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HomeMy WebLinkAbout06-3974 Date: 5/4/2006 Time: 02:27 PM Page 1 of 2 Dauphin County ROA Report Case: 2005-CV-2778-CU Current Judge: Lawrence F. Clark Jr. Jason S Derrickson vs. Jennifer L Brouse Date 7/6/2005 7/7/2005 7/18/2005 8/16/2005 1/23/2006 1/25/2006 2/23/2006 2/24/2006 User: LGARCIA ot. -3qtr C:i ()~tr ~ New Civil Case Filed This Date. Plaintiff: Derrickson, Jason S Attorney of Record: Barabara Sumple-Sullivan Filing: Custody Complaint Paid by: Sumple-Sullivan, Barabara (attorney No Judge for Derrickson, Jason S) Receipt number: 0083943 Dated: 7/6/2005 Amount: $221.00 (Check) Complaint in Custody, filed. Hearing scheduled for (Conference 08116/200510:00 AM) 4th Floor-Dauphin County Courthouse. See ORDER OF COURT, filed. Affidavit of service of Custody Complaint and Notice of the Custody Conciliation sheduled for August 16, 2005 at 10:00 a.m., was served upon defendant, filed The parties and their respective counsel having appeared for a custody conference on August 16, 2005 before Peter R. Henninger, Jr., Esquire, and having reached an agreement with regards to the best interest and welfare of the minor child, it is hereby ORDERED AND DECREED as follows: 1. It is the intention of the parties and the parties agree that they will have shared legal custody of Kristyn E. Derrickson (DOB 11/7/00). 2. The parties shall share physical custody of the minor child in accordance with the following schedule: See Complete ORDER, filed. Copies dist. 8-23-05 Hearing result for Conference held on 08/16/200510:00 AM: Hearing Held Peter Henninger 4th Floor-Dauphin County Courthouse. See ORDER OF COURT, filed. Filing: Custody Fee Paid by: Sumple-Sullivan, Barabara (attorney for Derrickson, Jason S) Receipt number: 0097128 Dated: 1/23/2006 Amount: $110.00 (Check) Petition for Modification of Custody Order, filed C&E in file Hearing scheduled for (Conference 02123/200610:30 AM) 4th Floor, Dauphin County Courthouse, See ORDER OF COURT, filed. Copies dist. 1-25-06 Hearing result for Conference held on 02123/200610:30 AM: Hearing Held Peter Henninger 4th Floor, Dauphin County Courthouse, See ORDER OF COURT, filed. Copies dist. 1-25-06 Conference Summary Report, filed Judge assigned to case. CustodyNisitation Judge No Judge No Judge No Judge Peter Henninger No Judge Bruce F. Bratton No Judge No Judge Peter Henninger Peter Henninger Lawrence F. Clark Jr. Date: 5/4/2006 Time: 02:27 PM Page 2 of 2 Dauphin County ROA Report Case: 2005-CV-2778-CU Current Judge: Lawrence F. Clark Jr. Jason S Derrickson vs. Jennifer L Brouse Date 2/24/2006 3/7/2006 4/12/2006 5/4/2006 User: LGARCIA CustodyNisitation Judge The parties and their respective counsel having appeared for a custody Bruce F. Bratton conference on February 23, 2006 before Peter R. Henninger, Jr., Esquire, and having reached a temporary amended agreement with regards to the best interest and welfare of the minor child, Kristyn E. Derrickson (DOB 11/7/00) it is hereby ORDERED AND DECREED as follows: THE ORDER OF AUGUST 16, 2005 IS AMENDED AS FOLLOWS; 1. Father shall have custody on Father's Day from 10:00 a.m. to 6:00 p.m. and Mother shall have custody on Mother's Day from 10:00 a.m. to 6:00 p.m. ...2. The parties agree that the child will attend Tender Years pre-school in Hershey in 2005-2006; 1/2 day Wednesday beginning at 12:30 p.m. and Mondays, Thursdays and Fridays beginning at 8:00 a.m. ...3. In all other respects, the order of August 16, 2005 shall remain in full force and effect. See ORDER filed. Copies Dist. 2-28-06. Hearing scheduled for (Conference 04/11/200610:00 AM) In Chambers, Lawrence F. Clark Jr. See ORDER, filed. Copies dist. 3-8-06 After convening a Status Conference in this matter, and after consultation Lawrence F. Clark Jr. by this Court with the Honorable Edgar B. Bayley, President Judge of the Cumberland County Court of Common Pleas, this Court has concluded that die to a change in circumstances whereby both. parties and the minor child are domiciled in Cumberland county, the interests of the parties would be best served by transferring this case to said County. Threrefore, the Prothonotary of Dauphin County IS HEREBY ORDERED to immediately transfer the above captioned matter to the Prothonotary of the Court of Common Pleas of Cumberland County. the Court further notes that President Judge Bayley has directed that upon re<;eipt of the case file by the Prothonotary of Cumberland County, that Prothonotary is to present the cile to him (Judge Bayley) for a determination of the proper stage of proceedings according to the Cumberland County protocols. see order as filed. copies distributed. The above action transferred to the Court of Common Pleas of Cumberland No Judge County. ....NO MORE ENTRIES CASE TRANSFERRED.... No Judge TOTHE COURT OF COMMON PLEAS MAY 0 4 2006 .... .~_.~--_...~_.-._._.-. .-.._._--._-....~ j il\J.i;;.., ...;., ~;~' ;~-","...("L'\.i . tn.itt ).;"ij;~\JI-:~;. l~'~~f .,l:-:: ~,i.t. ~:~, ;\ 1\ ~! . Ii' '. .~. '~,:::: ,~~_.>~:~.i.:~~;_'.,,~.,~~,J ',;,".~: ".!rr" , "'. '.. ' ,: ~ (':) ~ 1(~ ..... ~ . ~ () L D & ~ v ~ - - ~ -.:z- r 1- \ ~ L r-o o (~-; C: e.-.., '- :~ f':l - r-:> €) :c; i;;"1 \J:J , ~ . all COptLS Y'((J..J.J.