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HomeMy WebLinkAbout01-3706 " ADAM L. DONAHUE, . J:N THE COURT OF CODON PLEAS . Plaintiff . cmmERLAHD COUNTY, PENHSYLVANJ:A . . . v. . NO. 01-3706 C:rvJ:L TERM . : LJ:NDSAY A. TAYLOR (SENUTA), . . Defendant . C:rvJ:L ACTJ:ON - CUSTODY . PETJ:TJ:ON FOR MODJ:FJ:CATJ:ON OF CUSTODY ORDER AND NOW comes petitioner/plaintiff, Adam L. Donahue, ~ his attorney, Kent B. Patterson, and files this petition for modification of custody order, based on the following: 1. Plaintiff/petitioner is Adam L. Donahue (hereinafter referred to as ~Father") who resides at 1124 Columbus Avenue, Lower Allen Township, cumberland County, Pennsylvania (Lemoyne, PA 17043). 2. Defendant/respondent is Lindsay A. Semuta, formerly known as Lindsay A. Taylor (hereinafter referred to as UMother") who resides at 901 Allen Street, Lower Allen TownShip, Cumberland County, Pennsylvania (New cumberland, PA 17070). 3. The parties are the parents of Averi ~ycia Taylor (hereinafter referred to as ~Averi"'), born October 19, 2000. 4. Father seeks modification of the custody order entered in this case dated August 16, 2001, a copy of which is attached to this petition and marked Exhibit A. The custody order is based on a stipulation for custody dated JUly 30, 2001 which was signed ~ the parties and which provides for Mother and Father to have joint legal custody and for Mother to have prtmary physical custody with Father having rights of partial custody as outlined in the order. 5. Father and Mother agreed to modify the terms of the custody order and entered into a written agreement dated February 14, 2005 and entitled revised custody order, a copy of which is attached to this petition and marked Exhibit B. The agreement provides, among other things, for expanded rights of partial custody for Father, as follows: FROM TO Alternating weekends fram Saturday at 9:00 p.m. to Sunday at 6:00 p.m. Friday at 5:00 p.m. to Sunday at 5:00 p.m. None Every Tuesday fram 2:00 p.m. to 7:30 p.m. None One consecutive week in the sUllllDer between June and September. 6. Mother through her attorney sent Father a letter dated May 9, 2006 stating that she would no longer abide by the written agreement for the change in the custody provisions and would only - 2 - " allow Father the periods of partial custody outlined in the custody order of August 16, 2001. Attached to this petition and marked Exhibit C is a copy of the letter. 7. During the past five years, Averi has primarily resided with the following persons at the following addresses: Persons Address Date Lindsay A. Taylor Kevin & Jan Taylor (grandparents) Chris, Jamie & Colby (uncles) 14 Riddle Road Camp Hill, PA 17011 October 19,2000 Taylor to August 2004 Lindsay (Taylor) Brian Semuta (step father) Delaney Semuta (half brother Semuta 901 Allen Street New CUmberland PA 17057 August 2004 since July 2005) to present 8. Mother currently resides with the following persons: Name Relationship Brian Semuta Delaney Semuta Averi Taylor husband step-son child 9. Father currently resides with the following persons: Name Relationship Stephanie L. Hebb Kaden L. Hebb fiancee step-daughter 10. Except for the within action Father has not participated as a party or witness, or in another capacity, in - 3 - " other litigation concerning the custody of the children in this or another court. Except for the within action Father has no infor.mation of a custody proceeding pending in a court of this commonwealth. Father 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, except for Father's parents who are designated as substitute custodians in custody order dated August 16, 2001. 11. Father requests modification of the custody order to provide that the Father have primary physical custody of Averi. 