HomeMy WebLinkAbout93-4051
HEIDI M. (NORECK) REGAL,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
vs.
NO. 4051 CIVIL 1993
SCOTT A. REISINGER,
Defendant/Petitioner
CIVIL ACTION - LAW
ACTION FOR CUSTODY
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the Defendant/Petitioner. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
LAWYER REFERRAL SERVICE
of the Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Telephone (800)-990-9108
HEIDI M. (NORECK) REGAL,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
vs.
NO. 4051 CIVIL 1993
SCOTT A. REISINGER,
Defendant/Petitioner
CIVIL ACTION -LAW
ACTION FOR CUSTODY
NOTICIA
USTED HA SlOO DEMANDADO/A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mas adelante en las siguientes paginas, debe to mar accion dentro de
los proximos veinte (20) dias despues de la notificacion de esta Demanda y A viso radicando
personal mente 0 por medio de un abogado una comparecencia escrita y radicando en la Corte
por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se Ie
advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede
proceder sin usted y un fallo por cualquier sum a de dinero reclamada en la demanda 0 cualquier
otra reclamacion 0 remedio solicitado por el demandante puede ser dictado en contra suya por la
Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad u olros derechos
importantes para usted.
USTED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI
USTED NO T1ENE UN ABOGADO, LLAME 0 V A Y A A LA SIGUIENTE OFICINA. ESTA
OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN
ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE
QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE
OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE
CUALlFICAN.
LAWYER REFERRAL SERVICE
of the Cumberland County Bar Association
32 South Bedford Street
Carlisle, P A 17013
Telephone (800)-990-9108
HEIDI M. (NORECK) REGAL,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLV ANIA
vs.
NO, 4051 CIVIL 1993
SCOTT A. REISINGER,
Defendant/Petitioner
CIVIL ACTION - LAW
ACTION FOR CUSTODY
EMERGENCY PETITION FOR SPECIAL RELIEF
AND NOW, comes Defendant/Petitioner, Scott A. Reisinger, by and through his counsel,
Linda A. Clotfelter, and files this Emergency Petition for Special Reiief, stating in support
thereof the following:
1. Petitioner is Scott A. Reisinger, (hereinafter referred to as "Father"), an adult
individual who currently resides at 937 Eppley Road, Mechanicsburg, Cumberland County,
Pennsylvania, 17055.
2. Respondent is Heidi M. Regal, formerly known as Heidi M. Norek, (hereinafter
referred to as "Mother") who currently resides at 128 Richland Lane, Camp Hiil, Cumberland
County, Pennsylvania, 17011.
3. The parties are the natural parents of one child, Corey D. R. Reisinger,
(hereinafter referred to as the "Chiid"), age Fifteen (15) years having been born January 22,
1991.
4. The Honorable Kevin A. Hess, had previously entered an Order of Court for
custody of the Child dated December 4, 2002. A true and correct copy of the Order of Court is
attached hereto as Exhibit "A" and is incorporated herein as if fully set forth.
5. The Order of Court provides for shared legal custody of the Child, primary
physical custody to Mother and partial physical custody to Father.
6. On Wednesday, January 25, 2006, without notice to Father and without Father's
consent or consideration for the feelings of the Child, Mother removed the Child from the
Cumberland Valley School District and enrolled the Child in the East Pennsboro School District.
7. The Child is scheduled to begin enrolment at the East Pennsboro School District
on Monday, January 30, 2006.
8. The Child, who has always attended the Cumberland Valley School District, has
been extremely upset about changing schools and is emphatic about remaining enrolled in the
Cumberland Valley School District. The Child presently attends Eagle View Middle School and
is in the eighth (8th) grade.
9. Father now seeks to have this Court enter an Emergency Order providing that the
Child shall remain enrolled in the Cumberland Valley School District and further ordering the
parties to make custodial arrangements that meet the administrative mandates of the Cumberland
Valley School District.
