HomeMy WebLinkAbout02-0971
JOSHUA C. PRYOR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
JENNIFER N. PRYOR,
Defendant
; NO. OO-Cj7/
: IN CUSTODY
CIVIL TERM
CUSTODY STIPULATION & AGREEMENT
THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set
forth, by and between JOSHUA C. PRYOR, (hereinafter referred to as "Father") and
JENNIFER N. PRYOR, (hereinafter referred to as "Mother").
WHEREAS, the parties are the natural parents of one child, namely NICHOLAS
FRANKLIN CHARLES PRYOR, born May 11,2000, (hereinafter referred to as "Child"); and
WHEREAS, the parties live separate and apart, and wish to enter into an comprehensive
stipulation and agreement relative to physical and legal custody of their Child.
NOW THEREFORE, in consideration of mutual covenants, promises and agreements as
hereinafter set forth, the parties stipulate and agree as follows:
1. Mother and Father shall have shared legal custody of the child. Each party has the
right to be exercised jointly with the other to make all non-emergency decisions
regarding the child, including, but not limited to, medical, education and religious
decisions.
2. Mother shall have primary physical or residential custody of the child.
3.
4.
5.
6.
7.
8.
9.
.'
Father shall have periods of partial physical or residential custody of the child at the
following times:
a.)
On alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m.; and
b.)
At other times as the parties may agree.
If the Monday following Father's weekend period of custody is a holiday, Father
shall retain physical custody of the child until Monday at 6:00 p.m.
Father shall have partial physical custody of the child on Christmas Day from 2:00
p.m. until.8:00 p.m. This provision shall supersede the regular weekend custody
schedule.
The child shall always be with the Mother on Mother's Day and with Father on
Father's Day. In the event this requires an exchange of days, the parties will attempt
to accommodate each other to see that the child is with the respective parent on their
designated Mother's Day or Father's Day.
Each party shall be entitled to exercise one (I) week of vacation time during the
summer months, and agree to provide thirty (30) days advance notice to the other
party of the requested time.
The parties agree that custody exchanges shall take place at the Hampton Square.
The parties shall keep each other advised in the event of serious illness or medical
emergency concerning the child and shall further take any necessary steps to
ensure that the health and well-being of the child is protected. During such illness
or medical emergency, both parties shall have the right to visit the child as often
as he or she desires consistent with the proper medical care of the child.
10. Neither parent shall do anything which may estrange the child from the other
party, injure the opinion of the child as to the other party, or which may hamper
the free and natural development of the child's love and affection for the other
party .
11. Any modification or waiver of any of the provisions of this Agreement on a
permanent basis shall be effective only if made in writing, and only if executed
with the same formality as this Stipulation and Agreement.
12. The parties desire that this Stipulation and Agreement be made an Order of Court
of the Court of Common Pleas of Cumberland County, and further acknowledge
that the Court of Common Pleas of Cumberland County does, in fact, have
jurisdiction over the issue of custody of the parties' minor child has resided for
his entire life in Cumberland County, Pennsylvania.
13. The parties stipulate that in making this Agreement, there has been no fraud,
concealment, overreaching, coercion, or other unfair dealing on the part of the
other party.
14. The parties acknowledge that they have read and understand the provisions of this
Agreement. Each party acknowledges that the Agreement is fair and equitable
and that it is not the result of any duress or undue influence.
IN WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms
hereof, set forth their hands and seals the day and year hereinafter mentioned.
WITNESSETH:
)I!J~\LI..I<<I-'?_J YJn~:N1JQ:, hl:" ~
Date JE FERiN. PRYOR
.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
On this ~ 7-:y of bece..mber
, 2001, before me, the undersigned
officer, personally appeared JOSHUA C. PRYOR, known to me (or satisfactory proven) to be
the person whose name is subscribed to the within Agreement and acknowledged that he
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
~ ,rJ\~0 ~
~Pub1cl~
Notarial Seal
Dawn M. Baskette. No~ Public
Hanover Boro, York COunty
My Commission Expires Nov. 24', 2003
Member. Pennsylvania ASSOCiation ot Notaries
COMMONWEALTH OF PENNSYL VANIA
COUNTY OF
On this
day of
, 200 I, before me, the undersigned
officer, personally appeared JENNIFER N. PRYOR, known to me (or satisfactory proven) to be
the person whose name is subscribed to the within Agreement and acknowledged that she
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
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MAR 0 5 2002 v.--
JOSHUA C. PRYOR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO. 0;;2- q-:,\
: IN CUSTODY
JENNIFER N. PRYOR,
Defendant
QRDER OF COURT
AND NOW this III- day of
AI'I'/
, 2001, the attached Custody
Stipulation and Agreement is hereby made an Order of Court.