~ 0 4 1111 O(j) JASON S. DERRICKSON, . . IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA Plaintiff . . JENNIFER L. BROWSE, CUSTODY ACTION LAW~ c: -0 "'O::r: "'- -;:.7- -;:.n ~o c. Z -l -< . -o~ ~ ~O:;lj .0 -t~'" :;c""'n 0-1"1 ~~ -v Sof'l'\ ;:II: ~'""o ~ ~ :; - . . V. : CIVIL ACTION - . . N Defendant 2005 CV 2778 ORDER AND NOW, to wit, this 12th day of April, 2006, after convening a Status Conference in this matter, and after consultation by this Court with the Honorable Edgar B. Bayley, President Judge of the Cumberland County Court of Common Pleas, this Court has concluded that due to a change in circumstances whereby both parties and the minor child are domiciled in Cumberland County, the interests of the parties would be best served by transferring this case to said County. Therefore, the Prothonotary of Dauphin County IS HEREBY ORDERED to immediately transfer the above captioned matter to the Prothonotary of the Court of Common Pleas of Cumberland County. The Court further notes that President Judge Bayley has directed that upon receipt of the case file by the Prothonotary of Cumberland County, that Prothonotary is to present the file to him (Judge Bayley) for a determination of the proper stage of proceedings according to the Cumberland County protocols. MAY 0 4. ?006 ! ~~'n"~J,.,,, ('''','~'hf t~1~.t ;11e. fo",:\"'o\'oo '" a I ,,'."iJ.+j_--t,;J,,) ,,,.,,,, , ~.~ \*'.. ~ IQ >~,,,.' "'''J.' (;.;-n.,,' lll<1 "r~1 .f'_"... ~'~,.1oi ~N~lA.1 ~""'1' ~, .- 'r."""4 ~_....l ' .. ! . .., fl' ':"") (", f,;,'.,."J ..:::~, ':.. " ~..-::::.:...:....L~~.~~-"'- Pru .,',:, "'" ~(;..~ rv f ,r . . . DISTRIBUTION: The Honorable Edgar B. Bayley, President Judge of the Cumberland County Court of Common Pleas, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 The Honorable Stephen E. Farina, Prothonotary of Dauphin County The Honorable Curtis R. Long, prothonotary of Cumberland County, Cumberland County Courthouse, 1 Courthouse Square, Carlisle. PA 17013 Barbara sumple.Sullivan, Esquire, 549 Bridge Street, New Cumberland, PA 17070 Scott A. Stein, Esquire, 3800 Market Street, Camp Hill, PA 17011 fILE Barbara Swnple.Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cwnberland, PA 17070 (717) 774-1445 IMAGED ~a~ 7-1-05' o JASON S. DERRICKSON, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYL VANIA v. CIVIL ACTION - CUSTODY JENNIFER L. BROUSE, Defendant : NO. -aCD5 -DJ- 0l/78~(JA ORDER OF COURT AND NOW, this 71/ 2005, upon consideration of the attached Petition for Modification, it is hereby ected at the parties and their respective counsel appear before ? E/EIt!!- II Ed /V /;V~ e;1(../ , the Custody Conference Officer, at f9:!.0~~jl/~K~~(.(6E /c, #/ day of ~~2005, at/~106fa~e-Hearing Custody c6nferenc~ such c6"~t,=='~~llt'e made to resolve the issues to be heard by the Court and to and to enter a temporary order. Children need not be present at the Conference unless their presence is requested by the Custody Conference Officer. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. ..:I >"_ -:: ;: FOR THE COURT, a: 52 % -0 L'_ ...::( x: ::J i.)..'O\--"" c:C j:::>.<{, :~~~ \"J.,'. C') (,.,.) Z >'~, '-)' r- ::::. Z ...J".I~._. ,.~\J.J '...L'..:' :5-,~:r:::.. 0- >_.l ;..:_~_ c'",,.......,, ....-" '-"'. '-, -,-' Ln = = c-I BQ~4c::~o~ ~~ Custody Conference cer .~ 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. Dauphin County Lawyer Referral Service 213-A North Front Street Harrisburg, PA 17101 (717) 232-0581 . Barbara Swnp1e-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cwnberland, P A 17070 (717) 774-1445 JASON S. DERRICKSON, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYL VANIA v. CIVIL ACTION - CUSTODY CUSTODY COMPLAINT G l> c ..,-, -u:: 1""\-' z,;;: %.c l>C c ....., = = "" 2 , I en 'U rl'r~J ;XJ~ aC:J --\-"'1 :",r:..,.....'c -:~:nC:- ,)r-q~- r~' , JENNIFER L. BROUSE, Defendant NO. ;po ::lC ...-" -, - .. -< 1. The Plaintiff is Jason S. Derrickson (hereinafter referred to as "Father"), who curWntly resides at 71 Peachy Ann Drive, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant is Jennifer L. Brouse (hereinafter referred to as "Mother"), who currently resides at 560 Willow Street, Apt. D, Highspire, Dauphin County, Pennsylvania 17034. 3. Plaintiff seeks shared legal and primary physical custody of the following child: NAME PRESENT RESIDENCE DATE OF BIRTH Kristyn E. Derrickson 560 Willow Street, Apt. D Highspire, P A November 7, 2000 4. The child is presently in the custody of Mother, who is currently residing at 560 Willow Street, Apt. D, Highspire, Pennsylvania. Since the parties' separation, Father has had custody . the child each weekend from Friday through Sunday. Since October 1, 2001, Father had physical custody of the child from Wednesdays through Sundays. On March 1,2005, after returning the child to Mother at the completion of Father's period of custody, Mother was irate because the child referred to Father's fiance as "Mother." Mother indicated to Father that he would never seethe child and, since that date, Father has not seen the child. 5. During the past five years the child has resided with the following persons at the following addresses: DATES ADDRESSES NAMES OF PERSONS IN HOUSEHOLD 11/7/2000-2/2001 80 Old Quaker Road Father, Mother, Father's Etters, P A Father, Robert Derrickson and Child. 2/2001-3/1/2002 Highland Park Apts. Father, Mother, Erica 1113 Columbus Avenue Brouse and Child Camp Hill, P A 3/1/2002-12/1/2002 Creston Apartments Mother and Child 33 Willow Penn Drive Camp Hill, P A 12/1/2002-5/1/2003 103 S. Enola Drive Mother, Joe and Child Enola, P A 5/1/2003-12/31/03 Creston Apartments Mother, Brian and Child 33 William Penn Drive Camp Hill, P A 12/31/2003-3/30/2004 71 Peachy Ann Drive Mother, Father, Child Newville, PA 3/30/2004-8/1/2004 5 Wayne Road Mother, April Mountz Camp Hill, P A and Child 8/1/2004-4/2005 560 Willow Street, Apt. D Highspire, P A Mother, Joe and Child 4/2005-Present 560 Willow Street, Apt. D Highspire, P A Mother and Child 6. The Father of the child is Jason S. Derrickson, currently residing at 71 Peachy Ann Drive, Newville, Cumberland County, Pennsylvania 17241. 7. The Mother of the child is Jennifer 1. Brouse, currently residing at 560 Willow Street, Apt. D, Highspire, Dauphin County, Pennsylvania 17034. The parties were never married to each other. 