10. Father currently resides in the Cumberland Valley School District, and the Child
may remain enrolled in the district if the Order of Court for custody is modified.
11. Upon information and belief, the Cumberland Valley School District contacted
Mother on Monday, January 23,2006, and informed her that they recently learned of her change
of address, and they stated that the Child would be removed from the School District, effective
the end of the marking term which was Wednesday, January 25, 2006.
12. The Child had been attending the Cumberland Valley School District through
transportation facilitated by his step-father, Mike Regal, (married to Mother, but separated), who
resides at 1267 High Street, Boiling Springs, Pennsylvania 17007.
13. The Child has a Nine (9) year old one-half sibling who attends Monroe
Elementary School in the Cumberland Valley School District because the custody arrangement
for the Child's sibling provides for shared custody.
14. Upon information and belief, the Cumberland Valley School District stated that
because Mother is named in the current Order of Court as the primary custodial parent, and she
no longer resides in the Cumberland Valley School District, the Child must transfer to Mother's
school district.
15. Representatives of the Cumberland Valley School District have explained to
Father that the Child may remain in the District if the Order of Court for custody does not name
Mother as primary custodial parent, but if it states the parties have shared or joint custody.
16. Father has grave concerns for the result if the Child changes schools because the
Child has improved significantly in that he has become an "A" and "B" student, while in the past
the Child had struggled, had failing grades, and had to repeat the seventh (ih) grade.
17. Father consistently guides the Child and helps him with his school obligations.
Father also regularl y attends parent/teacher conferences regarding the Child.
18. Mother has shown no interest in the Child's education and has very limited
contact and/or involvement with his school and as a result, Mother has not attended conferences
for the Child in years.
19. Father is fearful that irreparable damage will be done to the Child because the
Child feels so strongly about not changing schools and Father sincerely feels that the best interest
of the Child would be served by modifying the custody Order such that the Child can remain in
the school district in which he is comfortable and where he has excelled.
20. Despite the Child being devastated by the upcoming change in schools, Mother
has refused to change the custody schedule such that the Child can remain enrolled in the
Cumberland Valley School District via Father's address.
21. Mother has at other times not acted in the best interest of the Child by refusing
Father custody during his scheduled times, and otherwise not complying with the directives of
the current Order of Court.
22. Because of the very limited time and the harm that the Child will suffer due to the
change in schools, Father seeks to have his Court enter an Emergency Order of Court ordering
that the Child shall remain enrolled in the Cumberland Valley School District and reversing the
current custody schedule such that Father is granted primary physical custody and Mother has
the Child alternating weekends and Tuesday and Thursday evenings until a conciliation
conference can be held, or until further order of court.
WHEREFORE, Petitioner, Scott A. Reisinger, respectfully requests that this Honorable
Court enter an Emergency Order of Court ordering that the Child shall remain enrolled in the
Cumberland Valley School District and reversing the current custody schedule such that Father
is granted primary physical custody and Mother has the Child alternating weekends and Tuesday
and Thursday evenings until a conciliation conference can be held, or until further order of court;
and granting such other relief as this Court deems just and proper.
Respectfully submitted,
LAW FIRM OF LINDA A. CLOTFELTER
Dated: January 27, 2006
By:
Li da A. Clotfelter, Esquire
C unsel for Petitioner
ttorney I.D. No. 72963
5021 East Trindle Road, Suite 100
Mechanicsburg, P A 17050
(717) 796-1930 telephone
(7] 7) 796-1933
a
VERIFICATION
I, SCOTT A. REISINGER, verify that the statements in the foregoing document 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. S 4904, relating to unsworn
falsification to authorities.
Date: /- 2 7- ()(,
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SCOTT A. REISIN. R
HEIDI MAY NORECK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
93-4051
CNIL ACTION LAW
SCOTT ALLEN REISINGER,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this If /h day of fJ J j1 P..lYY1 J H:. ,,> ) , 2002,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated July 27, 1994 is vacated and replaced with this Order.