BY THE COURT,
.11;1
cc:
Marylou Matas, Esquire
Attorney for Plaintiff
Mark D. Schwartz, Esquire
Attorney for Defendant
-
~~
CIVIL TERM
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Paul 1. Esposito, Esquire
LD. #25454
GOLDBERG KATZMAN, P,C
320 Market Street
P. 0, Box 1268
Harrisburg, PA 17108-1268
(717)234-4161;(717)234-4161 (facsimile)
Counsel for Plaintiff
JOSHUA C. PRYOR,
Plaintiff
IN THE COURT OR COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02.&.cIVIL TERM
v.
JENNIFER N. PRYOR,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PETITION TO MODIFY ORDER OF COURT
AND NOW, Plaintiff, Joshua C. Pryor, by and through his attorneys, Goldberg Katzman,
P.C., and Paul J. Esposito, Esquire, files this Petition to Modify Order of Court, and in support
thereof, avers the following:
I. Plaintiff is Joshua C. Pryor, who currently resides at 663 Baer Avenue, Hanover,
York County, Pennsylvania.
2. Defendant is Jennifer N. Pryor, who currently resides at 170 Faith Circle, Carlisle,
Cumberland County, Pennsylvania.
3. The parties hereto are the parents of the following minor child who currently
resides with Defendant: Nicholas Franklin Charles Pryor, born May 11,2000.
4. On April I, 2001 [sic], the Honorable Kevin A. Hess entered an Order of Court,
adopting the terms of the parties' Custody Stipulation and Agreement. Copies of said Order and
Custody Stipulation and Agreement are attached hereto, made a part hereof and marked Exhibit
"A,"
5. The best interests and permanent welfare of Nicholas will be served by a
modification of the Court's aforementioned Order whereby Plaintiff's rights of partial custody
-
would be expanded and clarified to include, but not be limited to, the equal sharing of physical
custody during the summer on an alternating weekly basis, greater specificity regarding the
major holidays and Mother's Day and Father's Day and a change of location for the exchange of
physical custody.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court modify its Order
of April I , 2002, as set forth in the within Petition.
Respectfully submitted,
GOL~ER~ TZMA~ P.C.
ra:~(,~ L fJ1-L~
Paul J. 9Po . 0
Attorney 1. . #25454
320 Market Stree1
P.O. Box 1268
Harrisburg, PA 17108-1268
(717) 234-4161
Date:
(),tU( ~. I
j
,2005
Attorney for Plaintiff
. ODMAIPCDOCSIDOCSI/22270\/
3
----
VERIFICATION
I verify that the statements contained in the foregoing PETITION TO MODIFY ORDER
OF COURT are true and correct to the best of my knowledge, information and belief. I
understand that false statements contained herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
Date: 5-.;2y-or
ac~
UA C. PRYOR
JOSHUA C. PRYOR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
; NO. Od C; 70
: IN CUSTODY
CIVIL TERc\.1
JENNIFER N. PRYOR,
Defendant
QRDJ:R OF COURT
AND NOW this /-<) day of ~ pr II
, 200 I, the attached Custody
Stipulation and Agreement is hereby made an Order of Court.
BY THE COURT,
1st ~~ a ()j-A4)
J.
cc: Marylou Matas, Esquire
Attorney for Plaintiff
Mark D. Schwartz, Esquire
Attorney for Defendant
"RUE COPY FROM RECORD
In Testimony wl1sreoI, I here unto ~e1 my hand
and the ~ of said Coo at Isle.
HI (( {. G I
JOSHUA C. PRYOR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
JENNIFER N. PRYOR,
Defendant
NO.