8. The relationship of the Plaintiff to the child is that of Father. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Jason S. Derrickson Self Erin C. Vathis Fiance 3 9. The relationship of the Defendant to the child is that of Mother. The Defendant currently resides with the following persons: NAME RELATIONSHIP Self Daughter Jennifer 1. Brouse Kristyn E. Derrickson 10. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 11. The Plaintiff has no information of a custody proceeding concerning the child pending in any court of this Commonwealth. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 13. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff is better able to provide a stable and loving environment for the child. Mother fails to provide for the needs of the child and to foster age appropriate learning experiences with her. Mother's work schedule prevents her from providing appropriate care for the 4 child. Mother's past behavior indicates that she is unable to foster a relationship between the child and the Plaintiff and her judgment is questionable. Father challenges mother's ability to be the primary parent of the minor child. . 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff requests the Court to grant him shared legal and primary DATE: ;l--5-6lJ Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 physical custody of the parties' child. 5 Barbara Swnple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cwnberland, P A 17070 (717) 774-1445 JASON S. DERRICKSON, Plaintiff : IN THE COURT OF COMMON PLEAS : DAUPHIN ; COUNTY, PENNSYLVANIA v. CIVIL ACTION - CUSTODY JENNIFER L. BROUSE, Defendant : NO. VERIFICATION I, Jason S. Derrickson, hereby certifY that the facts set forth in the foregoing CUSTODY COMPLAINT are true and correct to the best of my knowledge, information and belief I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: June 29,2005 ~~J. - J ON S. DERRICKSON IMAGED Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JASON S. DERRICKSON, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CJ .,.." ".- c: -, -u:" f"1:-"J z-- zc -0 'PC: ::r. c: ., ~ AFFIDAVIT OF SERVICE :.:, r:-? ~'" -< ~ I\~!/5 AZ , being duly sworn according to law, deposes and states that at . approximately /:::5~ .jJ.m. on 7 /~ /2.-005 at 5c.. cJ oJ,u__~ 57U::~ d/'r ~ #~-ui ~ I personally served Jennifer 1. Brouse, with a copy of v. CIVIL ACTION - CUSTODY ~ "'" "'" L c: r- "0 ::;{) :~:~ c ./1 ~. ~,,'"- _....- JENNIFER 1. BROUSE, Defendant NO.2005-CV-2778-CU eX> (' ".~ ' ;-":":- the Letter dated July 8, 2005, the Custody Complaint and Notice ofthe Custody Conciliation scheduled for August 16, 2005 at 10:00 a.m. I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A..4904 relating to unsworn falsification to authorities. Date: 7 II .;/c-( S}. --~~ Sworn to and subscribed before me t is 1#- day of ,2005 ~y cO:3~n;hires: I.!f:. - I ~f) I (SEAL) ,.. IMAGED Copi"lt a#6..~.d.t..~...J Date J.-a,3oS lnltlals" -{ens JASON S. DERRICKSON PLAINTIFF IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA vs. I ~ to.) w c l> c: "'0 "V:z: rt1- XX Xn l>g ~ ~ ~ AND NOW THIS 16th day of August, 2005, the parties and their respe~ve D JENNIFER L. BROUSE No. 2778 CV 2005 DEFENDANT ORDER counsel having appeared for a custody conference on August 16, 2005 before Peter R. Henninger, Jr., Esquire, and having reached an agreement with regards to the best interest and welfare of the minor child, it is hereby ORDERED AND DECREED as follows: 1. It is the intention of the parties and the parties agree that they will have shared legal custody of Kristyn E. Derrickson (DOB 11/7/00). The parties agree that major decisions concerning the child, including, but not limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other. with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency "'0 ::0 oO::ll -I..,,.., :Z:"'n 0-", xn_ 0""'< ::;:::!of"1:1 .......,0 ::0 -< , .) decisions which must be made, the party having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent pursuant to 23 Pa.C.S. 5309. 2. The parties shall share physical custody of the minor child in accordance with the following schedule: (a) Father shall have physical custody from Wednesday, August 17, 2005 at 4:30 p.m. or after school until Sunday, August 21, 2005 at noon. (b) Mother shall have physical custody from Sunday, August 21, 2005 at noon until Thursday, August 25, 2005 at 4:30 p.m. or after school. (c) Father shall have physical custody from Thursday, August 25, 2005 at 4:30 p.m. or after school until Sunday, August 28,2005 at noon. (d) Mother shall have physical custody from Sunday, August 28, 2005 at noon until Wednesday, August 31,2005 at 4:30 p.m. or after school. (e) The schedule set forth in (a) through (d) shall then repeat. 3. The parties will alternate the following major holidays: Easter, Memorial Day, Fourth of July, Labor Day, and New Year's Day. The custodial period shall run from 10:00 a.m. until 6:00 p.m. This schedule will begin with Father having the child on Labor Day in 2005. 4. Thanksgiving will be divided into two (2) segments. Segment A shall be from 10:00 a.m. on Thanksgiving Day until 6:00 p.m. the day after Thanksgiving Day. Segment B shall be from 6:00 p.m. the day after Thanksgiving Day until 6:00 p.m. the following day. This schedule will begin with Mother having Thanksgiving in 2005 and shall alternate thereafter. 5. Christmas will be divided into two segments. Segment A is from December 24th at 10:00 a.m. until December 25th at 2:00 p.m. Segment B is from December 25th at 2:00 p.m. until December 26th at 6:00 p.m. This schedule will begin with Mother having the child for Segment A in 2005 and shall alternate thereafter. 