2. The Mother, Heidi May Regel, and the Father, Scott Allen Reisinger shall have shared legal
custody of Corey Dustin Robert Reisinger, born January 22, 1991. 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 this paragraph each parent shall be entitled to all
records and information pertaining to the Child including, but not limited to, school and medical
records and information.
3. The Mother shall have primary physical custody of the Child.
4. The Father shall have partial physical custody of the Child on alternating weekends from
Friday after school through Monday morning when the Father shall provide transportation for the
Child to school. At the beginning of the Father's periods of custody on Friday, either the Father shall
pick up the Child after work at the Mother's residence or make arrangements with the Mother for the
Child to take the school bus to the Father's residence. The Father shall also have custody of the Child
every Tuesday and Thursday, when the Child shall take the bus to the Father's residence after school
through 8:00 p.m., when the Father shall transport the Child to the Mother's residence. The Father
shall ensure that all homework is completed during his periods of custody. The alternating weekend
schedule shall continue with the Father having custody during the weekend following Thanksgiving in
2002. The Father may have additional periods of custody with the Child as arranged by agreement
between the parties when the Mother is working or otherwise.
EXHIBIT
"A"
5. The parties shall share or alternate having custody of the Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which
shall run fr(,m Christmas Eve at 9:00 p.m. through Christmas Day at 12:00 noon, and Segment
B, which shall run from Christmas Day at 12:00 noon through December 26 at 12:00 noon.
The Mother shall have custody of the Child during Segment A in even numbered years and
during Segment B in odd numbered years. The Father shall have custody of the Child during
Segment A in odd numbered years and during Segment B in even numbered years. The parties
shall ensure that the Child continues to be available to participate in the Christmas Eve
celebration at the paternal grandparents' home on Christmas Eve between 5:00 p.m. and 9:00
p.m.
B, THANKSGIVING: The Father shall have custody of the Child every year for the
Thanksgivil'g holiday from Thanksgiving Day through the following Monday, with the specific
times of exchange to be arranged by agreement of the parties.
C. EASTER: The Mother shall have custody of the Child every year over the Easter
holiday from the Friday before Easter through the Monday following Easter.
D. MEMORIAL DAYfLABOR DAY: The Mother shall have custody of the Child
every year on Memorial Day and the Father shall have custody of the Child every year on
Labor Day.
E. INDEPENDENCE DAY: Each party shall have an opportunity to take the Child to
the fireworks for Independence Day each year.
F. ~I:OTHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child
every year on Mother's Day and the Father shall have custody of the Child every year on
Father's Day, with the times to be arranged by agreement of the parties.
G. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
6. The Father shall be entitled to have custody of the Child for 2 non-consecutive weeks each
summer upon providing at least 30 days advance notice to the Mother. The Mother shall be entitled to
have custody of the Child for summer vacation each year for a maximum continuous period of 2 weeks
and 3 weekends. The Mother may take the Child out of the country during her summer vacation
period and the Father shall cooperate with the requirements necessary for obtaining a passport.
7. Each party shall notify the other of all medical care the Child receives while in that parent's
care. Each parent shall notify the other immediately of medical emergencies which arise while the
Child is in that parent's care.
8. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion ofthe Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
9. This Order is entered pursuant to an agreement of the paJiies at a Custody Conciliation
Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
'2.1))'>--
1.
cc: Susan K. Candiello, Esquire - Counsel for Father
Thomas D. Gould, Esquire - Counsel for Mother
/ TRUE COpy fROM RECORD
in Test' ony whereof, I here unto set my hand
end t seal of said ourl a~e, Pa. ,
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HEIDI M, (NORECK) REGAL,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLV ANIA
vs.