IN CUSTODY
CIVIL TERM
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CUSTODY STIPULATION & AGREEMENT ~~ ~ '_'~~
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THIS STIPULATION AND AGREEMENT entered into the day and year ~@nafi~I seM~
:.Pc 4. -=-i
forth, by and between JOSHUA C. PRYOR, (hereinafter referred to as "Fier"~an~
JENNIFER N. PRYOR, (hereinafter referred to as "Mother").
WHEREAS, the parties are the natural parents of one child, namely NICHOLAS
FRANKLIN CHARLES PRYOR, bom May I I, 2000, (hereinafter referred to as "Child"); and
WHEREAS, the parties live separate and apart, and wish to enter into an comprehensive
stipulation and agreement relative to physical and legal custody of their Child.
NOW THEREFORE, in consideration of mutual covenants, promises and agreements as
hereinafter set forth, the parties stipulate and agree as follows:
1. Mother and Father shall have shared legal custody of the child. Each party has the
right to be exercised jointly with the other to nfake all non-emergency decisions
regarding the child, including, but not limited to, medical, education and religious
decisions.
2. Mother shall have primary physical or residential custody of the child.
3. Father shall have periods of partial physical or residential custody of the child at the
following times:
a.) On alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m.; and
b.) At other times as the parties may agree.
4. If the Monday following Father's weekend period of custody is a holiday, Father
shall retain physical custody of the child until Monday at 6:00 p.m.
5. Father shall have partial physical custody of the child on Christmas Day from 2:00
p.m. until 8:00 p.m. This provision shall supersede the regular weekend custody
schedule.
6. The child shall always be with the Mother on Mother's Day and with Father on
Father's Day. In the event this requires an exchange of days, the parties will attempt
to accommodate each other to see that the child is with the respective parent on their
designated Mother's Day or Father's Day.
7. Each party shall be entitled to exercise one (l) week of vacation time during the
summer months, and agree to provide thirty (30) days advance notice to the other
party of the requested time.
8. The parties agree that custody exchanges sball take place at the Hampton Square.
9. The parties shall keep each other advised in the event of serious illness or medical
emergency concerning the child and shall further take any necessary steps to
ensure that the health and well-being of the child is protected. During such illness
or medical emergency, both parties shall have the right to visit the child as often
as he or she desires consistent with the proper medical care of the child.
.. 10.
Neither parent shall do anything which may estrange the child from the other
party, injure the opinion of the child as to the other party,' or which may hamper
the free and natural development of the child's love and affection for the other
party.
II. Any modification or waiver of any of the provisions of this Agreement on a
permanent basis shall be effective only if made in writing, and only if executed
with the same formality as this Stipulation and Agreement.
12. The parties desire that this Stipulation and Agreement be made an Order of Court
of the Court of Common Pleas of Cumberland County, and further acknowledge
that the Court of Common Pleas of Cumberland County does, in fact, have
jurisdiction over the issue of custody of the parties' minor child has resided for
his entire life in Cumberland County, Pennsylvania.
13. The parties stipulate that in making this Agreement, there has been no fraud,
copcealment,overreaching, coercion, or other unfair dealing on the part of the
other party.
14. The parties acknowledge that they have read and understand the provisions of this
Agreement. Each party acknowledges that the Agreement is fair and equitable
and that it is not the result of any duress or undue influence.
IN WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms
hereof, set forth their hands and seals the day and year hereinafter mentioned.
WITNESSETH:
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(JfruA c. PR~R
)l!J~~\A.-';;J_#-'-/ YJ/Y~:bJJ~i./~A1 -if) rr-
Date JE E N. PRYOR
'JUl~t
Date
-.
COMMONWEALTH OF PENNSYL V ANlA
COUNTY OF
On this ~ 7-+:ayof ])eCL.rrtber
, 200 I, before me, the undersigned
officer, personally appeared JOSHUA C. PRYOR, known to me (or satisfactory proven) to be
the person whose name is subscribed to the within Agreement and acknowledged that he
executed the same for the purpose therein contained.
IN WI1NESS WHEREOF, I hereunto set my hand and official seal.
