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Home My WebLink About06-1285 MS, TRISHA STANIFER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v, : CIVIL ACTION - LAW : IN CUSTODY ; NO, OiR ~/,2 f'S CIVIL TERM MR, STEVEN A, ARENA, Defendant. 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 prompt action, You are warned that if you fail to do so, you may lose rights of custody and visitation of your child, 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, CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, P A 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations avail 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. MS. TRISHA STANIFER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v, : CIVIL ACTION - LAW : IN CUSTODY MR, STEVEN A, ARENA, Defendant. :NO, CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Ms. Trisha Stanifer, by her attorneys, the Family Law Clinic, sets forth the following cause of action in custody. 1. The plaintiff is Ms, Trisha Stanifer, residing at 10 Kerrs Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2, The defendant is Mr, Steven Anthony Arena residing at 409 East Walnut Street, York, York County, Pennsylvania 17403, 3, Plaintiff seeks primary custody of: Name Present Residence Age Gabriel Arena 10 Kerrs Avenue Carlisle, P A 17013 19 Months The child was born out of wedlock, The child is presently in the custody of Steven A, Arena, who resides at 409 East Walnut Street, York, PA 17403. During the past five years the child has resided with the following persons at the following addresses: Persons Address Dates Steven A. Arena Trisha Gallagher 952 W. Princess Street Apt I York, PA Birth-l 1/04 Trisha Gallagher 24A South Spring Gardens St Donna Ray Gallagher Carlisle, P A Donna Gallagher 11/04- 2/05 Trisha Stanifer Zachary Stanifer Trisha Stanifer Zachary Stanifer Ronald Gallagher Jennifer Gallagher 79 Nellie Baker Rd McKee, Kentucky 40447 2/05-6/05 Kennedy Valley Road Landisburg, P A 6/05 -6/05 Trisha Stanifer Zachary Stanifer William Nailor Jessica Nailor Katlyn Nailor Tory Nailor Sierra Nailor Robin Wickard Andra Wickard Wayne Wickard Brianne (Unknown Last name) Trisha Stanifer Zachary Stanifer Diane Holly David Holly Trisha Stanifer Zachary Stanifer Sebastian Stanifer Route 75 Honey Grove, P A 6/05 -8/05 Lake Shore Drive Quincy, Va .8/05 - 10/05 10 Kerrs Ave Carlisle, P A 10/05 - present The mother of the child is Trisha Gallagher, now by marriage Stanifer. She is married, The father of the child is Steven Anthony Arena, He is single, 4, The relationship of plaintiff to the child is that of mother, The plaintiff currently resides with the following persons: Name Zachary Stanifer Sebastian Stanifer Relationship Husband Child 5, The relationship of defendant to the child is that offather. The defendant currently resides with the following persons: Name Relationship Kirsten Unknown Last Name Fiancee Three Children Kirsten's Children 6, Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court, Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth, or any other state, Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7, The best interest and permanent welfare of the child will be served by granting the relief requested because: . a, Plaintiff has been the child's primary caretaker for all of the child's life; b, Plaintiff provides the child with a stable home and environment with adequate moral, emotional, and physical surroundings as required to meet the child's needs; c, Plaintiff has permitted contact between Defendant and the child and will continue to do so; d. Plaintiff is willing to maintain custody of the child, 8, Each parent whose parental rights to the children have not been terminated and the person who has physical custody to the child have been named as parties to this action, WHEREFORE, plaintiff requests the court to grant her shared legal custody and primary physical custody of the child, with the father having periods of partial custody, Respectfully submitted, Date: 3- 7-06 /;0/ , /?' "-. ,./ ~/it_C~_K ,_,..