12. The best interests and permanent welfare of Averi will be served by granting the relief requested for the following reasons: A. Mother has unilaterally curtailed Father's regular periods of physical partial custody with Averi for selfish reasons which are detrimental to Averi. B. Mother has created an atmosphere designed to disrupt the father and daughter relationship between Father and Averi. c. Averi needs to have a continuing and increased - 4 - relationship with her Father. D. Father will provide a stable environment and an environment which will be conducive to Averi having continued and good relationships with both Father and Mother. WHEREFORE, Petitioner/Plaintiff requests your Honorable Court to issue an order for custody as set forth in this petition. /c-r /I/'~ Kent H. Patterson Attorney for petitioner/plaintiff 221 Pine Street Harrisburg, PA 17101 717) 238-4100 - 5 - VERIPICATION I, Adam L. Donahue, verify that the statements in the foregoing petition for modification of custody order are true and correct to the best of ~ knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. il6;0b Dafe / l~ " Donahue/Taylor 7.23.01. Custody Agreement , ,~ AUG 1 5 zaatfJ ADAM L. .DONAHUE / Plaintiff " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3706 CIVIL TERM LINDSAY A. TAYLOR, Defendant CIVIL ACTION - LAW IN CUSTODY CUSTODY ORDER AND NOW, this /~,'t::' day of' ().u1"'~1, 2001/ upon consideration of the within CUstody Agreement e~ecuted by LINDSAY A. TAYLOR ("Motherl!) and ADAM L. DONAHUE ("Fatherl!) (individually "Parent'/' and c6ll~Gtive1y "Parentsl!) pertaining to their minor child/ AVERI 'l':~" ~ ...i . .:1' . '. , '0" . ALYCIA TAYLOR, bo~ October 18, 2000 . ("the Child) / IT IS HEREBY ORDERED.AND DECREED as follows: A. .LEGAL CUSTODY: The Parents shall share and have joint legal custody of their minor child, Avery A1ycia Taylor, born October 18, 2000/ '(hereinafter l?eferred'to as "the Child"). Each Parent shall be entitled to participate/ jointly with the other Parent, in all major non-emergency. decisions affecting the Child's he~l th, education/ religion and general well being. Each Parent ~hali be entitled to access ~o any and all inform~tion, persons, entities and documentation regarding the same so that E)( 11//.5/1 A Donahue/Taylor 7.23.01. Custody Agreement 'I informed decisions can be made. B. PHYSICAL CUSTODY: The following shall apply regarding physical custody of the Child: 1. Primary Custody: Mother shall have primary physical custody of the Child. 2 . Partial Custody: Father shall have rights of partial ~hysical custody of the Child. 3 . Custody Schedule: The parties rights of custody shall be in accordance with the following schedule: a. Alte~ating Weekends: The Parents shall alternate custody on alternating weekends. The times for Father's weekends shall be from 9:00 a.m. on Saturday until 6:00 p.m. on Sunday. Father/s first weekend shall be the weekend of August llu through August 12~, 2001. b. Substitute Custodian: If Father not available to exercise his custodial rights on his established alternating weekend/ Father's parents shall be g~ven the opportunity to have'custody of the Child, for Father/s weekend instead of Father; provided/ - 2 - ,I Donahue/Taylor 7.23.01. Custody Agreement however I that if Father is unavailable for two consecutive alternating weekends, then Mother shall retain custody of the child for Father's second alternating weekend and Father shall be deemed to have forfeited his custodial rights for that alternating weekend. , c. Holidays: The ,Parents shall alternate c~stody on the following major holidays under the terms and as set forth below: 1. Easter: From 9:00 a.m. to 6:00 p.m. 2. Memorial Day: From 9:00 a.m. to 6~00 p.m. 3. Independence Day (Observed); 9:00 a.m. to 6:00 p. m. on Independence Day (Observed) 4. Labor Day: From 9:00 a.m. to 6:00'p.m. 5.' Thanksgiving:' From 9:00 a.m. to 6:00 6. Christmas Eve Christmas Morning: From December 24th at 9:00 a.m. until December 25~ at 12:00 p.m. 7. Christmas Afternoon December 26th: From December 25th at 12 :'00 p. ffi.. until December 26th at 6:00 p.m. - ~ - .t Donahue/Taylor 7.23.01. Custody Agreement 8. Holiday Schedule: The following schedule shall apply to the above referenced holidays: !IB!