NO. 4051 CIVIL 1993
SCOTT A. REISINGER,
Defendant/Petitioner
CIVIL ACTION - LAW
ACTION FOR CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this 27th day of January, 2006, the undersigned hereby certifies that a true
and correct copy of the foregoing EMERGENCY PETITION FOR SPECIAL RELIEF was
served upon the interested parties as follows:
The Honorable Kevin A. Hess
One Courthouse Square
Carlisle, PA 17013
(VIA HAND-DELIVERY)
Thomas D. Gould, Esquire
2 East Main Street
Shiremanstown, P A 17011
(VIA FACSIMILE 761-1974 ANDFIRST CLASS MAIL)
LAW FIRM OF LINDA A. CLOTFELTER
Dated: I / }, 7 /0 It?
, /
y:
Li da A. Clotfelter, Esquire
At orney ID No. 72963
21 East Trindle Road, Suite 100
Mechanicsburg, P A 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
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HEIDI M. (NORECK) REGAL,
PlaintiffIRespondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 4051 CIVIL 1993
SCOTT A. REISINGER,
DefendantIPetitioner
: CIVIL ACTION - LAW
: ACTION FOR CUSTODY
AFFIDAVIT OF SERVICE
1, Linda A. Clotfelter, Esquire, counsel for Petitioner, Scott A. Reisinger, do hereby
affirm that the original return receipt of the Emergency Petition for Special Relief and the Order
of Court scheduling a Conciliation Conference signed on February 11, 2006, sent by Certified
Mail, Restricted Delivery, Return Receipt Requested, which return receipt appears to contain the
signature of Heidi M. Regal, is set forth below. The undersigned understands that the statements
herein are made subject to the penalties of 18 P.S. S 4904 relating to unsworn falsification to
authorities.
. Complete items 1. 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to YOLl.
. Attach this card to the back of the mail piece,
or on the front jf space permits.
1. Article Addressed to:
Heidi M. Regal
12B Richland Lane
Camp HiJI, PA 170ll
I)" 13 {?( cA (o.,JJ ~. Ap+.
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3.~ice Type
ertiiied Mail ~xpress Man
. Registered etum Receipt for Merchandis
o Insured Mail C.O.D.
4. Restricted Delivery? (Extra Fee) ~ as
2. Article Number
(Transfer from service labeO
PS Form 3811, February 2004
7001 2510 0003 4439 8386
Domestic Return Receipt
10.2595-()2-M-1540
Respectfully submitted,
LAW OFFICE OF LINDA A. CLOTFELTER
Dated: ,i\ {, /.p I 0 LP
B
A. Clotfelter, Esquire
Arney lD No. 72963
5 21 East Trindle Road, Suite 100
Mechanicsburg, P A 17050
telephone (717) 796-1930
facsimile (717) 796-1933
Attorney for Petitioner
. -.
HEIDI M. (NORECK) REGAL,
PlaintiffIRespondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: NO. 4051 CIVIL 1993
SCOTT A. REISINGER,
DefendantIPetitioner
: CIVIL ACTION - LAW
: ACTION FOR CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this ~ day of February, 2006, the undersigned hereby certifies that a true
and correct copy of the foregoing AFFIDAVIT OF SERVICE was served upon the interested
paJiies as follows:
Heidi M. Regal
12 B Richland Lane
Camp Hill, PA J70ll
Dawn S. Sunday, Esquire, Conciliator
39 West Main Street
Mechanicsburg, PA 17055
Respectfully submitted,
LAW OFFICE OF LINDA A. CLOTFELTER
B
Lin a A. Clotfelter, Esquire
Arney ID No. 72963
21 East Trindle Road, Suite 100
Mechanicsburg, P A 17050
telephone (717) 796-1930
facsimile (717) 796-1933
Attorney for Petitioner
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HEIDI M. REGEL
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
93-4051
CIVIL ACTION LAW
SCOTT A. REISINGER
Defendant
IN CUSTODY
ORDER OF' COURT
AND NOW, this 3~ day of""~ , 2006, upon
consideration ofthe attached Custody Conciliation Report, it is ordered and directed as follows:
I. The prior Order of this Court dated December 4, 2002 shall continue in effect as modified by
this Order.