-<_/:..:--~ "'___! Valerie J aC Certified Legal Intern THOMAS M, PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX WILLIAM G, MARTIN Supervising Attorneys THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PAl 70 13 (717) 243-2968 Fax: (717) 243-3639 ", , -" VERIFICA nON 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,C.S. 9 4904 relating to unsworn falsification to authorities, ~~i~Ji.f~f ,--.... {: MS, TRISHA STANIFER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v, : CIVIL ACTION - LAW : IN CUSTODY MR, STEVEN A, ARENA, Defendant. : NO, (j, ,- () fi:J CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Ms, Trisha Stanifer, Plaintiff, to proceed in forma pauperis, The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party, Date 3 - 7 -0 C. ..~~ Respectfully submitted, {r)-~~~ ROBERT E, RAINS THOMAS M, PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ,,------ MS. TRISHA STANIFER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN CUSTODY MR. STEVEN A. ARENA, Defendant. : NO. CIVIL TERM PETITION FOR SPECIAL RELIEF SEEKING EMERGENCY CUSTODY PURSUANT TO PA R.C.P.1915.13 AND NOW, this 7th day of March, 2006, pursuant to Rule 1915,13 of the Pennsylvania Rules of Civil Procedure, comes the Petitioner, Trisha Stanifer, by her attorneys, the Family Law Clinic, seeking emergency custody of the minor child, Gabriel Arena, born August 29,2004. In support of her Petition for Emergency Relief, Petitioner avers the following: I, The petitioner is Trisha Stanifer, an adult individual who resides at 10 Kerrs Avenue, Carlisle, Pennsylvania 17013, 2, The respondent is Steven Anthony Arena, an adult individual who resides at 409 East Walnut Street, York, Pennsylvania 17403, 3, The petitioner is the biological mother (hereinafter "Mother") of the nineteen- month-old minor child, Gabriel Arena, born August 29, 2004 (hereinafter "Child"), 4, The respondent is the biological father (hereinafter "Father") of the child. 5, The child was born out of wedlock, 6, Child resided in Cumberland County from the time of November 2004 until February 2005, and October 2005 until present, 7, Mother has been the primary caretaker of the child since his birth, 8, The parties resided together until November 2004, 9. In August 2005, Mother filed for welfare and was required to file for support against father. 10, Father is on SSI and is unable to pay support, II. Father told Mother that because she filed for support, he wanted to see the child, 12, Mother took child to Father's home in York, PA on August 29, 2005, for a visit at Father's request for four to five hours, ]3, Father did not see, nor did he request to visit the child, until February 2006, 14. The parties agreed to an informal custody arrangement such that the Father had visitation periods with the child from Sundays until Tuesdays. 15, Mother and Father also agreed that Father could visit with the child from Tuesday, February 28, 2006 until Thursday, March 2, 2006, at which time Father would return child to Mother's care at 3:00 p,m. at Mother's home, 16. Father refused to return the child to Mother's care on Thursday, March 2,2006, 17, Father informed Mother he was keeping the child for four weeks and then the parties agreed upon two weeks, 18, Mother then called 911 and requested the police officers to retrieve her child, 19, The police officers went to Father's home and requested he return the child to mother, but the Father refused to return the child, 20. Mother called Father on the telephone, and he told her that if she stayed in contact with him, then he would return the child on March 17,2006. 21. Father also agreed that Mother could visit the child as long as she called in advance, 22, Father has not spoken with Mother since Friday, 23, Mother has not been able to reach the Father by telephone; Mother has called at least four times a day and left numerous messages, 24, Mother is filing a Complaint for Custody contemporaneously with this Petition for Special Relief. 25, Mother believes and therefore avers that it is in the best interests of the minor child that Mother be granted shared legal and temporary primary physical custody of the child, pending further Order of Court, WHEREFORE, the petitioner, Trisha Stanifer, respectfully requests that this Honorable Court restore the status quo by entering an Order granting Petitioner shared legal and temporary primary physical custody of the Child, Gabriel Arena, by ordering Respondent to return the Child immediately to Petitioner, by providing that the Sheriff serve the Order on Respondent and effectuate the immediate return of the child, and by scheduling this matter for hearing or conciliation, .,;- 7-0(. Date Respectfully submitted, .