_~l~'J~~ ~ r..~;.~~"~...~~.;",,);i~~.~ .:ar.3 ""~'r.~ '{';.~'~1Il1~ "~ f'~:';7~~C-';"~ '. ; ,";:'~ ";~\"".~,,~~{;"? f; ~!_~ ~~-~i~~~i~l ~:~'::~~~:i~;:~~~~ EASTER Mother Father MEMORIAL DAY Father Mothez:: INDEPENDENCE DAY Moth.er Father LABOR DAY Father Mother THANKSGIVING DAY Mother Father CHRISTMAS EVE- Father Mother CHRISTMAS MORNING CHRISTMAS AFTERNooN- Moth~r Father DECEMBER 26TH d. Mother I S Day: Mother shall have custody each Mother's Day from 9:00 a.m. until 6:00 p.m. , e. Father's Day: Father shall custody of the Children each Father's Day from 9:00 a.m. until 6:00 p.m. c. zaSCELLANEOUS CUSTODY TERMS: 1. Transportation: The transportation necessary for the custodial exchanges herein set forth shall be provided by Father. 2. Precedence: The holiday, schedule shall take precedence over any other" custodial period set forth herein. The - 4 - .' , ,. Donahue/Taylor 7.23.01. Custody Agreement , ,\ other miscellaneous custodial periods shall take precedence over the regular alternating weekend and midweek custodial periods set forth herein. 3. Modification: The Parents shall be at liberty to modify the custodial periods herein provided to accommodate their respective schedules and special events, subject, nonetheless in all respects to the mutual agreement of the Parents for any such modifications. BY THE COURT: /~J i~ ~ I~ I I J. TRUE COpy FROM RECORD In TestimOny whereof, I here unto set my hand and thesOal of said Court at Carlisle, Pa. Thla l1;ay 01 ~t:i? -ft:/ ( ~ 0 d .'j. -A I Pr~honotarl - 5 - ..' .' '. . FILE COpy February 14,2005 Revised Custody Order Effective February 14, 2005 In accordance with the agreement drawn up on July 30, 200 I I would like to address the following issues that Adam Donahue and 1 have agreed to reVIse. - We have agreed to remove the following from the previous order; Page 2, Section B, Article 3, Subtitle b. Titled Substitute Custodian. (included with these re~sions is a copy of the original document with this section highlighted) In other words the father will be held personally responsible for all transportation to and from my custody. Only under extreme circumstances, after Adam and 1 have already made prior arrangements may any other relative pick Averi up for his visitation. -I have agreed to give Adam one day a week of his choice to have custody of Averi. He has chosen Tuesday from 2:00pm-7:30pm, unless different arrangements are agreed to by us. -Currently Adam's custody on his weekends consists of Saturday at 9:00am until Sunday at 6:00pm. We have agreed to change those hours to Friday at 5:00pm until Sunday at 5:00pm. (unless different arrangements are made and agreed upon) -I have agreed to give Adam the opportunity to have custody of Averi for one consecutive week of his choice between the months of June - September. (provided school is not in session, and one months notice has been given) IYwJ~ 2/; S-/uj Date -;' -/5-G'S- Date f , / <j:' /t/,;'" " ~t'(. :;x)'7/:;~/' , ~. .~---:;(/'k...1-'1 j/ (.., (/' i ~,/ v-r l/ t.t,~. I /J Page 1 Exll/g/I t3 " .' ". In reference to the fITst page Adam and I have already agreed to some changes that I would like to address for the record. -March 4th - 6th is Adam's weekend and he has agreed to return Averi at 10:00am on Sunday the 6th. -Tuesday, March 8th Adam has forfeited his visitation on this day. -Adam's weekend August 5th - 7th has been changed to the weekend of August 12th - 14th. : -Tuesday, August the 2nd has been changed to Lindsay's day, (No day has been traded in return) -Adam's weekend December 9th - 11 th has been changed to the weekend of December 16th - 18th. -Tuesday, December 6th has been changed to Lindsay's day.