearing. Counsel have agreed to have this hearing occur in August 2005. Due to trial schedules and vacation for Mother's counsel, the hearing should not be scheduled the week of August 1, 2005 nor the week of August 22, 2005. In the interim, the parties will continue a shared physical custody schedule which alternates each two (2) weeks. The two (2) week interval was suggested by counsel to reduce the frequency of the trips between Pittsburgh and Boili p' gs. tel ~/()5 Date LA Melissa Peel Greevy, squire Custody Conciliator :252167 DONNA CODER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-2124 CIVIL TERM DANIEL CODER, Defendant : CIVIL ACTION - LAW : CUSTODY CUSTODY STIPULATION THIS STIPULATION, made this L day of AW,1--Si ,2005, by and between DONNA R. CODER (hereinafter referred to as "Mother") and DANIEL S. CODER (hereinafter referred to as "Father"). WITNESSETH: WHEREAS, Mother, Donna R. Coder is an adult individual who resides at 5 Enck Drive, Boiling Springs, Cumberland County, Pennsylvania. WHEREAS, Father, Daniel S. Coder is an adult individual who resides at 115 Highland Avenue, Waynesburg, Greene County, Pennsylvania. WHEREAS, Mother and Father are the natural parents ofRY AN D. CODER, born December 25,1988 and LAUREN R. CODER, born November 7,1992. WHEREAS, Mother had filed a Complaint for Custody, ai result of which a custody conference was held before Melissa P. Greevy, Esquire on June 3, 2005. WHERESAS, on June 15, 2005 a Temporary Order of Court was issued by the Honorable Edward E. Guido scheduling a hearing on August 10,2005 at 9:00 a.m. WHEREAS, the parties have reached an agreement and therefore desire to have same incorporated as an Order of Court. NOW, THEREFORE, the parties hereto mutually agree and stipulate as follows: 1. The parties shall share legal custody of the children as defined by 23 Pa. C.S.A. 95301 et sea. 2. Mother, Donna R. Coder, shall have primary physical custody of Lauren R. Coder. 3. Father, Daniel S. Coder, shall have primary physical custody of Ryan D. Coder. 4. Mother and Father have liberal partial custody with the child not in her/his physical custody at mutually convenient times as the parties and children arrange between themselves. 5. The parent without custody of the children may have the ability to enjoy reasonable telephone calls, E-mail, and other types of communication with the children. 6. The parent with custody has an absolute duty to provide the other parent with all information, copies of all documents and notice of all activities and/or meetings of and concerning the children. 7. The parent with custody may make emergency dedsions in the best interests of the children. However, that parent has an absolute duty to contact the other parent as soon as reasonably possible, to share all information and enable that parent to have a part in the decision- making process. 8. The parties agree that neither will utilize his or her rights with respect to the minor children to harass and interfere with the other party, including the scheduling of partial custody 8. The parties agree that neither will utilize his or her rights with respect to the minor children to harass and interfere with the other party, including the scheduling of partial custody arrangements. The parties further agree that they will not harass or malign each other in the pres- ence of the minor children, as both parties recognize that such wnduct is detrimental to the best interests and welfare of the children. c.,,"~:... .,::;:'-:"'"'.::::. :::~;::::~~M~:~~g~ Stipulation and its legal effect have been fully explained to Father by his legal counsel, MAX J, SMITH, JR., Esquire, and to Mother by her legal counsel, P. RICHARD WAGNER, Esquire. ] O. The parties wi\1 seek the assistance of this Honorable Court in resolving any difference which may arise, and which differences cannot be amicably resolved, concerning custody matters herein. ] 1, Father and Mother agree that a Court Order encompassing the provisions herein set forth shall be entered by the Court of Common Pleas of Cumberland County, Pennsylvania. IN WITNESS WHEREOF, the Parties hereto, intending to be lega\1y bound hereby, affix their hands and seals below, the day and year first above written. h - ~fi'~ I WITNESS DONNA R. CODER Wl~; ~ ---- f}J) L~ DANIEL S. CODER (') '" 0 = c: = ." ~.".. CJ1 .."d} "'" ~::n r:;;C": c:: 2t1-" (;') I -o~ ~:;- :n 00 ':.l C::i^:.; :--1 ) :::r::, fe, ",.. ("):!.. :.J;: "0 5>' c) (5n1 C v:> 7 --l ":.~ 55 =< ..,- 00 -<