~V~ Valerie 1.1at1 n Certified Legal Intern J1wJ!ik ....~ LUCY JOHNSTON-WALSH ROBERT E, RAINS THOMAS M, PLACE ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013-2899 (717) 243-2968 VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa,C.S. S4904, relating to unsworn falsification to authorities, Date: 317 Icxo . -, c TRISHA STANIFER, Plaintiff IN THE COURT OF COMMON PLEAS OF. CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW STEVEN A. ARENA, Defendant 06-1285 CIVIL TERM IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 10th day of March, 2006, after hearing on the plaintiff's Petition for Special Relief seeking emergency custody, it is hereby ordered and directed that the parents, Steven Anthony Arena and Trisha Stanifer, will have shared legal custody of the minor child, Gabriel Arena, born August 29, 2004. The parents will share physical custody of the child on the following schedule: The father shall deliver the child to the mother in Carlisle on Sunday, March 12, 2006, by 3:00 p.m. The mother shall then have custody of the child for one week until March 19, 2006, at which time she shall deliver the child to the father in York at 3:00 p.m. This schedule will then repeat itself weekly until further Order of Court after the completion of the custody conciliation hearing which is currently being scheduled. By the Court, ~-L M. L. Ebert, Jr., J. / ./William Martin, Esquire . Family Law Clinic For the Plaintiff ~even A. Arena, Defendant 409 Walnut St. York, Pa. 17403 -1 :mtf ~: 1 t\ 'i TRISHA STANIFER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-1285 CIVIL ACTION LA W STEVEN A. ARENA DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, Mareh 10,2006 ._,_, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, April II, 2006 , the conciliator, 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 if this cannot be accomplished, to dc1ine 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 pennanent 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: _/"L_JacqueJine M. VerneYt1I~~_ /~ Custody Conciliator ~. The Court of Common Pleas of Cumberland Coumy 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 arf2ngements must be made at Icast 72 hOllrs 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 Telepbone (717) 249-3166 .~ 4u?''1/iz-tJ ~ ,.m~ 4.; 7:?:/?/.r .~ ~ JPi!T7.7JW r~U, 1.;7 ,/t/ [' . 7;;1 ~ ~ ~ ./~ 'Jv.1J/ E . , " I:" '. ",:i' " , . ~ ~ ~~..' c . TRISHA STANIFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA VS. NO. 06-1285 CIVIL TERM STEVEN A. ARENA, Defendant : IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Defendant, Steven A. Arena, in the above captioned case, Respectfully submitted, Jes 'ca olst, Esquire MidPenn Legal Services 401 E, Louther Street Carlisle, PA 17013 (717) 243-9400 Date: c; c./. 001 I · . TRISHA STANIFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06-1285 CIVIL TERM STEVEN A. ARENA, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Jessica Holst, Esquire. of Mid Penn Legal Services, attorney for the Defendant. Steven A. Arena, hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: D,S, First Class Mail. Postage Pre-Paid Valerie Jackson, Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Date: l( C/ OG Je i a Holst, Esquire idPenn Legal Services 401 E, Louther Street Carlisle, PA 17013 (717) 243-9400 C~ '''--,,'' ; - ~ 1 ml -j TRISHA STANIFER, Plaintiff [1PR . E 10(6 j II '____ cy j - .,.- --_._--~:.. ~-,~;;',;. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA ~-7.-.:,-,,...;;~-,-CC~:--':-;--;\/~ ~,~=-)., v. NO. 06-1285 CIVIL ACTION - LA W STEVEN A. ARENA, Defendant IN CUSTODY COURT ORDER Gf1--- AND NOW, this ,;)4 day of April, 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No.5 of the Cumberland Count)' Courthouse on the ~ day of ~ ,2006, at J :30 ~. m. At this hearing the Father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with this Court and the opposing counsel a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called to testity on behalf of each party, and a summary of anticipated testimony of each witness. This Memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's temporary Order dated March 10, 2006 shall remain in effect. BY THE COURT, >L~~,.J~J\\ Cc: ~. Valerie Jackson . Jessica Holst, Esquire ~ l' ",' 1", {~', ':.