2. Until such time as the Mother relocates back to the Cumberland Valley School District, the
parties shall share having physical custody of the Child on an alternating four-day cycle which shall be
scheduled so that the Mother's four day periods of custody coincide with the four days when the
Mother has custody of the Child's brother, Austin. The shared custody schedule set forth in this
provision shall begin immediately to enable the Child to re-emoll in the Cumberland Valley School
District.
3. At such time as the Mother relocates within the Cumberland Valley School District, the
pmies shall resume the primary/pmial custody schedule set forth in the December 4, 2002 Order with
the exception that the Father shall also have custody of the Child on every school night, when the
Child shall take the bus to the Father's residence after school until 6:00 p.m., with the exception of
Tuesdays and Thursdays, when the Child shall remain in the Father's custody until 8:00 p.m. The
purpose of the after school arrangement is to enable the Child to complete his homework at the
Father's residence. The parties shall share responsibility for providing transportation to the Mother's
residence on weekdays at 6:00 p.m. The parties shall follow the prior schedule set forth in the
December 4,2002 Order for a period of three weeks under this provision to enable the pmies to
ascertain the Child's best interests under both the equally shared custody schedule and the
primary/partial schedule prior to the follow-up custody conciliation conference. The daily after school
periods of custody with the Father shall terminate if the December 4, 2002 schedule is still in effect at
the end of the 2005-2006 school year.
4. At such time as the Mother establishes a definite date for relocation to the Cumberland
Valley School District, counsel for either party may contact the conciliator to schedule an additional
custody conciliation conference for the purpose of reviewing the custodial arrangements after the
parties have followed both the equally shared schedule and the primary/partial schedule with daily
after school periods at the Father's residence.
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5. This Order is entered purSUaJlt to an agreement of the parties at a custody conciliation
conference.
BY THE COURT,
cc: Susan M. Kadel, Esquire - Counsel for Mother \. 2.
Linda A. Clotfelter, Esquire - Counsel for Father/ '7
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HEIDI M. REGEL
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COLNTY, PENNSYLVANIA
vs.
93-4051
CIVIL ACTION LAW
SCOTT A. REISINGER
Defendant
IN CUSTODY
Prior Judge: Kevin A. Hess
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
Corey D. R. Reisinger
January 22, 1991
Mother
2. A custody conciliation conference was held on February 28, 2006, with the following
individuals in attendance: The Mother, Heidi M. Regel, with her counsel, Susan M. Kadel, Esquire,
and the Father, Scott A. Reisinger, with his counsel, Linda A. Clotfelter, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
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Date
D~
Custody Conciliator
LAW OFFICES OF DILS & DILS
DIANE M. DILS, ESQUIRE
Attorney J.D. No. 71873
1400 North Second Street, First Floor Front
Harrisburg, P A 17102
Telephone No. (717) 232-9724
Attorney for Heidi M. Regel:
HEIDI M. REGEL,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
93-4051 CIVIL ACTION LAW
SCOTT A. REISINGER,
IN CUSTODY
PRAECIPE
TO THE PROTHONOTARY:
Please withdraw the appearance of Susan M. Kadel, Esquire, on behalf of
the Plaintiff, Heidi M. Regel, and enter the appearance of Diane M. Dils, Esquire,
on behalf of the Plaintiff, Heidi M. Regel.
Respectfully submitted, Respectfully submitted,
BY~:s~ ~~,~
James Smith Dietterick & Connelly, LLP Dils & Dils Law Office
P.O. Box 650 1400 N. Second S1., First Floor Front
Hershey, PA 17033 Harrisburg, PA 17102
(717) 533-7771 (717) 232-9724
I.D. No. 44837 J.D. No. 71873
Date:~1 jc)- It} ~
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HEIDI M. REGEL
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
93-4051
CIVIL ACTION LAW
SCOTT A. REISINGER
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 2J'1 day of F-J>.-':7 ' 2007, upon
consideration ofthe attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Orders of this Court dated December 4,2002, and March 3, 2006 are vacated and
replaced with this Order.