(No day has been traded in return) -Any other changes that need to be made will be made in our agreement. Sincerely, ! Lindsay T. Semuta 901 Allen Street New Cumberland, P A 17070 (717)-774-3169 d 11..$"--/ If S- . .-:7 J)~j:e, i- ?'~/~ =-c' 0 Date Page 2 .' Patrick F. Lauer, Jr., Esq.* Marlin L. Markley, Esq.** Shana M. Pugh, Esq. 1-800-822-4-LAW THE LAW OFFICES OF PATRICK F. LAUER, JR., L.L.C. 2108 MARKET STREET, AZTEC BUILDING CAMP HILL, PENNSYLVANIA 17011 (717) 763-1800 FAX (717) 763-4247 Reply to Camp Bill Address Satellite Office: 8 S. Hanover Street Carlisle, PA 17013 '" . -.,' ".,",., ',.~ ....-...;;" ' - rln;-}Y-' ...nm May 9. 2006 Adam Donahue 2712 Lisbum Road Apartment 204 Camp Hill, PA 17011 RE: Donahue v. Semuta, No. 01-3706 Civil Cumberland Coun.ty Custody Dear Mr. Donahue: Be advised that I have been retained to represent Lindsey Semuta with respect to 1he above- referenced matter. This letter serves as written notice that Mrs. Semuta is no longer in agreement .;. with the custody stipulation dated March 24, 2005. Since Judge Hess' Custody Order datM August 16,2001, can only be altered by mutual consent of1he parties, Mrs. Semuta will be abiding by the August 16,2001, order. I have enclosed a copy of1hat orcler for you. . t' . . ~ " Additionally, I am senc1ing a cease and desist letter to Ms. Stanley-Hebb. Mrs. Semuta is very upset with the frequency and content of telephone caIls from Ms. Stanley-Hebb.. MIs. Sem.uta in no way wishes to limit you telephone contact with. your i1~11gJ1ter, Averi. However, she does not want any further telephone calls from Ms. Stanley-Rubbo At this time I am encouraging you to contact Mrs. Semuta when and if there are matters that concern Averi. Very truly yours, 1v.ILMI Enclosure Cc: Lindsey Semma . ~: ," .,.'f .', &xH/8/rc. tit *Boar4 Certif,u. as a Criminal Trial Advocate' by'the National Board of Trial A.dvocacy. ... M~er: National Association of Criminal Defense lawyers ." n ~ r; '" ~ '" *- ? ~ ~ 8 ~ ~ f! ~~-J i ~ r- -r' N - -- N .--<~ - ~ .r:::- ., ADU L. DONAHUE, I IN THE COURT OF COIIMON PLEAS Plaintiff I CUMBERLAND COtJN'1'Y, PENNSYLVANIA . . V. I NO. 01-3706 CIVIL TERM I LINDSAY A. TAYLOR (SEHUTA) , . . Defendant I CIVIL ACTION - CUSTODY PETITION FOR SPECIAL IRTER~ RELIEF AND NOW comes petitioner/plaintiff, Adam L. Donahue, b.Y his attorney, Kent H. Patterson, and files this petition for special interim relief pursuant to Pa.R.C.P. 1915.13, as followsl 1. plaintiff/petitioner is Adam L. Donahue (hereinafter referred to as "Father") who resides at 1124 Columbus Avenue, Lower Allen Township, cumberland County, Pennsylvania (Lemoyne, PA 17043). 2. Defendant/respondent is Lindsay A. Semuta, formerly known as Lindsay A. Taylor (hereinafter referred to as "Rother") who resides at 901 Allen Street, Lower Allen Township, cumberland County, pennsylvania (New cumberland, PA 17070). 3. The parties are the parents of Averi Alycia Taylor (hereinafter referred to as "Averi"), born October 19, 2000. 4. A custody order was entered in this case dated August 16, 2001 which provided for Rother and Father to have joint legal custody with Mother having primary physical custody and Father having partial custody on alternating weekends from Saturday to Sunday and on alternating holidays. 5. Father and Mother agreed to modify the terms of the custody order and entered into a written agreement dated February 14, 2005 which expanded Father's periods of partial custody so that Father would have Averi on alternating weekends from Friday at 5:00 p.m. to Sunday at 5:00 p.m., Tuesdays from 2:00 p.m. to 7:30 p.m., and one consecutive week during the summer. 6. Mother unilaterally revoked the agreement to modify the custody order by a letter that she had her attorney send to Father dated May 9, 2006. 