~, ., t , ~, ~; " ,'~ '..l TRISHA STANIFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-1285 CIVIL ACTION - LAW STEVEN A. ARENA, Defendant IN CUSTODY Prior Judge: The Honorable M. L. Ebert, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Gabriel Arena, born August 29, 2004 2. A Conciliation Conference was held on April 11, 2006 with the following individuals in attendance: The Mother, Trish Stanifer, with her student attorney, Valerie Jackson of the Dickinson School of Law Family Law Clinic The Father, Steven A. Arena, with his counsel, Jessica Holst, Esquire 3. This case has a rather unique history. Apparently, the Father had not been seeing the child at all from November, 2004 through February of 2006. For some reason, the Mother then delivered custody of the child to the Father on what the Mother thought was a temporary basis. The Father thought it was a bit more than temporary. The Mother filed a Petition for Custody and a Petition for Special Relief. A short hearing was held before Judge Ebert who entered an Order dated March 10, 2006 giving custody to each party on a week onlweek off basis. 4. Father now suggests that the Mother is being investigated by Children's Services and that the Mother's home is not an appropriate environment for the child. Although Father went approximately 15 months without seeing the child at all, now Father is asserting that he should be the primary custodian and he desires a hearing on the issue. Mother is suggesting that she could live with the week on/week off arrangement on a temporary basis, but that in the long run primary custody should be returned to her because she has always been the primary custodian for the minor child. . . 5. The parties were unable to reach an agreement and the Conciliator recommends an Order in the form as attached. 6. The hearing in this case should take Y, day. Date: April I[) ,2006 CJ1.x~, >>,.iR Custody Conciliator .. TRISHA STANIFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-1285 CIVIL TERM STEVEN A. ARENA, Defendant : CUSTODY CUSTODY AGREEMENT AND ORDER AND NOW, this day of , 2006, the following Order is entered by consent of the parties with regard to custody ofthe minor child, Gabriel Arena, born August 29,2004. 1. Steven Arena, hereinafter referred to as Father, and Trisha Stanifer, hereinafter referred to as Mother, shall share legal custody of the child, Gabriel Arena. 2. Father shall have primary physical custody of Gabriel. 3. Mother shall enjoy periods of partial physical custody of Gabriel on weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. 4. The parties shall share responsibility for transportation as agreed. Mother understands that Father does not currently possess a valid driver's license and recognizes that with Father's limited access to alternative transportation, she may need to accept primary responsibility for transportation during custody exchanges. 5. Mother shall comply with any requirements set forth by Children and Youth Services that may be more stringent than the provisions in this Order. 6. The parties shall alternate the following holidays: Memorial Day, July 4, and Labor Day. Father shall start with Memorial Day in 2006. 7. The parties shall share the Easter and Thanksgiving holidays as follows. In even years, Father shall have Thanksgiving and Mother shall have Easter. In odd years, Father shall have Easter and Mother shall have Thanksgiving. 8. The Christmas holiday shall be divided into two Blocks, Block A being from December 24 at noon until December 25 at noon, and Block B being from December 25 at noon until December 26 at noon. Father shall have Block A on a yearly basis and Mother shall have Block B on a yearly basis. 9. Mother shall have custody of Gabriel on Mother's Day and Father shall have custody of Gabriel on Father's Day. 10. Mother and Father agree that each shall notify the other immediately of medical emergencies that arise while Gabriel is in that parent's care. 11. Each parent shall provide the other with a current address and telephone number. 12. Neither party shall do anything which may estrange Gabriel from the other parent, or injure Gabriel's opinion as to the other parent or which may hamper the free and natural development of Gabriel's love or respect for the other parent. Both parties shall provide Gabriel with a "safety zone" by discouraging third parties from making negative remarks about either parent when Gabriel is within earshot. 