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HomeMy WebLinkAbout05-5314IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KELLY FAHNESTOCK, CIVIL ACTION Plaintiff V. Rte. `YLo, d S- Sf 3 / y ?- KEITH GREENWALD, Defendant CUSTODY COMPLAINT FOR CUSTODY 1 2 3 4. 5 Plaintiff is Kelly Fahnestock, who resides at 50 Bonny Brook Road, Lot #9, Carlisle, PA 17013. Defendant is Keith Greenwald, who resides at 265 Lincoln Street, Carlisle, PA 17013. Plaintiff seeks custody of the following child: Name Present Residence DOB Age 3 years Hunter Greenwald 50 Bonny Brook Rd. Lot #9, Carlisle, PA 17013 The child was born out of wedlock. 12/10/01 The child is presently in the legal custody of Defendant, Keith Greenwald who resides at 265 Lincoln Street, Carlisle, PA 17013. The child is presently in the physical custody of Plaintiff, Kelly Fahnestock who resides at 50 Bonny Brook Road, Lot #9, Carlisle, PA 17013. 6. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Kelly Fahnestock 143 North West Street Birth-1/02 Keith Greenwald Carlisle, PA 17013 Deric Fahnestock Keith Greenwald Kelly Fahnestock Deric Fahnestock 85 West Main Street Newville, PA 1/02-6/02 Kelly Fahnestock 9 Brenley lane 6/02-9/02 Deric Fahnestock Mt. Holly, PA 17065 Kelly Fahnestock Domestic Violence Shelter 9/02-11/02 Deric Fahnestock P.O. Box 1039 Kelly Fahnestock Safe Harbor 11/02-2/03 Deric Fahnestock 102 West High Street Carlisle, PA 17013 Kelly Fahnestock 651 Alexander Spring Rd. 2/034/03 Deric Fahnestock Carlisle, PA 17013 Joseph Barrick, Jr. Joseph Barrick, Sr. Susan Barrick Kaitlyn Barrick Felicia Barrick Kelly Fahnestock 167 Old Town Rd. 4/03-5/03 Deric Fahnestock Gardners, PA Joseph Barrick, Jr. Kelly Fahnestock 98 Fairview Street 5/03-10/03 Deric Fahnestock Lot #l, Carlisle, PA 17013 Gary Singer Kelly Fahnestock 135 Wesley Drive 10/03-1/04 Deric Fahnestock Carlisle, PA 17013 William Fitzhenry Kelly Fahnestock 50 Walmar Manor 1/01/04-1/15/04 Deric Fahnestock Dillsburg, PA 17019 Penny Ramos Amy and Kyle Ramos Kelly Fahnestock 98 Fairview Street 1/15/04-3/04 Deric Fahnestock Lot #1, Carlisle, PA 17013 Gary Singer Kelly Fahnestock 98 Fairview Street 3/04-4/04 Deric Fahnestock Lot #11, Carlisle, PA 17013 Michael Irvin Heather Irvin Michael Kope Kelly Fahnestock 98 Fairview Street 4/04-5/17/04 Deric Fahnestock Lot #1, Carlisle, PA 17013 Gary Singer Kelly Fahnestock 501 Windy Hill Rd. 5/17/04-9/04 Deric Fahnestock Shermansdale, 17090 Keith Greenwald Keith Greenwald Kelly Fahnestock Deric Fahnestock 7. The mother of the c Carlisle, PA 17013. She is not married. 501 Windy Hill Road 9/04-9/17/04 Shermansdale, PA 17090 265 Lincoln Street, Carlisle, PA 17013 50 Bonny Brook Rd. 9/17/04-present Lot #9, Carlisle, PA 17013 hild is Kelly Fahnestock who resides at 50 Bonnybrook Road, Lot #9, 8. The father of the child is Keith Greenwald, who resides at 265 Lincoln Street, Carlisle, PA 17013. He is not married. 9. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons. Name Relationship Deric Fahnestock Son Hunter Greenwald Son 10. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons. Name Unknown Relationship 11. The best interest and permanent welfare of the child will be served by granting the relief request because: A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. A Court ordered determination of custody is required to avoid continuing conflict between the parties regarding parental responsibilities for custody and support. Hunter has been in Plaintiff's primary care and custody since birth. Plaintiff is desirous of enrolling Hunter into a Headstart program. Defendant currently has no permanent residence in which to care for Hunter Greenwald. Plaintiff has no way of contacting the Defendant as Defendant will/can not provide a phone number or current residential address. Plaintiff is able to provide the care and nurture which the child needs for healthy development in a primary custody situation. 12. Plaintiff's attorney is unaware of any opposing counsel and will serve the Complaint of Custody on the opposing party directly. 13. The proposed temporary order states that the Plaintiff Kelley Fahnestock shall have primary physical and legal custody of the child Hunter Greenwald. Child. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody of Date: ? d /71 j Respetfull sub ied, c tt Jo angan Attorny for Plaintiff---/ Attorney I.D. #87000 35 East High Street Suite 204 Carlisle, PA. 17013 717-241-2446 VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unworn falsification to authorities. Date: Kelly F ock, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KELLY FAHNESTOCK, CIVIL ACTION Plaintiff V. F. R. KEITH GREENWALD, Defendant CUSTODY CERTIFICATE OF SERVICE I, John J. Mangan, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Custody Complaint upon the following by depositing same in the United States Mail, Certified mail/Return Receipt Requested/Restricted Delivery at Carlisle, Pennsylvania, addressed as follows: Keith Greenwald 265 Lincoln Street, Carlisle, PA 17013 Date: 1/ - ?G Respect *Iy Wbn*Ae , John J/gan Atto y or Plaintiff Attorney I.D, #87000 35 East High Street Suite 204 Carlisle, PA. 17013 717-241-2446 r-a r - t.:ra Z7 _ c_n y ^, C7 4 ?y7 i,? KELLY FAHNESTOCK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH GREENWALD DEFENDANT 05-5314 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, October 14, 2005 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 Oil Thursday, November 17, 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 ifthis 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 conference. 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. FOR THE COURT. By: /s/ ac ueline M. Verney, Esq. lid\ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 sv 67,- -5a-,p - 0/ NOV t 7 2005 KELLY FAHNESTOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5314 CIVIL TERM KEITH GREENWALD, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this ZI 5-1 day of 1K) o V _ 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Kelly Fahnestock, and the Father, Keith Greenwald, shall have shared legal custody of Hunter Greenwald, born December 10, 2001. 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. 1 Mother shall have primary physical custody of the child. 1 Father shall have periods of partial physical custody as follows: A. Beginning November 18, 2005, alternating weekends from Friday at 9:00 a.m. (except if the child begins Head Start, then after Head Start) to Sunday at 6:00 p.m. B. Every Monday, Tuesday and Friday from 9:00 a.m. to 6:00 p.m. unless the child begins Head Start, in which case from after Head Start to 7:00 p.m. C. Such other times as the parties agree. below: 4. Holidays. The parties shall have physical custody of the child as indicated A. Thanksgiving-Father shall always have physical custody of the child from 8:00 a.m. to 2:00 p.m. and Mother shall always have physical custody of the child from 2:00 p.m. to 8:00 p.m. B. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered and Father shall have Block A in even numbered years and Block B in odd numbered years. C. Easter-Father shall have physical custody of the child from 8:00 a.m. to 2:00 p.m. and Mother shall have physical custody of the child from 2:00 p.m. to 8:00 p.m. D. Mother's Day/Father's Day- Mother shall have physical custody of the child on Mother's Day and Father shall have physical custody of the child on Father's Day, both at times as agreed by the parties. E. Memorial Day/Fourth of July/Labor Day-alternate with Father having Memorial Day in 2006. F. Child's birthday-each party shall have a block of time with the child on the child's birthday. 5. Each party shall be entitled to seven (7) uninterrupted days of physical custody of the child during the summer vacation, provided they give the other party thirty (30) days prior notice. In the event the child will leave the area during this time, the custodial parent shall provide an address and telephone number where the child can be contacted. 6. Father shall be responsible for all transportation. 7. In the event of a medical emergency, the custodial parent shall notify the other parent as soon as practicable after the emergency is handled. 8. This Order is entered pursuant to the request of Mother at a Custody Conciliation Conference which Father was aware of but did not attend. 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. cc: John J. Mangan, Esquire, Co4el for Kei"th G ld reenwa , pro se ?y 265 Lincoln Street ?r'?VLS l 't? 0 Carlisle, PA 17013 rr KELLY FAHNESTOCK, Plaintiff V. KEITH GREENWALD, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 2005-5314 CIVIL TERM CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Hunter Greenwald December 10, 2001 Mother 2. A Conciliation Conference was held in this matter on November 17, 2005, with the following individuals in attendance: The Mother, Kelly Fahnestock, with her counsel, John J. Mangan, Esquire and Father, Keith Greenwald, pro se 3. The parties agree to the entry of an Order in the form as attached. Date acgOline M. Verney, Esquire Custody Conciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KELLY FAHNSTOCK, Respondent v No. 2005-5314 CIVIL ACTION - LAW KEITH GREENWALD, Petitioner CUSTODY PETITION FOR MODIFICATION OF A CUSTODY ORDER AND NOW, this day of April, 2007, comes Petitioner, Keith Greenwald, by and through his attorney, Suzanne Spencer Abel, Esq., and who avers as follows: 1. The petition of Keith Greenwald respectfully represents that on November 21, 2005, an Order of Court was entered for partial custody, a true and correct copy of which is attached. 