6. Father shall have custody on Father's Day from 10:00 a.m. until 6:00 p.m. and Mother shall have custody on Mother's Day from 10:00 a.m. 7. Beginning in 2006, both parties are entitled to two (2) week(s) of uninterrupted custody during the summer. It is understood that a week is defined as seven (7) days, which must include the party's regularly scheduled custodial weekend. Each party shall provide the other with thirty (30) days notice of his/her intention to exercise the extended custody period. 8. The holiday schedule shall take precedence over the regular custody schedule. 9. Should either party be unavailable to care for the child during their custodial period, the other party will have the right of first refusal to care for the child. 10. During any period of custody or visitation, the parties to this order shall not possess or use controlled substances or consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or houseguests comply with this prohibition. 11. Neither party will smoke cigarettes or tobacco products nor allow others to smoke in the presence of the child. . 12. Each party shall be entitled to reasonable telephone or e-mail contact with the child when she is in the custody of the other party. The parties shall provide to one another an emergency contact telephone number, e-mail address or contact person. 13. Neither party shall relocate from a current address if such relocation will necessitate a change in the custody schedule as set forth in this Order, or if the relocation will be to a location in excess of fifty (50) miles from the other party's then- current address without (a) such party's first giving prior written notice to the other party not less than sixty (60) days prior to the planned relocation, and (b) either written consent of the other party to such relocation or further Order of this Court. In the event of any intended relocation, either party may seek modification of the terms of this custody Order by filing a Petition to Modify Custody with the Prothonotary. 14. The parties shall refrain from making derogatory comments about the other party in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. 15. It is understood and stipulated by the parties that upon mutual agreement an expanded or altered schedule may be agreed upon between the parties and that such mutual agreement would be in the best interests of the child. 16. The transportation will be shared as follows: If the child is not in school, the transfer point shall be the Wal-Mart on the Carlisle Pike in Cumberland County or at some other mutually agreeable point. Otherwise, the child is to be picked up at school. 17. The parties agree that the child will attend Mulberry School in 2005-2006 from Wednesday through Friday and that the parent with physical custody will be responsible to see that the child is at school between 7:00 a.m. and 8:00 a.m. on those days. / ~ Bruce F. Bratton, Judge DISTRIBUTION: Barbara Sumple-Sullivan, Esquire, 549 Bridge Street, New Cumberland, PA 17070 T. Korey Leslie, Esquire, 2411 North Front Street, Harrisburg, PA Barbara Swnp1e-Sullivan, Esquire I MAG E D Supreme Court #32317 549 Bridge Street New Cwnberland, P A 17070 (717) 774-1445 ~tJfiw U . l~o/OCI o v. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYL V ANlA .. ~ = "" CIVIL ACTION - CUSTODY '- ,. :z: N (J'I JASON S. DERRICKSON, Plaintiff JENNIFER L. BROUSE, Defendant NO. 2778 CV 2005 2:>> :x 1.0 .. VI ~ 006, upon consideration of the -0<- /"'11,:::" z::::: Zn >6 c:: :z -< -< (':)0'..,.., :'":!-r,i" ; ':~ -rr \;. ~;::;0' o/"'l1<. >0/"'l1 ;::0...,,0 -< AND NOW, this ORDER OF COURT diSH day 0 attached Petition for Modification, it is hereb Irected that t e parties and their respective counsel .t> /H.A Y' tf; Iv' c.ou f?:;t appear before Peter R. Henninger. Jr.. the Custody Conference Officer, at(l,'ll~ ~~. on _'7 ItJ/&o 1f1YJ ~-abJ/ /9 the t?'(..a.eJ:> day of!ENdvr06, at _.M., for a Pre-Hearing Custo y 0 erence.4{t such conference, an effort will be made to resolve the issues to be heard by the Court and to and to enter a temporary order. Children need not be present at the Conference unless their presence is requested by the Custody Conference Officer. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, B~~D4~~~ ustody Conrerence 0 ~tf ,? 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. Dauphin County Lawyer Referral Service 213-A North Front Street Harrisburg, PA 17101 (717) 232-0581 Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 JASON S. DERRICKSON, Plaintiff v. : CIVIL ACTION -IN CUSTQpy ~ 't'"' a"'a " c..... C ". :'O!~ JENNIFER L. BROUSE, Defendant : No. 2778 CV 2005 ;~-"'" I~,:'" . - ~ -, -,,~ PETITION FOR MODIFICATION OF CUSTODY ORDER 1. Petitioner is Jason S. Derrickson, an individual residing at 71 Peachy Ann Drive, Newville, Cumberland County, Pennsylvania 17241. 2. Respondent is Jennifer L. Brouse, an individual allegedly continuing to reside at 560 Willow Street, Apt. D, Highspire, Dauphin County, Pennsylvania 17034. However, Petitioner believes she may be evicted. (Service of this Petition is also being made on her attorney of record. ) 3. Petitioner seeks to amend the current custody order and gain primary physical custody ofthe following child: ADDRESS DOB NAME Kristyn E. Derrickson 560 Willow Street, Apt. D Highspire, P A and 71 Peachy Ann Drive Newville, P A 111712000 The child is currently in the shared physical custody of Mother and Father. Mother and Father reside at the addresses referenced above. During the last five years, the child has resided with the following persons and at the following addresses: PERSONS ADDRESSES DATES 11/7/2000-2/200 I 80 Old Quaker Road Father, Mother, Father's Etters, P A Father, Robert Derrickson and Child. 