13. The parties may modify the schedule in the event they reach an agreement between themselves. Absent an agreement, the custody schedule set forth above shall control. 14. By agreement ofthe parties, the hearing scheduled for June 2, 2006, is hereby canceled. By the Court: Judge .. This Order is entered. pursuant to the consent of the parties: , '~ed Legal Intern ~(3~ a l./;h I Esq\ Robert E 'ns, Esquire Thomas M. Pla.ce, Esquire Anne MacDonald-Fox, Esquire :SUPERVISING ATTORNEYS Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 085-d v00!v00d L6t-l Steven A. Arena, Defendm1t Jessica Holst, Esquire MidPenn LeSal Services 401 East Louther Street <.;arlisle, PA 17013 (717) 243-9400 _=I'JQ~B ~:_~~EZ-51L .' .. .. This Order is entered pursuant to the consent of the parties: Trisha Stanifer, Plaintiff , Certified Legal Intern Jes 'ca ols, Esquire M' enn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 Lucy Johnston-Walsh, Esquire Robert E. Rains, Esquire Thomas M. Place, Esquire Anne MacDonald-Fox, Esquire SUPERVISING ATTORNEYS Family Law Clinic 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 -~.~. ("') c. ;;;: ...,.... ~ ..J> ,~.Jl r~:; 2"[:-'-' ..,... ci-; .'~ -~-! , ~ c..:> -.s '" C";:' <.;;;:) 0"'- :ir .:1':'::.:llI o ., 5! 171 :::n r- "T'Jrr; :00 · ) .L .::3 ~;': ,c'5'7 0;;'0 om '--I ~:>o :~1'J -< -.: N O"'l -0 =:: .. 5 . . " RECEIVED MAY 302006 1 TRISHA STANIFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-1285 CIVIL TERM STEVEN A. ARENA, Defendant : CUSTODY CUSTODY AGREEMENT AND ORDER f\~ AND NOW, this k day of 1~"t., , 2006, the following Order is entered by consent of the parties with regard to custody of the minor child, Gabriel Arena, born August 29, 2004. 1. Steven Arena, hereinafter referred to as Father, and Trisha Stanifer, hereinafter referred to as Mother, shall share legal custody of the child, Gabriel Arena. 2. Father shall have primary physical custody of Gabriel. 3. Mother shall enjoy periods of partial physical custody of Gabriel on weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. 4. The parties shall share responsibility for transportation as agreed. Mother understands that Father does not currently possess a valid driver's license and recognizes that with Father's limited access to alternative transportation, she may need to accept primary responsibility for transportation during custody exchanges. 5. Mother shall comply with any requirements set forth by Children and Youth Services that may be more stringent than the provisions in this Order. 6. The parties shall alternate the following holidays: Memorial Day, July 4, and Labor Day. Father shall start with Memorial Day in 2006. SS :2 ~\d Z- lUll qUill ^'dV10'l{IJ;.\.Odd 3\-\1 :\0 3J\~~,O-CB1\:I . . -" 7. The parties shall share the Easter and Thanksgiving holidays as follows. In even years, Father shall have Thanksgiving and Mother shall have Easter. In odd years, Father shall have Easter and Mother shall have Thanksgiving. 8. The Christmas holiday shall be divided into two Blocks, Block A being from December 24 at noon until December 25 at noon, and Block B being from December 25 at noon until December 26 at noon. Father shall have Block A on a yearly basis and Mother shall have Block B on a yearly basis. 9. Mother shall have custody of Gabriel on Mother's Day and Father shall have custody of Gabriel on Father's Day. 10. Mother and Father agree that each shall notify the other immediately of medical emergencies that arise while Gabriel is in that parent's care. 11. Each parent shall provide the other with a current address and telephone number. 12. Neither party shall do anything which may estrange Gabriel from the other parent, or injure Gabriel's opinion as to the other parent or which may hamper the free and natural development of Gabriel's love or respect for the other parent. Both parties shall provide Gabriel with a "safety zone" by discouraging third parties from making negative remarks about either parent when Gabriel is within earshot. 13. The parties may modify the schedule in the event they reach an agreement between themselves. Absent an agreement, the custody schedule set forth above shall control. 14. By agreement ofthe parties, the hearing scheduled for June 2,2006, is hereby canceled. ,lP()\c O\J BYfue~urt-t ~ ~ Judge " ..'::-W.-'/'lf."''''' . ~I,i Iv 9S :2 Irld 2- Imr" 900l AbV10NOH.LOdd 3Hl :10 3Cil:J:10-0311:l