~
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----
-~-~
Notarial Seal
Dawn M. Baskette, Notary PUblic
Hanover Bora, York COunty
My Commission Expires Nov. 24, 2003
Member, Pennsylvania Assoclstion ot Notaries
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF :
On this .J't ~ay of ~ /;~
, 2001, before me, the undersigned
officer, personaliy appeared JENNIFER N. PRYOR, known to me (or satisfactory proven) to be
the person whose name is subscribed to the within Agreement and acknowledged that she
executed the same for the purpose therein contained.
IN WI1NESS WHEREOF, I hereunto set my hand and official seal.
Notarial Seal
Martha I.. Noel, Notary Public
Carlisle Bora. Cumberland Coun
My Commission Expires Sept. 18, 2
Member, Pennsyivania Association ot Notaries
CERTIFICATE OF SERVICE
! sf. (,
On this -- dayof ~ ,2005, I certify that a copy of the
- {/
foregoing was served upon the following party of record by delivering same in the manner
indicated, addressed as follows:
VIA CERTIFIED MAIL -
RETURN RECEIPT REOUESTED
Jennifer N. Pryor
170 Faith Circle
Carlisle, Pennsylvania 17013
GOLDBERG KATZMAN, P.C.
--; Jf
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/diCi1 f ,'tit Y
Paul J. osi
Supreme Co ID #25454
Attorneys for Plaintiff
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Paul J Esposito, Esquire
J.D, #25454
GOLDBERG KATZMAN, P.C
320 Market Street
P,O. Box 1268
Harrisburg,PA 17108-1268
(717)234-4161;(717)234-4161 (facsimile)
Counsel (or Plaintlfl
JOSHUA C. PRYOR,
Plaintiff
IN THE COURT OR COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02.&.cIVIL TERM
v.
JENNIFER N. PRYOR,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PETITION TO MODIFY ORDER OF COURT
AND NOW, Plaintiff, Joshua C. Pryor, by and through his attorneys, Goldberg Katzman,
P.C., and Paul J. Esposito, Esquire, files this Petition to ModifY Order of Court, and in support
thereof, avers the following:
1. Plaintiff is Joshua C. Pryor, who currently resides at 663 Baer Avenue, Hanover,
York County, Pennsylvania.
2. Defendant is Jennifer N. Pryor, who currently n~sides at 170 Faith Circle, Carlisle,
Cumberland County, Pennsylvania.
3. The parties hereto are the parents of the following minor child who currently
resides with Defendant: Nicholas Franklin Charles Pryor, born May 11,2000.
4. On April I , 200 I [sic], the Honorable Kevin A. Hess entered an Order of Court,
adopting the terms of the parties' Custody Stipulation and Agn:ement. Copies of said Order and
Custody Stipulation and Agreement are attached hereto, made a part hereof and marked Exhibit
"A,"
5. The best interests and permanent welfare of Nicholas will be served by a
modification of the Court's aforementioned Order whereby Plaintiffs rights of partial custody
---
would be expanded and clarified to include, but not be limited to, the equal sharing of physical
custody during the summer on an alternating weekly basis, gwater specificity regarding the
major holidays and Mother's Day and Father's Day and a change oflocation for the exchange of
physical custody.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court modify its Order
of April I, 2002, as set forth in the within Petition.
Respectfully submitted,
GOLplilER? TZMAN'? P.C.
/ / IF (,.,d
Iftltd;; L. tl-1.-LrfV
Paul J. 7BPo . 0
Attorney I. .#25454
320 Market Street
P.O. Box 1268
Harrisburg, P A 17108-1268
(717) 234-4161
Date:
q,(~,( t' I
//
(J
,2005
Attorney for Plaintiff
. ,ODMA IPCDOCSIDOCSII 22270\1
3
VERIFICATION
I verify that the statements contained in the foregoing PETITION TO MODIFY ORDER
OF COURT are true and correct to the best of my knowledge, information and belief. I
understand that false statements contained herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
Date: 5-.)'f-oS-
ell
UA C. PRYOR
JOSHUA C. PRYOR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
; NO. Od 970
: IN CUSTODY
CIVIL TERM
JENNIFER N. PRYOR,
Defendant
ORDER QF COURT
ANDNOWthis /..,1 dayof ^pr,1
Stipulation and Agreement is hereby made an Order of Court.