2/2001-3/1/2002 Highland Park Apts. Father, Mother, Erica 1113 Columbus Avenue Brouse and Child Camp Hill, P A 3/1/2002-12/1/2002 Creston Apartments Mother and Child 33 Willow Penn Drive Camp Hill, P A 12/1/2002-5/1/2003 103 S. Enola Drive Mother, Joe and Child Enola, P A 5/1/2003-12/31/03 Creston Apartments Mother, Brian and Child 33 William Penn Drive Camp Hill, P A 12/31/2003-3/30/2004 71 Peachy Ann Drive Mother, Father, Child Newville, PA 3/30/2004-8/1/2004 5 Wayne Road Mother, April Mountz Camp Hill, PA and Child 8/1/2004-4/2005 560 Willow Street, Apt. D Mother, Joe and Child Highspire, P A 4/2005-8/16/05 560 Willow Street, Apt. D Mother and Child Highspire, P A 2 8/16/06-present 560 Willow Street, Apt. D Highspire, P A and an undisclosed address in Carlisle, P A and 71 Peachy Ann Drive Newville, P A 17241 Mother and Child Father, Aryn Vathis and Child The Mother ofthe child is Jennifer L. Brouse, currently residing at 560 Willow Street, Apt. D, Highspire, Dauphin County, Pennsylvania. The Father ofthe child is Jason S. Derrickson, currently residing at 71 Peachy Ann Drive, Newville, Cumberland County, Pennsylvania. The parties were never married. 4. The relationship of the Petitioner to the child is that of Father. The Petitioner currently resides with the child. 5. The relationship of the Respondent to the child is that of Mother. The Respondent currently resides with the child. It is believed that Mother also currently resides with persons whom she is not related to, including Joe (a cab driver), his wife Sue and four (4) children. 6. Petitioner and Respondent had previously participated in a custody proceeding in this Court. A copy of the Custody Order and Agreement dated August 16, 2005, is attached hereto as 3 Exhibit "N' and incorporated herein by reference. 7. Petitioner has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 8. Petitioner does not know ofa person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 9. The best interest and permanent welfare of the child will be served by granting the relief requested because Mother has been unable to provide a stable and appropriate home for the child. It is believed that she has been evicted from her Highspire residence listed above and has relocated to Carlisle, Cumberland County, where she is living with unrelated persons in an environment that is not enjoyed by the child. Mother has failed to follow the Order relating to daycare. Plaintiff continues to have concerns about Mother's physical care and supervision ofthe child, and her general ability to parent. Mother has failed to keep him notified of her living arrangements and circumstances. Dated: January 20, 2006 arbara Sumple-Sullivan, Esquire Attorney for Petitioner 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. No. 32317 4 EXHIBIT "A" JASON S. DERRICKSON PLAINTIFF IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA JENNIFER L. BROUSE ~ I c:: ,," ",,3: z:Z: :z:(") >0 c:: :z: -i -< - AND NOW THIS 16th day of August, 2005, the parties and their respectiveO vs. No. 2778 CV 2005 "'\) ::u 00::0 -i"'T1,." :t:""tn 0(=;,." :z:",- ~ 0 < :z ~Ol""l SS ;o"TIO -< - a=i ~ Co) DEFENDANT ORDER counsel having appeared for a custody conference on August 16, 2005 before Peter R. Henninger, Jr., Esquire, and having reached an agreement with regards to the best interest and welfare of the minor child, it is hereby ORDERED AND. DECREED as follows: 1. It is the intention of the parties and the parties agree that they will have shared legal custody of Kristyn E. Derrickson (DOB 11/7/00). The parties agree that major decisions concerning the child, including, but not limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which must be made, the party having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent pursuant to 23 Pa.C.S. 5309. 2. The parties shall share physical custody of the minor child in accordance with the following schedule: (a) Father shall have physical custody from Wednesday, August 17, 2005 at 4:30 p.m. or after school until Sunday, August 21,2005 at noon. (b) Mother shall have physical custody from Sunday, August 21, 2005 at noon until Thursday, August 25, 2005 at 4:30 p.m. or after school. (c) Father shall have physical custody from Thursday, August 25, 2005 at 4:30 p.m. or after school until Sunday, August 28, 2005 at noon. (d) Mother shall have physical custody from Sunday, August 28, 2005 at noon until Wednesday, August 31,2005 at 4:30 p.m. or after school. (e) The schedule set forth in (a) through (d) shall then repeat. 3. The parties will altemate the following major holidays: Easter, Memorial Day, Fourth of July, Labor Day, and New Year's Day. The custodial period shall run from 10:00 a.m. until 6:00 p.m. This schedule will begin with Father having the child on Labor Day in 2005. 4. Thanksgiving will be divided into two (2) segments. Segment A shall be from 10:00 a.m. on Thanksgiving Day until 6:00 p.m. the day after Thanksgiving Day. Segment B shall be from 6:00 p.m. the day after Thanksgiving Day until 6:00 p.m. the following day. This schedule will begin with Mother having Thanksgiving in 2005 and shall alternate thereafter. 5. Christmas will be divided into two segments. Segment A is from December 24th at 10:00 a.m. until December 25th at 2:00 p.m. Segment B is from December 25th at 2:00 p.m. until December 26th at 6:00 p.m. This schedule will begin with Mother having the child for Segment A in 2005 and shall alternate thereafter. 6. Father shall have custody on Father's Day from 10:00 a.m. until 6:00 p.m. and Mother shall have custody on Mother's Day from 10:00 a.m. 7. Beginning in 2006, both parties are entitled to two (2) week(s) of uninterrupted custody during the summer. It is understood that a week is defined as seven (7) days, which must include the party's regular1y scheduled custodial weekend. Each party shall provide the other with thirty (30) days notice of his/her intention to exercise the extended custody period. 