7. Father has filed a petition for modification of the August 16, 2001 order. Attached to this petition is a copy of the petition for modification which is marked Exhibit 1 and which contains Exhibit A (custody order dated August 16, 2001), Exhibit B (agreement of the parties dated February 14, 2005 modifying the custody order) and Exhibit C (letter from Mother's attorney dated May 9, 2006 revoking the parties agreement to modify the custody order). 8. In March 2006, Mother and Father agreed that Father would have custody of Averi for one week beginning July 29, 2006 - 2 - and extending through August 5, 2006 so that Father could have Averi accompany him, his parents, his sister and his fiancee on a one week vacation in Orlando, Florida and Disney World. Father agreed to forego partial custody on the Fourth of JUly, 2006 as part of the agreement that he would have this one week of custody for the family vacation. 9. Despite Mother's revocation of the agreement of February 14, 2005, Father believed that Mother was still abiding by agreement for him to have custody for the one week summer vacation and Father yielded custody of Averi to Mother on the Fourth of JUly as part of the agreement. 10. On JUly 17, 2006, Mother advised Father that she would not allow Averi to go to Florida and gave no reason other than she objected to Father's fiancee being part of the vacation trip. 11. Father requests that an interim order be issued which would allow him to have partial custody of Averi for the Florida trip (JUly 29, 2006 through August 5, 2006) and for the expanded times set forth in the February 14, 2005 agreement between the parties, pending hearing on Father's petition for modification or further order of court, for the fOllowing reasonSI A. The airplane ticket for Averi for the Florida trip - 3 - has been purchased, roams have been reserved at a resort hotel and all arran~ements have been made for the Florida trip with Father's family. B. Averi has had a close relationship with Father's family since birth and with pather's fiancee since August, 2005. C. There is no le~itimate reason for Averi to be denied the opportunity to ~o on vacation with pather and his family. D. There is no le~itimate reason for Averi to be denied the times of partial custody with Father and pather's family which had been in place from Pebruary, 2005 to Hay, 2006, II. period of over one year. WHEREFORE, petitioner/plaintiff requests the court to issue an interim order for custody as requested in the petition. Respectfully submitted, ~ T /J~ Kent H. Patterson Attorney for petitioner/plaintiff 221 pine Street Harrisbur~, PA 17101 717) 238-4100 - " - VER:IF:ICAT:ION :I, AdllJll L. Donahue, verify that the statements in the within petition are true and correct to the best of ~ knowledge, information and belief. :I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. If)rc ADAM L. DONAHUE, . IN THE COURT OF COMMON PLEAS . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. : NO. 01-3706 CIVIL . . LINDSAY A. TAYLOR (SEMUTA) , . . Defendant . CIVIL ACTION - CUS'1'ODY . ORDER OF COURT You, Adam L. Donahue and Lindsay A. Taylor (SeIIII1ta), are directed to appear in person before the CUstody Conciliator, at on , 2006 at .m., for a pre-hearing custody conference. At such conference, an effort will be made to resolve the issues in disputel or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, aDd to enter into a temporary order. Failure to appear at the conference ~ provide grounds for entry of a temporary or pernuoTlent order. YOU SHOULD TARE TRIS PAPER '1'0 YOUR LAWYER AT OHCB. IF YOU DO NOT RAVE A LAWYER OR CANNOT AFFORD ONE, GO '1'0 OR TELEPHONE THE OFFICE SET FOR'l'R BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Admini.trator CUmberland County Courthouse one Courthouse Square Carlisle, PA 17013-6200 (717) 240-6200 Page 1 of 2 e)<H-\~)r \ AMERICANS WiTH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUmberland County is required by law to coqlly with the Americans with Disabilities Act of 1990. For information about assessable facilities