2. This Order should be modified because the Petitioner has, for the past 16 months, been denied regular visitation and communication with their minor child. Specifically, Respondent consistently and defiantly refuses to have their child at Respondent's home when Petitioner arrives to pick up the child, and then refuses to release their child to Petitioner's parents when they subsequently attempt to pick him up for Petitioner's visitation; repeatedly refuses to identify their child's Head Start School, and now volunteers at their child's school which further deters Petitioner from exercising his Court-Ordered periods of visitation; consistently refuses to permit phone communication between Petitioner and their child; repeatedly refuses to provide Petitioner with her oft-changing phone numbers; and insists upon communicating with Petitioner's parents in lieu of communicating directly with Petitioner, while simultaneously insisting that Petitioner's parents' home be the transfer site when Respondent unilaterally decides to allow Petitioner to spend some time with their son. 3. This Order should further be modified because the minor child's home environment causes the child extreme stress and emotional trauma; to wit, each of Respondent's two regular live-in paramours have criminal records spanning from 1998 through the present, including several periods of incarceration. Based upon the child's increasingly agitated emotional state when talking about his activities with Respondent's paramours, as well as the child's frantic pleas and exhortations to not be returned to Respondent's home, Petitioner believes the child requires a therapeutic psychological evaluation to determine from what, if any, services the child may benefit. Petitioner seeks an Order directing such evaluation, and temporary primary custody pending the outcome of that evaluation. WHEREFORE, Petitioner, Keith Greenwald, respectfully requests this Honorable Court modify the existing Order for partial custody because it will be in the best interest of the child. Respectfully submitted, Spencer Abel Law Office u ne Spe r Abel, Esq. Atty ID #202443 22 East Street, #6 Mt Holly Springs, PA 17065 (717) 323-0046 spencer abel_esq@fastmail.fm Counsel for Petitioner Page 2 NOV 1 7 1005 KELLY FAHNESTOCK, Plaintiff V. KEITH GREENWALD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-5314 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT 2. Mother shall have primary physical custody of the child. 1 Father shall have periods of partial physical custody as follows: A. Beginning November 18, 2005, alternating weekends from Friday at 9:00 a.m. (except if the child begins Head Start, then after Head Start) to Sunday at 6:00 p.m. B. Every Monday, Tuesday and Friday from 9:00 a.m. to 6:00 p.m. unless the child begins Head Start, in which case from after Head Start to 7:00 p.m. C. Such other times as the parties agree. AND NOW, this -Lt J day of y K) o v , 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Kelly Fahnestock, and the Father, Keith Greenwald, shall have shared legal custody of Hunter Greenwald, born December 10, 2001. 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. below: 4. Holidays. The parties shall have physical custody of the child as indicated A. Thanksgiving-Father shall always have physical custody of the child from 8:00 a.m. to 2:00 p.m. and Mother shall always have physical custody of the child from 2:00 p.m. to 8:00 p.m. B. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered and Father shall have Block A in even numbered years and Block B in odd numbered years. C. Easter-Father shall have physical custody of the child from 8:00 a.m. to 2:00 p.m. and Mother shall have physical custody of the child from 2:00 p.m. to 8:00 p.m. D. Mother's Day/Father's Day- Mother shall have physical custody of the child on Mother's Day and Father shall have physical custody of the child on Father's Day, both at times as agreed by the parties. E. Memorial Day/Fourth of July/Labor Day-alternate with Father having Memorial Day in 2006. F. Child's birthday-each party shall have a block of time with the child on the child's birthday. 