8. The holiday schedule shall take precedence over the regular custody schedule. 9. Should either party be unavailable to care for the child during their custodial period, the other party will have the right of first refusal to care for the child. 10. During any period of custody or visitation, the parties to this order shall not possess or use controlled substances or consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible. that other household members and/or houseguests comply with this prohibition. 11. Neither party will smoke cigarettes or tobacco products nor allow others to smoke in the presence of the child. 12. Each party shall be entitled to reasonable telephone or e-mail contact with the child when she is in the custody of the other party. The parties shall provide to one another an emergency contact telephone number, e-mail address or contact person. 13. Neither party shall relocate from a current address if such relocation will necessitate a change in the custody schedule as set forth in this Order, or if the relocation will be to a location in excess of fifty (50) miles from the other party's then- current address without (a) such party's first giving prior written notice to the other party not less than sixty (60) days prior to the planned relocation, and (b) either written consent of the other party to such relocation or further Order of this Court. In the event of any intended relocation, either party may seek modification of the terms of this custody Order by filing a Petition to Modify Custody with the Prothonotary. 14. The parties shall refrain from making derogatory comments about the other party in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. 15. It is understood and stipulated by the parties that upon mutual agreement an expanded or altered schedule may be agreed upon between the parties and that such mutual agreement would be in the best interests of the child. 16. The transportation will be shared as follows: If the child is not in school, the transfer point shall be the Wal-Mart on the Carlisle Pike in Cumberland County or at some other mutually agreeable point. Otherwise, the child is to be picked up at school. 17. The parties agree that the child will attend Mulberry School in 2005-2006 from Wednesday through Friday and that the parent with physical custody will be responsible to see that the child is at school between 7:00 a.m. and 8:00 a.m. on those days. .-/ DISTRIBUTION: Barbara Sumple-Sullivan. Esquire, 549 Bridge Street, New Cumberland, PA 17070 T. Korey Leslie, Esquire, 2411 North Front Street, Harrisburg, PA AU6 2 3 2005 ~8l': cartlfy !hat !he foragoing isa .. -lr-. ~~ . ""0 notary . I/JtvLOJ Barbara SumpJe-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JASON S. DERRICKSON, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA v. CIVIL ACTION - CUSTODY JENNIFER L. BROUSE, Defendant : NO. 2005-CV-2778-CU VERIFICATION I, Jason S. Derrickson, hereby certify that the facts set forth in the foregoing Petition for Modification of Custody Order, are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. DATED: January 18 ,2006 c;~ ason S. Derric on Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA JASON S. DERRICKSON, Plaintiff v. : CIVIL ACTION -IN CUSTODY JENNIFER L. BROUSE, Defendant : No. 2778 CV 2005 CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certity that on this date, I served a true and correct copy of the PETITION FOR MODIFICA nON OF CUSTODY ORDER, in the above- captioned matter upon the following individual, by United States first-class mail, postage prepaid, addressed as follows: Ms. Jennifer L. Brouse 560 Willow Street, Apt. D Highspire, P A 17034 Barbara Sumple-Sullivan, Esquire Attorney for Petitioner 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 DATE: January 20, 2006 r ^ .~~ r Y. ~~ /I..i.#~ IMAGED ~ v. IN THE COURT OF, COMMON Pf..EA~ DAUPHIN COUNTY, PENNSYLVANI.te; -0,. ;:::J rr, -.," ......., NO. 2778 CV 2005 :-:e:';;: '" ~f'- .c:- ;c.' JASON S. DERRICKSON, Plaintiff JENNIFER L. BROWSE, Defendant CIVIL ACTION - LAW CUSTODY -I -< -0 ::l1: ~ ~; n~...... ;;:) 'v ':':;0.-,.. ""' ~'-,., ....- 1;:;] h ,:J rr"j ~ :-T 0 r1"~ .::;:"110 ~ -< - .",.. CONFERENCE SUMMARY REPORT 1. The partiel;;' requests: Plaintiff is requesting primary physical custody from Monday through Friday with Mother having alternating weekends. Mother is OK with present schedule but requests primary physical especially sinCe the child will go to kindergarten in the fall of 2006. 2. The Plaintiff has appeared at the Conference. The Attorney for Plaintiff is: Barbara Sumple-Sullivan, Esquire,. Plaintiff's address is 71 Peachy Ann Drive, Newville, PA 17241. 3. The Defendant has appeared at the Conference. The Attorney for Defendant is: Scott A. Stein, Esquire:. Defendant's address is 232 West Simpson Street, Mechanicsburg, PA 17050. 4. If either party has not previously attended the Seminar for Separating Families, they are directed to do so by contacting InterWorks at (717) 236-6630. 5. The Conference was held on February 23, 2006. 6. The child is Kristyn E. Derrickson (DOB 11/7/00'). 7. Witnesses, lay and expert: Plaintiff: Witness list shall be exchanged 10 days before the hearing. Defendant: Witness list shall be exchanged 10 days before the hearing. 8. The hearing is expected to take eight (8) hours. 9. Independent counsel should not be appointed for the child. ...... 10. Any Reports from appropriate agencies/experts: None expected although Father may pursue a custody evaluation. 