, 200 I, the attached Custody
BY THE COURT,
IsI ~J-W1 a %)
1.
cc: Marylou Matas, Esquire
Attorney for Plaintiff
Mark D. Schwartz, Esquire
Attorney for Defendant
l'RUE COPY FROM RECORD
in Testlmo~~ whereof. I here unto ~et my hand
and the seal of said Coo at Isle.
nl (/lJ, 0 I
JOSHUA C. PRYOR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
JENNIFER N. PRYOR,
Defendant
NO.
IN CUSTODY
CIVIL TERM
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CDS L ON & AGO NT;:R~ g il~;:2
TODYSTIPU ATI 0 REEME ~e N -"'2
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THIS STIPULATION AND AGREEMENT entered inl:o the day and year ~@ina~ se\;l~
"",'2" - u
~c:. .. -i
forth, by and between JOSHUA C. PRYOR, (hereinafter referred to as "Fier"~anJii
JENNIFER N. PRYOR, (hereinafter referred to as "Mother").
WHEREAS, the parties are the natural parents of one child, namely NICHOLAS
FRANKLIN CHARLES PRYOR, bom May II, 2000, (hereinafter referred to as "Child"); and
WHEREAS, the parties live separate and apart, and wish to enter into an comprehensive
stipulation and agreement relative to physical and legal custody of their Child.
NOW THEREFORE, in consideration of mutual covenants, promises and agreements as
hereinafter set forth, the parties stipulate and agree as follows:
1. Mother and Father shall have shared legal custody of the child. Each party has the
right to be exercised jointly with the other to irtake all non-emergency decisions
regarding the child, including, but not limited to, medical, education and religious
decisions.
2. Mother shall have primary physical or residential custody of the child.
3. Father shall have periods of partial physical or residential custody of the child at the
following times:
a.) On alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m.; and
b.) At other times as the parties may agree.
4. If the Monday following Father's weekend period of custody is a holiday, Father
shall retain physical custody of the child until Monday at 6:00 p.m.
5. Father shall have partial physical custody of the child on Christmas Day from 2:00
p.m. until 8:00 p.m. This provision shall supersede the regular weekend custody
schedule.
6. The child shall always be with the Mother on Mother's Day and with Father on
Father's Day. In the event this requires an exchange of days, the parties will attempt
to accommodate each other to see that the child is with the respective parent on their
designated Mother's Day or Father's Day.
7. Each party shall be entitled to exercise one (1) week of vacation time during the
summer months, and agree to provide thirty (30) days advance notice to the other
party of the requested time.
8. The parties agree that custody exchanges shall take place at the Hampton Square.
9. The parties shall keep each other advised in the event of serious illness or medical
emergency concerning the child and shall further take any necessary steps to
ensure that the health and well-being of the child is protected. During such illness
or medical emergency, both parties shall have the light to visit the child as often
as he or she desires consistent with the proper medical care of the child.
.. 10.
Neither parent shall do anything which may estra.nge the child from the other
party, injure the opinion of the child as to the other party, or which may hamper
the free and natural development of the child's love and affection for the other
party.
II. Any modification or waiver of any of the provisions of this Agreement on a
permanent basis shall be effective only if made in writing, and only if executed
with the same formality as this Stipulation and Agreement.
12. The parties desire that this Stipulation and Agreeme'nt be made an Order of Court
of the Court of Common Pleas of Cumberland County, and further acknowledge
that the Court of Common Pleas of Cumberland County does, in fact, have
jurisdiction over the issue of custody of the parties' minor child has resided for
hi~ entire life in Cumberland County, Pennsylvania.
13. The parties stipulate that in making this Agreeml:nt, there has been no fraud,
co~cealment, overreaching, coercion, or other unfair dealing on the part of the
other party.
14. The parties acknowledge that they have read and understand the provisions of this
Agreement. Each party acknowledges that the Agreement is fair and equitable
and that it is not the result of any duress or undue inHuence.
IN WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms
hereof, set forth their hands and seals the day and year hereinafter mentioned.
WITNESSETH:
UU1~tL
JiL'4{1"-.!oI} .97-0 { (Lc. J2..
Date (jfruA C~ PRyeJR
)!Heu.~.41l~\d.-'hJ_~-' ~ YJn~:bJJ(~ 4.f.Jn. M-rr-
Date JE ERiN. PRYOR
-.