and reasonable acco~lltions available to disabled individuals having business before the court, please contact our office. All arrang-.nts must be lIIlIde at least 72 hours prior to llDY hearing or business before the court. You must attend the scheduled conference or hearing . FOR THE COURT I Date I Byl Custody Conciliator " Page 2 of 2 ADAM L. DONAHUE, Plaintiff : IN THE COURT OF COIINON PLEAS : CUMBERLAND COmrrY, PENNSYLVANIA : v. : NO. ,.., 01-3706 CrvIL TERM' ~., . . , I =-:1 LINDSAY A. TAYLOR (SElmTA), Defendant : : CrvIL ACTION - CUSTODY -C', . . :. ,., PETITION FOR IIODIFICATION OF CUSTODY ORDER r, " :.'<: AND NOW comes petitioner/plaintiff, Adam L. Donahue, by his attorney, Kent B. Patterson, and files this petition for modification of custody order, based on the following: 1. Plaintiff/petitioner is Adam L. Donahue (hereinafter referred to as ~Father") who resides at 1124 Columbus Avenue, Lower AJ.len Township, CWIIberland County, Pennsylvenia (Lemoyne, PA 17043). 2. Defendant/respondent is Lindsay A. Semuta, formerly known as Lindsay A. Taylor (hereinafter referred to as 'Hothern) who resides at 901 Allen Street, Lo_r Allen Township, cumberland County, Pennsylvania (New cumberland, PA 17070). 3. The parties are the parents of Averi Alycia Taylor (hereinafter referred to as 'Averin), born October 19, 2000. 4.. Father seeks modification of the custody order entered in this case dated August 16, 2001, a copy of which is attached to this petition and marked Exhibit A. The custody er.H-II?/r- I order is based on a stipulation for custody dated July 30, 2001 which was signed by the parties and which provides for Mother and Father to have joint legal custody and for Mother to have primary physical custody with Father having rights of partial custody as outlined in the order. 5. Father and Mother agreed to modify the te:r:1ll8 of the custody order and entered into II. written agreement dated February 14, 2005 and entitled revised custody order, a copy of which is attached to this petition and marked Exhibit B. 'l'he agreement provides, among other things, for expanded rights of partial custody for Father, as follows I FROM TO Alternating _ekends from Saturday at 9100 p.m. to Sunday at 6100 p.m. Friday at 5100 p.m. to Sunday at 5100 p.m. None Every Tuesday from 2100 p.m. to '130 p.m. None one consecutive _ek in the s~r bet_en June and September. 6. Mother through her attorney sent Father a letter dated Jllay 9, 2006 stating that she would no longer ebide by the written agreement for the change in the custody provisions and would only - 2 - allow Father the periods of partial custody outlined in the custody order of August 16, 2001. Attached to this petition and marked Exhibit C is a copy of the letter. 7. During the past five years, Averi has primarily resided with the following persons at the following addresseSt Persons Address Date LindSay A. Taylor Kevin &: Jan Taylor (grandparents) Chris, Jamie &: Colby (UDcles) 14 Riddle Road CaRP Bill, PA 17011 October 19,2000 Taylor to August 2004 LindSay (Taylor) BrillJ1 SeJIII1ta (step father) DelllJ1ey SeJIII1ta (half brother Semu.ta 901 Allen Street N_ CUmberland PA 17057 August 2004 since July 2005) to present 8. Rother currently resides with the following pe:rsons I Name Relationship BrillJ1 SeJIII1ta DelllJ1ey SeJIII1ta Averi Taylor husbllJ1d step-son child 9. Father currently resides with the fOllowing personsl Name Relationship Stephanie L. Bebb Kaden L. Bebb fiancee step-daughter 10. Except for the within action Father has not participated. as a party or witness, or in another capacity, in - 3 - other litigation concerning the custody of the children in this or another court. Except for the within action Father has no information of a custody proceeding pending in a court of this commonwealth. Father 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, except for Father'S parents who are designated as substitute custodians in custody order dated August 16, 2001- 11. Father requests modification of the custody order to provide that the Father have primary physical custody of Averi. 