11. Present status of Custody and/or Visitation: Shared legal, shared physical, Sunday-Wednesday; Sunday-Thursday. 12. Reports from agencies/experts/home studies recommended by Conference Officer: Counsel and conference officer believe case would benefit from an evaluation but money is an issue. Father will pursue therapuetic family counseling if covered by insurance to some extent and Mother will participate. 13. Issues for resolution and other additional relevant information: 1. Primary physical custody; 2. Right of first refusal on weekends when Mother is working; 3. School in the fall. Father alleges Mother lost a job at Sierra Madre for smoking pot out back; and that her car was repossessed and she was evicted from her apartment and alleges that she is too unstable to share custody at this time. Mother alleges that without her consent, Father changed the child's school and changed dates and times at Thanksgiving and Christmas without her consent and cannot be trusted to follow the order, will not let her call when he has custody, etc. Dated: February 24, 2006 Peter R. Henninger, Jr., Esquire Conference Officer DISTRIBUTION: Barbara Sumple-Sullivan, Esquire, 549 Bridge Street, New Cumberland, PA 17070 Scott A. Stein, Esquire, 3800 Market Street, Camp Hill, PA 17011 . rV"j\GED ~ ..... .,,\ Copies D. i.,s:r f.).ld r91cu Date 'a ~ Illi'ia!;; JASON S. DERRICKSON PLAINTIFF IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA ::.:.:~ '" ..., = = "'" " n"I ro N co :>00 -, - vs. JENNIFER L. BROWSE DEFENDANT No. 2778 CV 2005 "'C)"I' ~f-' ;:'t: (--~; ,... . ........-- ....".. ~ -...., -< '!? ORDER 0'1 AND NOW THIS 24th day of February, 2006, the parties and their respective counsel having appeared for a custody conference on February 23, 2006 before Peter R. Henninger, Jr., Esquire, and having reached a temporary amended agreement with regards to the best interest and welfare of the minor child, Kristyn E. Derrickson (DOB 11/7/00) it is hereby ORDERED AND DECREED as follows: THE ORDER OF AUGUST 16, 2005 IS AMENDED AS FOllOWS: 1. Father shall have custody on Father's Day from 10:00 a.m. to 6:00 p.m. and Mother shall have custody on Mother's Day from 10:00 a.m. to 6:00 p.m. 2. The parties agree that the child will attend Tender Years pre-school in Hershey in 2005-2006; y, day Wednesday beginning at 12:30 p.m. and Mondays, Thursdays and Fridays beginning at 8:00 a.m. 3. In all other respects, the order of August 16, 2005 shall remain in full force and effect. -......., -- ."........ ~~ ~72 ,:-:f ' ~~ -.') ,'-'. ~,)-,~ ^ ;1....>:;0 ;~3i"";'j< :-1 r-; m .:>." 0 :u -< t,," .... BY THE COURT: if iUI-- Bruce F. Bratton, Judge DISTRIBUTION: Barbara Sumple-Sullivan, Esquire, 549 Bridge Street, New Cumberland, PA 17070 Scott A. Stein, Esquire, 3800 Market Street, Camp Hill, PA 17011 --. ,... Dllle CIJIerriq ~ IMAGED ~ cf1uJ-- 3/iY/O{' JASON S. DERRICKSON, Plaintiff . . IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. . . . . JENNIFER L. BROWSE, Defendant . . NO. 2778 CV 2005 c );, c:: .'_,n. '" g .... :x ~ ::u J co '''':) AJ :r>o :x C5 AND NOW, to wit, this 7th day of March, 2006, IT is ~E&Y ..... ORDERED that a Custody Conference in the above captioned matter is scheduled for Tuesday, Ap..il 11, 2006 at 10:00 A.M., in Chambe..s, of the Dauphin County Cou..t House, F..ont and Ma..ket St..eets, Ha....isbu..g, pennsylvania. ORDER -0- f'1'1' ::: ",,-(- ,",co'-( ...~., ""-.. ~... ~".,..... -.-; ""1 ::.:~. " ._.~, I~-' BY THE COURT: Judge DISTRIBUTION: Barbara Sumple-Sullivan, Esquire, 549 Bridge Street, New Cumberland, PA 17070 Scott A. Stein, Esquire, 3800 Market Street, Camp Hill, PA 17011 FILE ... ~4..\ ~~ . "./\GED .. . ~' JASON S. DERRICKSON, , Plaintiff IN THE COURT OF COMMON PE.EA~ DAUPHIN COUNTY, PENNSYL\(ANI.Je;' ""V'", f"'7i rn ::. co NO. 2778 CV 2005 ::1:::;- '" ~r-' ~ Pc:; v. JENNIFER L. BROWSE. Defendant -0 :r <.:l " CIVIL ACTION - LAW CUSTODY ~ -< -< - .c- CONFERENCE SUMMARY REPORT 1 . The parties' requests: Plaintiff is requesting primary physical custody from Monday through Friday with Mother having alternating weekends. Mother is OK with present schedule but requests primary physical especially since the child will go to kindergarten in the fall of 2006. 2. The Plaintiff has appeared at the Conference. The Attorney for Plaintiff is: Barbara Sumple-Sullivan, Esquire. Plaintiff's address is 71 Peachy Ann Drive, Newville, PA 17241. 3. The Defendant has appeared at the Conference. The Attorney for Defendant is: Scott A. Stein, Esquire. Defendant's address is 232 West Simpson Street, Mechanicsburg, PA 17050. 4. If either party has not previously attended the Seminar for Separating Families, they are directed to do so by contacting InterWorks at (717) 236-6630. 5. The Conference was held on February 23, 2006. 6. The child is Kristyn E. Derrickson (DOB 11/7/00). 7. Witnesses, lay and expert: Plaintiff: Witness list shall be exchanged 10 days before the hearing. Defendant: Witness list shall be exchanged 10 days before the hearing. 8. The hearing is expected to take eight (8) hours. 9. Independent counsel should not be appointed for the child. -~ ~:; Il/r (~) c::, ~~'_ :~~~~',~ D~=2 :;Jor;; ::::11t:.) --v -< , . 10. Any Reports from appropriate agencies/experts: None expected although Father may pursue a custody evaluation. 11. Present status of Custody and/or Visitation: Shared legal, shared physical, Sunday-Wednesday; Sunday-Thursday. 12. Reports from agencies/experts/home studies recommended by Conference Officer: Counsel and conference officer believe case would benefit from an evaluation but money is an issue. Father will pursue therapuetic family counseling if covered by insurance to some extent and Mother will participate. 