2. The Mother, Heidi M. Regal, and the Father, Scott Allen Reisinger, shall have shared legal
custody of Corey Dustin Robert Reisinger, born January 22, 1991. 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. Each parent shall be entitled to have equal access to all records and
information pertaining to the Child including, but not limited to, school and medical records and
information.
3. The parties shall share having physical custody of the Child on an alternating weekly basis,
with the exchange to take place each week on Sunday at 8:00 p.m.
4. The parties shall share or alternate having custody of the Child on holidays as follows:
A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run
from Christmas Eve at 9:00 p.m. through Christmas Day at 12:00 noon, and Segment B, which shall
run from Christmas Day at 12:00 noon through December 26 at 12:00 noon. The Mother shall have
custody of the Child during Segment A in odd-numbered years and during Segment Bin even-
numbered years. The Father shall have custody of the Child during Segment A in even-numbered
years and during Segment B in odd-numbered years. The parties shall ensure that the Child continues
to be available to participate in the Christmas Eve celebration at the paternal grandparents' on
Christmas Eve between 5:00 p.m. and 9:00 p.m.
B. Thanksgiving: The Father shall have custody every year for the Thanksgiving
holiday from Thanksgiving day through the following Monday with the specific times of exchange to
be arranged by agreement of the parties.
C. Easter: The Mother shall have custody of the Child every year over the Easter
holiday from the Friday before Easter through the Monday following Easter, with the specific times of
exchange to be arranged by agreement between the parties.
D. Memorial Day/Labor Day: The Mother shall have custody of the Child every year
on Memorial Day and the Father shall have custody ofthe Child every year on Labor Day.
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E. Independence Day: The Father shall be entitled to have custody ofthe Child for one
week over the July 4th holiday each summer for a vacation with extended family. In 2007, the Father
shall ensure that the Child is available for his trip to Europe by July 8.
F. Mother's DayIFather's Day: The Mother shall have custody ofthe Child every year
on Mother's Day and the Father shall have custody of the Child every year on Father's Day, with the
times to be arranged by agreement by the parties.
G. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule .
5. The Mother shall have custody of the Child for one month during the summer in 2007 for a
trip to visit the Child's relatives in Europe. The parties shall cooperate in discussing make-up time for
the Father for custodial periods missed due to the trip as arranged by agreement.
6. Each party shall ensure that the Child attends all of his regularly scheduled activities during
that party's period of custody.
7. In the event the Child's academic performance declines due to homework issues, either
party may file a request for review of the custodial schedule.
8. The Father shall be entitled to claim the Child as a dependent for income tax purposes so
long as the Father assumes responsibility for maintaining the Child's automobile insurance.
9. The parties agree that in the event either parent initiates a child support action, either party
may file a request for review of the custodial arrangements.
10. Each party shall notify the other of all medical care the Child receives while in that
parent's custody. Each parent shall notify the other immediately of medical emergencies which arise
while the Child is in that parent's care.
11. Neither party shall do or say anything which 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 a
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
12. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT, J
f',q.6k
Kevi . Hess J.
cc: Linda A. Clotfelter, Esquire - Counsel for Father
Diane M. Dils, Esquire - Counsel for Mother
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". 10.
HEIDI M. REGEL
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
93-4051
CIVIL ACTION LAW
SCOTT A. REISINGER
Defendant
IN CUSTODY
Prior Judge: Kevin A. Hess
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
Corey D. R. Reisinger
January 22, 1991
MotherlFather
2. A custody conciliation conference was held on February 9, 2007, with the following
individuals in attendance: the Mother, Heidi M. Regel, with her counsel, Diane Dils, Esquire, and the
Father Scott A. Reisinger, with his counsel, Linda Clotfelter, Esquire.
3. The parties agree to entry of an Order in the form as attached.
K6rv~
Date
/ 3. doOI
I
Da~~
Custody Conciliator
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