12. The best interests and permanent welfare of Averi will be served by granting the relief requested for the following reasons: A. Mother has unilaterally curtailed Father's regular periods of physical partial custody with Averi for selfish reasons which are detrimental to Averi. B. Mother has created an atmosphere designed to disrupt the father and daughter relationship between Father and Averi. C. Averi needs to have a continuing and increased - 4 - relationship with her Father. D. Father will provide a stable environment and an environ:ment which will be conducive to Averi having continued and good relationships with both Father and Nother. WHEREFORE, Petitioner/plaintiff requests your Honorable court to issue an order for custody as set forth in this petition. J:--:/ 1(Il~ KeUt H. Patterson Attorne,v for petitioner/plaintiff 221 pine Street Harrisburg, PA 17101 717) 238-4100 - 5 - VElUP':ICA'r:ION I, Adam L. Donahue, verify that the statements in the foregoing petition for modification of custody order are true and correct to the best of m;y knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1/6~b Oaf. / ~ ~ '. Donahue/Taylor 7.23.01. Custody Agreement , ., AUG 1 fi zoa'lfl ADAM L. pONAHUE, Plaintiff " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3706 CIVIL TERM LINDSAY A. TAYLOR, Defendant CIVIL ACTION - LAW IN CUSTODY CUSTODY ORDER AND NOW, this //,~ day of' ()nru'r, 2001, upon consideration of the within Custody Agreement e~ecuted by LINDSAY A. TAYLOR ("Mother") and ADAM L. DONAHUE ("Father") (individually "Parent"' and c6l'1~qti vely "Parents") pertaining to their minor child, AVERI ,..:l.'-::..I.... . '. . ~" . . ALYCIA TAYLOR, born October 18, 2000 '( "the Childj, IT IS HEREBY ORDERED ,AND DECREED as follows: A. ' . LEGAL CUSTODY: The Parents shall share and have joint legal custody of their minor child, Avery Alycia Taylor, born October 18, 2000, (hereinafter referred 'to as "the Child"). Each Parent shall , be entitled to participate, jointly with the other Parent, in all major non-emergency, decisions affecting the Child's heal th, education, religion and general we;I.l being. Each , . , Parent ~hali beentltled,to access ~9 any and all information, persons, entities and documentation' regarding the same so that EXH/&/T J4 Donahue/Taylor 7.23.01. Custody Agreement ., informed decisions can be made. B. PHYSICAL CUSTODY: The following shall apply regarding physical custody of the Child: 1. Primary Custodv: Mother shall have primary physical custody of the Child. 2. Partial Custodv: Father shall have rights of partial physical custody of the Child. 3 . Custodv Schedule: The parties rights of custody shall be in accordance with the following schedule: a. Alternatina Weekends: The Parents shall alternate custody on alternating weekends. The times for Father's weekends shall be from 9:00 a.m. on Saturday until 6:00 p.m. on Sunday. Father's first weekend shall be the weekend of August 11th through August 12th, 2001. b. Substitute CUstodian: If Father not available to " exercise his 9ustodiaJ rights on his established al ternating weekend, Father's parents shall be given the opportunity to have' custody of the Child. for Father'S weekend instead of Father; provided, - ? - Donahue/Taylor 7.23.01. Custody Agreement .. however, that if Father is unavailable for two consecutive alternating weekends, then Mother shall retain custody of the child for Father's second alternating weekend and Father shall be deemed to have forfeited his custodial rights for that alternating weekend. c. Holidays: The Parents shall alternate custody on the following major holidays under the terms and as set forth below: 1. Easter: From 9:00 a.m. to 6:00 p.m. 2. Memorial Dav: From 