5. Each parry shall be entitled to seven (7) uninterrupted days of physical custody of the child during the summer vacation, provided they give the other party thirty (30) days prior notice, In the event the child will leave the area during this time, the custodial parent shall provide an address and telephone number where the child can be contacted. 6. Father shall be responsible for all transportation. 7. In the event of a medical emergency, the custodial parent shall notify the other parent as soon as practicable after the emergency is handled. 8. This Order is entered pursuant to the request of Mother at a Custody Conciliation Conference which Father was aware of but did not attend. 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. cc: John J. Mangan, Esquire, Co sel for Keith Greenwald s ro e , p 265 Lincoln Street lvt ? Carlisle, PA 17013 .IPV s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KELLY FAHNSTOCK, Respondent v KEITH GREENWALD, Petitioner VERIFICATION No. 2002-4939 No. 2005-5314 CIVIL ACTION - LAW CUSTODY I VERIFY that I have personal knowledge of all facts not of record set forth in the foregoing pleading, and that such statements are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: .; Keith Greenwald 0 l p M1 • r j i"TI ? .....1d tf..s 1 W ?? KELLY FAHNSTOCK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH GREENWALD DEFENDANT 05-5314 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, April 04, 2007 , 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 Tuesday, May 01, 2007 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or i f 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 conference. 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. FOR THE COURT. By: /s/ ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 4V «-h-h ' a, ?oh.h ?oq L 0-17 -h nHI JO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KELLY FAHNSTOCK, Respondent No. 2005-5314 v CIVIL ACTION - LAW KEITH GREENWALD, Petitioner CUSTODY AFFIDAVIT OF SERVICE AND NOW, this rd day of May, 2007, I, Suzanne Spencer Abel, Esq., hereby certify that on April 2, 2007, as evidenced on the following page bearing a true copy of the signed, returned receipt, a certified true copy of the PETITION FOR MODIFICATION OF A CUSTODY ORDER were served in person upon the defendant: Kelly Fahnstock 164 East Penn Street Carlisle, PA 17013 Respectfully submitted, 5)'J-'CL? calao, aw Suz a Spen Abel ID # 443 22 East Street, #6 Mt. Holly Springs, PA 17065 (717) 323-0046 Attorney for Petitioner AFFIDAVIT OF RETURN OF SERVICE I, swear and affirm that this day of Dspn , 20at o'clock am/ m, was present at when and where I personally served , Defendant in the case docketed by the County Prothonotary's office at ,)-o u5 - 53 H , by LanAirsa &e, aAA At this same time and place, h L JAI .PS 1 n9 Commonwealth of Pennsylvania ) SS: County of Cumberland } known to me, who being duly sworn according to law, swears and affirms to the statement as written above, under penalty of law pursuant to 18 U1 (city/statetzip) (area code + phone) Pa.C.S.A. §4903, relating to false wearin (Signature of Affiant) (. It r RPVV;4 FP N07ARYPUBLIC q"1P1f q„rr -i1Mb&eb66dW and !worn to before me this ? day of g,,PC21 , 20A Alt n 1m?C41 ' %gttQS AL,014 pn(jq Notarv Public ? 1 ACCEPT SERVICE AND ACKNOWLEDGE RECEIPT OF THE DOCUMENT ? 1 REJECT SERVICE BUT ACKNOWLEDGE RECEIPT OF THE DOCUMENT. Signed: day, personally appeared Date: Address: Ga O ? 't.i W C3 Y? MAY 0' 2 lrV KELLY FAHNSTOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5314 CIVIL TERM KEITH GREENWALD, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this 7I? day of A4 , 2007, upon consideration of the attached Custody Conciliation Rep rt, it is ordered and directed as follows: The prior Order of Court is hereby vacated. 2. The Father, Keith Greenwald and the Mother, Kelly Fahnstock, shall have shared legal custody of Hunter Greenwald, born December 10, 2001. 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. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child 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. 3 During the school year Mother shall have primary physical custody of the child. 