13. Issues for resolution and other additional relevant information: 1. Primary physical custody; 2. Right of first refusal on weekends when Mother is working; 3. School in the fall. Father alleges Mother lost a job at Sierra Madre for smoking pot out back; and that her car was repossessed and she was evicted from her apartment and alleges that she is too unstable to share custody at this time. Mother alleges that without her consent, Father changed the child's school and changed dates and times at Thanksgiving and Christmas without her consent and cannot be trusted to follow the order, will not let her call when he has custody, etc. Dated: February 24, 2006 Peter R. Henninger, Jr., Esquire Conference Officer DISTRIBUTION: Barbara Sumple-Sullivan, Esquire, 549 Bridge Street, New Cumberland, PA 17070 Scott A. Stein, Esquire, 3800 Market Street, Camp Hill, PA 17011 JASON S. DERRICKSON, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. JENNIFER L. BROWSE, DEFENDANT : 06-3974 CIVIL TERM ORDER OF COURT AND NOW, this ~tt day of July. 2006, IT IS ORDERED that a custody hearing on the merits shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania, on Thursday, August 17, 2006, at 8:45 a.m. ~rbara Sumple-Sullivan, Esquire For Plaintiff ~cott A. Stein, Esquire For Defendant :sal r\,DV 0:\ o Court Administrator '. LS AtJ\i.LC :Dl \1';"1 1_ I Iii grDZ . , ~ :10 " - Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JASON S. DERRICKSON, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -IN CUSTODY JENNIFER 1. BROUSE, Defendant : No. 06-3974 AFFIDAVIT OF SERVICE 1, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of a Subpoena to Attend and Testify at a Custody Hearing in the above captioned matter which is scheduled for August 17, 2006 at 8:45 a.m., United States Mail, Certified Delivery, Certified No. 7005 1820 00027613 2501, Return Receipt Requested, on Sharon 1. Brouse on August 9, 2006 at Ms. Brouse's last known address: 3642 Route 249, Westfield, PA 16950. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. Dated: August 11,2006 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070-1931 (717)-774-1445 Supreme Court 10 #32317 Attorney for Plaintiff , - .." r),)~, I I I" ,( I flT"'C 1\ '1AIt Hl:, If! . mestlc Mall Only No Int;UrdrJlf' Co~"r 'gf' P'f'. ,~(' (I ..... Cl .., I\l m ..... ..D l'- ......... . ~... I\l C C C --... p'...IflIIIl~ C __... ru ......._..It ReqLnd) CI ..... -'_'FeM $ LI1 C C l'- $0.63 n.~ U.85 $0.00 $4.88 -" .. e&MfOfl L. .~. 3lo~~ l<ouJre. ~L/q W~~ fA J{~/150 .. ;:t.r..uw" L ........I!' 1. "l J.~'" :s.__1P .~.... C....,..MoI C - _ I C ....1IIaIIpl1Dr r.h..,. C __ Mol C c.o.o. 4. .......11 .-,ttElRI'WI C. 7DDS 18CO ODOe 7~13 cSDl .....- ....... .... EXHIBIT "A" (} <; .,.,. o ti}~ \\ "., 1~ ~ ~~ ~ :'f,Q Ii'" qb ~""t'\ -0 ~~? ~ ~ :;;;; rI' .~:-~ Cot? "1;;- o '-~ (0 . . JASON S. DERRICKSON, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. JENNIFER L. BROWSE, DEFENDANT 06-3974 CIVIL TERM ORDER OF COURT AND NOW, this CR day of August, 2006, following a hearing on the merits, IT IS ORDERED: (1) The custody order of August 16, 2005, is vacated as of August 28,2006. (2) Jason S. Derrickson and Jennifer L. Browse shall have shared legal custody of their daughter, Kristyn Derrickson. bom November 7, 2000. (3) During the school year, the father shall have primary physical custody of Kristyn. (4) The mother shall have the following periods of temporary physical custody when Kristyn is in kindergarten: (i) Every three out of four weekends from Saturday at 6:30 p.m. until two hours before the beginning of kindergarten on Monday afternoon. The first such weekend shall begin on the second Saturday after Kristyn starts school. The father shall deliver Kristyn to the mother at the Wal-Mart on the Carlisle Pike in Cumberland County. The mother shall return Kristyn to the father's home. (ii) On a weekday following the weekends the father has Kristyn, on a day the mother is not working from after kindergarten until 8:00 p.m. The mother shall notify the father of the weekday she chooses not later than the Saturday . . before. The mother shall pickup Kristyn at the father's home unless she is allowed to pick her up at school. She shall return Kristyn to the father's home. (4) When Kristyn starts first grade, the mother shall have her every other weekend from Friday at 6:00 p.m. until Sunday at 8:00 p.m. with exchanges at the Wal- Mart. (5) During each summer school vacation period starting in 2007, the mother shall have Kristyn every two out of three weeks with exchanges at the Wal-Mart on Sundays at 6:00 p.m. The mother's first two continuous week period shall commence on the first Sunday after the end of the school year. (6) Holiday schedule with exchanges at the Wal-Mart: (i) The parents shall alternate Memorial Day, Thanksgiving and New Year's Day. The mother's alternate holidays shall begin at 9:30 a.m. and end at 8:00 p.m., but if her holiday falls on a day after she has Kristyn it shall extend through that night before. The mother's first holiday shall be Thanksgiving, 2006. (ii) Christmas shall alternate in two segments. Segment A shall be from December 24th at 9:00 a.m. until December 25th at 2:00 p.m. Segment B is from December 25th at 2:00 p.m. until December 26th at 6:00 p.m. The father shall have Segment A in 2006. (iii) The father shall always have Kristyn on Father's Day and the mother shall always have her on Mother's Day. ( ~~~ rj;\ I ...P .e"'l <'"> .,c. 0-- ~ ~ ,9" 'D. t.l (~...-).":. 'o;S"'O, c>- \j.l"'" tt.~~ '5 - . %4. ~-'J~_ '-'\'LL -7 .,C-' ~-:-, -;'1"" .';p<:D.,.. ~:~~~ S;'j c\) ',''\0-- ,i~ ~ o <P " ~ :;&. ~ ~ . , Barbara Sumple-Sullivan, Esquire For Plaintiff Scott A. Stein, Esquire For Defendant :sal