'.
COMMONWEALTH OF PENNSYL VANIA
COUNTY OF
On this ~ 7.f~y of heurnber
, 2001, before me, the undersigned
officer, personally appeared JOSHUA C. PRYOR, known to me (or satisfactory proven) to be
the person whose name is subscribed to the within Agreement and acknowledged that he
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
~
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QpUb~ '
---
-~--.
Notarial Seal
Dawn M. Baskette, Notary Public
HlIJ1I!V8r Boro, York County
My Commission Expires Nov. 24, 2003
Member, Pennsylvanls Assoclatlcn cf NOlanes
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF :
On this .;l 't 1ay of ~ /;.v-z--....
, 2001, before me, the undersigned
officer, personally appeared JENNIFER N. PRYOR, known to me (or satisfactory proven) to be
the person whose name is subscribed to the within Agreement and acknowledged that she
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notarial Seal
Martha L. Noel. Notary Public
Carlisle Boro, Cumberland Coun
My Commission Expires Sep!. 18, 2
Member. Pennsylvania ASSOciation 01 Notaries
"
CERTIFICATE OF SERVICE
On this l'if day of ~., 2005, I certify that a copy of the
foregoing was served upon the following party of record by delivering same in the manner
indicated, addressed as follows:
VIA CERTIFIED MAIL -
RETURN RECEIPT REOUESTED
Jennifer N. Pryor
170 Faith Circle
Carlisle, Pennsylvania 17013
GOLDBERG KATZMAN, P.c.
;/i,i '
/ 1 e.
(N,iLL I- Ztil-1
Paul J. osi
Supreme Co it ID #25454
Attorneys for Plaintiff
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-
JOSHUA C. PRYOR
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
02-971
CIVIL ACTION LAW
JENNIFER N. PRYOR
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Wednesday, June 08, 2005
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq.
at DJ Manlove's, 1901 State St., Camp Hill, PA 17011 on Monday, July 25, 2005
, the conciliator,
at 11:00 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the 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/
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 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
HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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RECEIVED AUG 01 2005 r
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-971 CIVIL TERM
JOSHUA C. PRYOR,
v.
CIVIL ACTION - LAW
JENNIFER N. PRYOR,
IN CUSTODY
Defendant
HESS, J. m
ORDER OF COURT
AND NOW, this z,-:t- day of August, 2005, upon consideration of the Custody
Conciliation Summary Report, it is hereby ordered and directed as follows:
This Court's Order of April 1, 2001 (sic) shall remain in full force and effect with the
following modifications:
1. With regard to the 2005 Summer custodial schedule, Father shall have
custody from 6:00 p.m. Au~ust 3'd until 6:00 p.m. August ih, and from 6:00 p.m. August 14th
until 6:00 p.m. August 215. Father reserves his right to seek modifications to subsequent
Summer custodial schedules which shall be reviewed at the time of the Custody Conciliation
Conference in March 2006.
2. The custodial periods for Mother's Day and Father's Day shall be defined as
6:00 p.m. Saturday until 6:00 p.m. Sunday.
3. Christmas. The Christmas custodial schedule shall be modified as follows:
Christmas shall be divided into two segments, Segment A and Segment
B. Segment A shall be from December 24th at 6:00 p.m. until December 25th
at Noon. Segment B shall be from December 25th at Noon until December 26th
at 6:00 p.m. In 2005 and subsequent odd-numbered years, Father shall have
Segment A and Mother shall have Segment B. In 2006 and subsequent even-
numbered years, Mother shall have Segment A and Father shall have
Segment B.
4. Thanksgivinq. Father's custodial time for Thanksgiving holiday shall be from
2:00 p.m. Thanksgiving day until Black Friday at 6:00 p.m.
5. Holidavs. The following holidays shall be observed by the parent having the
preceding custodial weekend, which shall be extended until 6:00 p.m. on the holiday:
Easter, Memorial Day and Labor Day. However, neither party shall have any given holiday
weekend for more than two (2) consecutive years. In the event that that would happen, the
NO. 02-971 CIVIL TERM
parent who has not enjoyed that holiday for the two (2) previous years shall have rights of
custody on the holiday from 6:00 p.m. the day before the holiday until 6:00 p.m. on the
holiday. With regard to Independence Day, the same guidelines shall apply, however, the
custodial period for that holiday shall be from 9:00 a.m. until 9:00 p.m.