3. During the school year, beginning May 3, 2007 Father shall have periods of partial physical custody on alternating weekends from Thursday at 4:00 p.m. to Monday at 12:00 noon. Father shall pick up the child from Mother's at the beginning of 4 4 ?-? 1'' ?? ? ?. ,- r\S\" :Z ?aa a- ?'????? Lc°?0? ?.,? his custodial period and drop off the child to his Head Start program by 12:00 noon on Mondays. 4. During the summer, the parties shall share physical custody on a week on/week off basis. The exchange day shall be Sundays and Father's week shall begin on June 10, 2007. The exchange time shall be 6:00 p.m. 5. Within one week of the date of this Order, Mother shall sign all necessary releases so that Father may speak to and receive any and all reports from the child's therapist and Behavioral Specialist. Father also has the right to have the child evaluated by a psychologist of his choice. 6. The parents shall have the right to liberal telephone contact with the child between the hours of 7:00 p.m. to 8:00 p.m. In the event that the child is not available at that time, the custodial parent shall have the child return the call to the non-custodial parent. 7. In the event that either party is in need of a babysitter for more than three (3) hours, they shall notify and offer the non-custodial parent said babysitting opportunity in such reasonable time so that it can be accepted. 8. Holidays. The parties shall have physical custody of the child as indicated below: A. Thanksgiving-Father shall always have physical custody of the child from 8:00 a.m. to 2:00 p.m. and Mother shall always have physical custody of the child from 2:00 p.m. to 8:00 p.m. B. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered and Father shall have Block A in even numbered years and Block B in odd numbered years. C. Easter-Father shall have physical custody of the child from 8:00 a.m. to 2:00 p.m. and Mother shall have physical custody of the child from 2:00 p.m. to 8:00 p.m. D. Mother's Day/Father's Day- Mother shall have physical custody of the child on Mother's Day and Father shall have physical custody of the child on Father's Day, both at times as agreed by the parties. E. Memorial Day/Fourth of July/Labor Day-alternate with Father having Memorial Day in 2006. F. Child's birthday-each party shall have a block of time with the child on the child's birthday. 9. Each party shall be entitled to seven (7) uninterrupted days of physical custody of the child during the summer vacation, provided they give the other party thirty (30) days prior notice. In the event the child will leave the area during this time, the custodial parent shall provide an address and telephone number where the child can be contacted. 10. Unless otherwise indicated herein, the receiving party shall transport. It. In the event of a medical emergency, the custodial parent shall notify the other parent as soon as practicable after the emergency is handled. 12. Neither party shall say or do anything, or permit a third parry from doing or saying anything that 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. If the child calls someone else "Mom" or Dad" other than his biological parents, the custodial parent shall correct him and suggest an alternate name for the child to use. 13. The parties shall communicate with each other directly regarding custody matters, and shall not use the child to exchange messages. They shall be civil toward each other in the presence of the child. 14. This Order is entered pursuant to 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. Another conciliation conference is scheduled for July 10, 2007 at 8:30 a.m. ce.? e Spencer Abel, Esquire, Counsel for Father ahnstock, pro se 164 East Penn Street Carlisle, PA 17013 4 ,61r !Z:zz?s V?1? KELLY FAHNSTOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-5314 CIVIL TERM KEITH GREENWALD, : CIVIL ACTION - LAW Defendant 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 Hunter Greenwald December 10, 2001 Mother 2. A Conciliation Conference was held in this matter on May 1, 2007, with the following individuals in attendance: The Father, Keith Greenwald, with his counsel, Suzanne Spencer Abel, Esquire and Mother, Kelly Fahnestock, pro se 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court dated November 21, 2005 providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends and three evenings per week. 4. The parties agree to the entry of an Order in the form as attached. ?- -10 7 /? - ??' Date acq line M. Verney, Esquire Custody Conciliator JUL 13 2001 Yi KELLY FAHNESTOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5314 CIVIL ACTION - LAW KEITH GREENWALD, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 13"' day of July, 2007, the parties having failed to appear at a scheduled conciliation conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, IVIac line M. Verney, Esquire, Cust y Conciliator ?1 1 LUZ _ 3RI 30 KELLY FAHNESTOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5314 CIVIL TERM KETIH GREENWALD, : CIVIL ACTION - LAW Defendant IN CUSTODY PETPITON FOR MODIFICATION OF CUSTODY AND NOW, comes Petitioner, Kelly Fahnestock, by and through her attorney, Mark F. Bayley, Esquire, and in support of the within Motion avers as follows: 1. Kelly Fahnestock, Petitioner, (hereinafter referred to as "Mother"), is the Plaintiff in the above caption-matter, and is an adult currently residing at 164 E. Penn St., Carlisle, PA 17013. 2. Keith Greenwald, Respondent, (hereinafter referred to as "Father"), is the Defendant in the above-captioned matter, and is an adult whose address is unknown. 3. The parties are the natural parents of: Hunter Greenwald (date of birth 12/10/2001) 4. By Order dated May 7, 2007, by the Honorable J. Wesley Oler, and by agreement of the parties, Mother and Father have shared legal custody of Hunter Greenwald (copy is attached as Exhibit "A") 5. A change of circumstances has occurred since the parties' prior agreement and Order because: a. Hunter Greenwald, 6 years old, now has a full time school schedule and the prior Order is not consistent with his new schedule. 6. Mother is requesting that the current Order be modified. WHEREFORE, Plaintiff requests this Honorable Court to schedule a custody conciliation conference. Date: oc0 Respectfully submitted, BAYLEY & MANGAN QU Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Plaintiff KELLY FAHNESTOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5314 CIVIL TERM KETIH GREENWALD, : CIVIL ACTION - LAW Defendant IN CUSTODY VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unworn falsification to authorities. Kelly F esto amtiff G r.> 7a a fil KELLY FAHNESTOCK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2005-5314 CIVIL ACTION LAW KEITH GREENWALD IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, February 08, 2008 , 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 Tuesday, March 04, 2008 at 10:30 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. FOR THE COURT, By: /s/ ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 504- e JO MAY os 200 (-1 KELLY FAHNESTOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5314 CIVIL TERM KEITH GREENWALD, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this 'i (t day of , 2008, upon consideration of the attached Custody Concili R port, it is ordered and directed as follows: The prior Order of Court dated May 7, 2007 is hereby vacated. 2. The Mother, Kelly Fahnestock and the Father, Keith Greenwald, shall have shared legal custody of Hunter Greenwald, born December 10, 2001. 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. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child 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. 3 During the school year Mother shall have primary physical custody of the child. 4. During the school year, Father shall have periods of partial physical custody for three consecutive weekends, Friday at 5:30 p.m. to Monday at 7:00 a.m. Mother shall then have one weekend, and Father will again have three weekends. Said schedule shall continue on the 3/1 alternating weekend schedule. Mother's weekend shall begin shall r.t X: 7:11 _ RL z ? JZ *C?'L R U ?.,r have Mother's Day weekend, May 9-11, 2008. When Father returns the child on Monday mornings he shall already be showered and ready for school. 5. During the summer, the parties shall share physical custody one. week on/week off basis. The exchange day shall be Fridays at 5:30 p.m. Father's week shall begin on the first Friday that school is recessed. 6. The parents shall have the right to liberal telephone contact with the child between the hours of 7:00 p.m. to 8:00 p.m. In the event that the child is not available at that time, the custodial parent shall have the child return the call to the non-custodial parent. 7. In the event that either party is in need of a babysitter for more than three (3) hours, they shall notify and offer the non-custodial parent said babysitting opportunity in such reasonable time so that it can be accepted. 