6. The parties shall meet for custodial exchanges at Smith's Grocery Store in
York Springs. In the event that either party subsequently elects to relocate such that it
would cause the relocating party to have a greater drive time for custodial exchanges, the
relocating party will be deemed to have elected to bear responsibility for the greater drive
distance without the option of asking the other parent to share in responsibility for their
decision.
7. The Custody Conciliation Conference shall reconvene on March 3, 2006,
at 9:00 a.m. at the office of the Custody Conciliator, Melissa Peel Greevy, Esquire,
1901 State Street, Camp Hill, PA 17011. It is contemplated at the time the Custody
Conciliation Conference reconvenes that parties will discuss Father's request to have
an alternating week custodial schedule commencing in Summer 2006.
BY THE COURT:
AM-
Dis!:
~tsPosito, Esquire, PO Box 1268, Harrisburg, PA 17108
VJ3ne Adams, Esquire, 117 S. Hanover Street, Carlisle, PA 17013
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-971 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
JOSHUA C. PRYOR,
v.
JENNIFER N. PRYOR,
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 child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN THE CUSTODY OF
Nicholas Franklin Charles Pryor May 11, 2000
Mother
2. Father filed a Petition to Modify Order of Court on or about June 1, 2005. A
Custody Conciliation Conference was held on July 25, 2005 with the following individuals in
attendance: the Father, Joshua C. Pryor, and his counsel, Paul J. Esposito, Esquire; the
Mother, Jennifer N. Pryor, and her counsel, Jane Adams, Esquire.
3. The parties reached an agreement for Father to have additional time this
summer, clarified the holiday schedule, and agreed to come back to Conciliation for
purposes of further discussions regarding summer custodial schedule. The parties did not
agree with regard to the custodial exchange point. The parties were informed that the
Conciliator would make a recommendation to the Court with regard to the location for
custodial exchanges.
4. Father had initially asked to change the position for custodial exchange.
However, he withdrew the request to change the location when Mother pointed out that she
was doing more than 50% share of the driving and sought to equalize the distance. Father
opposes equalizing the drive time between the parties because of Mother's decision to
move to a location more distant from where he resides.
NO. 02-971 CIVIL TERM
5. Mother's position with regard to transportation is that each of them have
relocated to different addresses since the parties' separation that the drive time
betweeo th, p,rt;~ 'h~r ,h,rod eq",I~.
Me Issa Peel Greevy, Esquire
Custody Conciliator
:255702
JOSHUA C. PRYOR,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 02-971 CIVIL TERM
v.
CIVIL ACTION - LAW
JENNIFER N. PRYOR,
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 child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN THE CUSTODY OF
Nicholas Franklin Charles Pryor May 11, 2000
Mother
2. The parties' second Custody Conciliation Conference was scheduled for
March 3, 2006, for consideration of Father's request to have an expansion of summer
custodial time, to an alternating-week schedule.
3. Father's position on custodv is as follows: Father's counsel reports that his
client had determined that he was satisfied to leave the Order as it was entered in August
2005 and that he had sent correspondence to the opposing counsel on or about February
15,2006 inquiring whether the parties might be able to cancel the Conciliation Conference.
He reports he received no response. Therefore, Father's counsel came to the Custody
Conciliation Conference. Father did not attend.
4. Mother's position on custody is as follows: Unknown. Mother's counsel did
not contact the Conciliator's office nor did she, or Mother, attend the Custody Conciliation.
5. The Conciliator and Father's counsel tried unsuccessfully to reach Mother's
counsel. Mother did not attend the Conciliation Conference. Therefore, the Conciliator
recommends that the Order of August 2, 2005 remain in full force ~.
j/gfiJp , ~. /{u/ ~
Date Melissa Peel Greevy, Esquire
Custody Conciliator
Dist: v~aul J. Esposito, Esquire. PO Box 1268, Harrisburg, PA 17108
yne Adams, ESq\U~1~ S Hanover Street, Carlisle, PA 17013
270509 ~ ~
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