8. Holidays. The parties shall have physical custody of the child as indicated below: A. Thanksgiving-Father shall always have physical custody of the child from 8:00 a.m. to 2:00 p.m. and Mother shall always have physical custody of the child from 2:00 p.m. to 8:00 p.m. B. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered and Father shall have Block A in even numbered years and Block B in odd numbered years. C. Easter-Father shall have physical custody of the child from 8:00 a.m. to 2:00 p.m. and Mother shall have physical custody of the child from 2:00 p.m. to 8:00 p.m. D. Mother's Day/Father's Day- Mother shall have physical custody of the child on Mother's Day and Father shall have physical custody of the child on Father's Day, both at times as agreed by the parties. E. Memorial Day/Fourth of July/Labor Day-alternate with Father having Memorial Day in 2006. F. Child's birthday-each party shall have a block of time with the child on the child's birthday. G. Trick or Treat night shall be alternated with Father having even numbered years and Mother having odd numbered years. 9. Each party shall be entitled to seven (7) uninterrupted days of physical custody of the child during the summer vacation, provided they give the other party thirty (30) days prior notice. In the event the child will leave the area during this time, the custodial parent shall provide an address and telephone number where the child can be contacted. 10. Transportation shall be shared as agreed. 11. In the event of a medical emergency, the custodial parent shall notify the other parent as soon as practicable after the emergency is handled. 12. Neither party shall say or do anything, or permit a third party from doing or saying anything that may estrange the child from the other parent, injure the opinion of the chi Id as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. If the child calls someone else "Mom" or Dad" other than his biological parents, the custodial parent shall correct him and suggest an alternate name for the child to use. 13. The parties shall communicate with each other directly regarding custody matters. and shall not use the child to exchange messages. They shall be civil toward each other in the presence of the child. 14. This Order is entered pursuant to 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. cc?:Mark F. Bayley, Esquire, Counsel for Mothei 'Nathan C. Wolf, Esquire, Counsel for Father 016F t'LS fn7.1 LS-CL S1Q1og ql?n BY THE COURT, KELLY FAHNESTOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-5314 CIVIL TERM KEITH GREENWALD, : CIVIL ACTION - LAW Defendant 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: I . The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Hunter Greenwald December 10, 2001 Mother 2. A Conciliation Conference was held in this matter on May 2, 2008, with the following individuals in attendance: The Mother, Kelly Fahnestock Kwith her counsel, Mark F. Bayley, Esquire and the Father, Keith Greenwald, with his counsel, Nathan C. Wolf, Esquire. 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court dated May 7, 2007 providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends, Thursday to Monday. 4. The parties agreed to the entry of an Order in the form as attached. ,5-- 2, Date Jac eline M. Verney, Esquire Custody Conciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENSYLVANIA KELLY FAHNESTOK, RESPONDENT V. KEITH GREENWALD JR-, POTITIONER, PRAECIPE CUSTODY t-. J 1 L 1? ctJ i`i i _ T1 ? PRAECIPE TO ENTER ORDER OF THE COURT ADOPTING STIPULATION FOR CUSTODY. TO THE PROTHONATRY: KINDLY TRANSMIT THE ENCLOSED FULLY EXECUTED STIPULATION FOR CUSTODY TO THE COURT FOR ENTRY AS AN ORDER OF COURT. RE?SP CTF Y T KE BRfAN GREENWALD JR. PROSE NO.20005-5314 CIVIL ACTION-LAW AGREMENT FEBUARY 22 2010 1.THE PRIOR ORDER OF COURT IS HERBY VACATED. 2. THE FATHER, KEITH GREENWALD AND THE MOTHER, KELLY FAHNSTOCK, SHALL HAVE SHARED LEGAL COSTODY OF HUNTER GREENWALD, BORN DECEMBER 10, 2001. EACH PARENT SHALL HAVE AN EQUAL RIGHT,TO BE EXERCISED JOINTLY WITH THE OTHER PARENT, TO MAKE ALL MAJOR NON-EMERGENCY DECISIONS AFFECTING THE CHILDS GENERAL WELL-BEING INCLUDING, BUT NOT LIMITED TO, ALL DECISIONS REGUARDING HIS 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 CHILD 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 REGUARD TO THE MINOR CHILD. EACH PARENT SHALL BE ENTITLED TO FULL AND COMPLETE INFORMATION FROM ANY PHYSICIANE, 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. ADDITIONALY, EACH PARENT SHALL BE ENTITLED TO RECEIVE COPIES OF ANY NOTICES WHICH COME FROME SCHOOL WITH REGUARD TO SCHOOL PICTUERS, EXRACURRICULAR ACTIVITIES, CHILDREN'S PARTIES, MUSICAL PRESENTATIONS, BACK-TO-SCHOOL NIGHTS, AND THE LIKE. 3. DURING THE SCHOOL YEAR FATHER SHALL HAVE PRIMARY PHYSICAL CUSTODY OF THE CHILD. 3. DURING THE SCHOOL YEAR BEGINNING FEBUARY 22, 2010 MOTHER SHALL HAVE PARTIAL PHYSICAL CUSTODY ON ALTERNATING WEEKENDS FROM FRIDAY AT 4:00 PM. TO SUNDAY AT 4:00 PM. MOTHER SHALL PICK UP CHILD FROM FATHERS AT THE BEGINNING OF HER CUSTODIAL PERIOD AND DROP OFF THE CHILD TO THE FAHER AT CHILDS PRIMARRY RESIDENCE WITH FATHER. 4. DURING THE SUMMER, THE PARTIES SHALL HAVE SHARED PHYSICAL CUSTODY ON A WEEK ON WEEK OFF BASIS. THE EXCHANGE DAY SHALL BE FRIDAYS AND MOTHERS WEEK SHALL BEGIN ON JUNE 10, 2010. THE EXCHANGE TIME SHALL BE 4:00 PM. 5. THE PARENT SHALL HAVE THE RIGHT TO LIBERAL TELEPHONE CONTACT WITH THE CHILD BETWEEN THE HOURS OF 7:00 AM. TO 8:00 PM. IF THE CHILD IS NOT AVAILABLE AT THAT TIME, THE CUSTODIAL PARENT SHALL HAVE THE CHILD RETURN THE CALL TO THE NON-CUSTODIAL PARENT. 6.IF IN THE EVENT THAT EITHER PARTY IS IN NEED OF A BABYSITTER FOR MORE THAN (3) HOURS, THEY SHALL NOTIFY AND OFFER THE NON-CUSTODIAL PAERENT OPPORTUNITY IN SUCH REASONABLE TIME SO THAT IT CAN BE ACCEPTED. 7. HOLIDAYS. THE PARTIES SHALL HAVE PHYSICAL CUSTODY OF THE CHILD AS INDICATED BELOW: A. THANKSGIVING-FATHER SHALL ALWAYS HAVE PHYSICAL CUSTODY OF THE CHILD FROM 8:00 AM TO 2:00 PM. AND THE MOTHER SHALL ALWAYS HAVE PHYSICAL CUSTODY OF THE CHILD FROM 2:00 PM. TO 8:00 PM. B. CHRISTMAS SHALL BE DIVIDED INTO TWO BLOCKS. BLOCK A SHALL BE FROM 12:00 NOON ON CHRISTMAS EVE TO 12:00 NOON ON CHRISTMAS DAY. BLOCK B SHALL BE FROM CHRISTMAS DAY AT 12:00 NOON UNTIL DEC. 26, AT 12:00 NOON. MOTHER SHALL HAVE BLOCK A IN ODD NUMBER YEARS AND BLOCK B IN EVEN YEARS AND FATHER SHALL HAVE BLOCK A IN EVEN NUMBERED YEARS AND BLOCK B IN ODD NUMBERED YEARS. C. EASTER-FATHER SHALL HAVE PHYSICAL CUSTODY OF THE CHILD FROM 8:00 AM. TO 2:00 PM. AND MOTHER SHALL HAVE PHYSICAL CUSTODY OF THE CHILD FROM 2:00 PM. UNTIL 8:00 PM. D. MOTHER'S DAY/FATHER'S DAY- MOTHER SHALL HAVE PHYSICAL CUSTODY OF THE CHILD ON MOTHER'S DAY AND FATHER SHALL HAVE PHYSCIACL CUSTODY OF THE CHILD ON FATHERS DAY, BOTH AT TIMES AGREED BY THE PARTIES. E. MEMORIAL DAY/ FOURTH OF JULY/ LABOR DAY- ALTERNATING WITH THE FATHER HAVING MEMORIAL DAY IN 2010. F. CHILD'S BIRTHDAY- EACH PARTY SHALL HAVE A BLOCK OF TIME WITH THE CHILD ON THE CHILD'S BIRTHDAY. 9. IN THE EVENT OF A MEDICAL EMERGENCY, THE CUSTODIAL PARENT SHALL NOTIFY THE OTHER PARENT AS SOON AS PRACTICABLE AFTER THE EMERGENCY IS HANDLED. 10.THIS AGREMENT IS ENTERED TO MODIFY THE PREVIOUS ORDER BY MUTUAL CONSENT. FEBUARY 22, 2010. AT 2:00 PM. a 55 KEITH GREENWAL D J .- - _ ___ _______ KELLY FAHNESTOCK -1----- ----- ----- - ""- llS- alaa I v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENSYLVANIA KELLY FAHNESTOK, RESPONDENT V. KEITH GREENWALD JR-, POTITIONER, VERIFICATION CUSTODY I VERIFY THAT I HAVE PERSONAL KNOWLEDGE OF ALL FACTS NOT OF RECORD SET FORTH IN THE FOREGOING PLEADING, AND THAT SUCH STATEMENTS ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. I UNDERSTAND THAT FAULSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF IS PA. C.S.A. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE----- KEITH GREENWALD JR., PROSE : NO.20005-5314 CIVIL ACTION-LAW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KELLY FAHNESTOCK PLAINTIFF KEITH GREENWALD JR., DEFENDANT ACCEPTANCE OF SERVICE CIVIL ACTION aboT - 53l ? :CUSTODY :? rya I KELLY FAHNESTOCK DO HEREBY CERTIFY THAT I THIS DAY RECEIVED A COPY OF THE AGREEMENT BY PERSONAL DELIVERY. 0.rd rtc?ev?C? cc) KELLY FAHNESTOCK 147 W. LOUTER ST. APT.4 CARLISLE, PA 17013 DATE RESPECTFULLY SUBMITTED,, L 1r 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENSYLVANIA KELLY FAHNESTOK, RESPONDENT : NO.20005-5314 : CIVIL ACTION-LAW V. KEITH GREENWALD JR., POTITIONER, : CUSTODY ORDER OF COURT FEB 2 6 2 AND NOW THIS--LL DAY OF 2010, UPON CONSIDERATION OF THE ATTACHED STIPULATION FOR CUSTODY WITH RESPECT TO THE PARTIE'S MINOR CHILD,HUNTER BRIAN GREENWALD, (D.O.B. DECEMBER 10 2001),IT IS HEREBY ORDERED AND DIRECTED AS FOLLOWS: 1. THE PRIOR ORDER OF THE COURT DATED MAY 5, 2005, IS HEREBY VACATED. 2. THIS ORDER IS ENTERED PURSUANT TO THE STIPULATION FOR CUSTODY ATTACHED HERETO, ADOPTED AND MADE A PART OF THIS ORDER 3. THIS ORDER SHALL CONTINUE IN FULL FORCE AND EFFECT UNTIL ORDERED OTHERWISE. c N ` o = rvi, (-;ice i. E I ?.. L BY THE COURT,