9:00 a.m. to 6:00 p.m. 3. Indeoendence Dav (Obse~ed); 9:00 a.m. to 6:00 p. m. on Independence Day (Observed) 4. Labor Day: From 9:00 a.m. to 6:00'p.m. s." Thanksaivina, From 9:00 a.m. to 6:00 6. Christmas Eve Christmas Mornina: From December 24~ at 9:00 a.m. until December 25~ , at 12:00 p.m. 7. Christmas Afternoon December 26~: From December 2S~ at 12:00 p.m.. until tlecember 26~ at 6:00 p.m. - 3 - Donahue/Taylor 7.23.01. Custody Agreement ., 8. Holidav Schedule: The following schedule shall apply to the above referenced holidays: EASTER Mother Father MEMORIAL DAY Father Mothe:r:: INDEPENDENCE DAY Moth,er Father LABOR DAY Father Mother THANKSGIVING DAY Mother Father CHRISTMAS EVE- Father Mother CHRISTMAS MORNING CHRISTMAS AFTERNOON- Mother Father DECEMBER 26TH d. Mother's Day: Mother shall haye custody each Mother's Day from 9:00 a.m. until 6:00 p.m. . e. Father's Dav: Father shall custody of the Children each Father's Day from 9:00 a.m. until 6:00 p.m. C. MISCELLANEOUS CUSTODY TERMS: 1. Transoortation: The transportation necessary for the custodial exchanges herein se,t. forth shall be provided by Father. 2. Precedence: The holiday. schedule shall.take precedence over any other. custodial period set forth herein. The - 4 - Donahue/Taylor 7.23.01. Custody Agreement , ,I other miscellaneous custodial periods shall take precedence over the regular alternating weekend and midweek custodial periods set forth herein. 3. Modification: The Parents shall be at liberty to modify the custodial periods herein provided to acco!l1lll6date their respeative schedules and special events, subject, nonetheless in all respects to the mutual agreement of the Parents for any such modifications. BY THE COURT: /~J 1!...~':'" ~ J~ I I J. " , ", " TRUE COPY FROM RECORD In restimOnYwhereof\ I here unto set my hand and tile s8aI of said Court at Cartlsle. Pa. ThIs t~ (l~l:(:~/~ Protflonritar( - 5 - Donahue/Taylor 7.23.01. CUstody Agreement '" . .r,... - ADAM L. DONAHUE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3706 CIVIL TERM LINDSAY A. TAYLOR, Defendant CIVIL ACTION - LAW IN CUSTODY STIPULATION FOR CON2ENT CUSTODY ORDER """""" Thi'~ day O~ 2001, ADAM L. IlOlO\lIUE and LINDSAY A. TAYLOR hereby stipUlate and agree that the foregoing Custody Order shall be entered by the Court in the above captioned matter. IN W'X'l'NESS WHEREOF the parties, intending to be legally bound hereby, have set their hands and se~ls the day and year below written. SEAL, Date: ~36-{)/ GIi!r!!!!i fu;/Jr.... Date: 7/:?iJ/ot - 6 - FILE COpy February ] 4, 2005 Revised Custody Order Effective February 14,2005 In accordance with the agreement drawn up on July 30, 2001 I would like to address the following issues that Adam Donahue and 1 have agreed to revise. -We have agreed to remove the following from the previous order; Page 2, Section B, Article 3, Subtitle b. Titled Substitute Custodian. (included with these reVisions is a copy of the original document with this section highlighted) In other words the father will be held personally responsible for all transportation to and. from my custody. Only under extreme circumstances, after Adam and 1 have already made prior arrangements may any other relative pick Averi up for his visitation. -I have agreed to give Adam one day a week ofhis choice to have custody of Averi. He has chosen Tuesday from 2:00pm-7:30pm, unless different arrangements are agreed to by us. -Currently Adam's custody on his weekends consists of Saturday at 9:00am until Sunday at 6:00pm. We have agreed to change those hours to Friday at 5:00pm until Sunday at 5:00pm. (unless different arrangements are made and. agreed upon) -I have agreed to give Adam. the opportunity to have custody of Averi for one consecutive week of his choice between the months of June - September. (provided school is not in session, and one months notice has been given) ffwiG-. ,"', ,(~, /:';:" ~ ~ .', , , ,,-:"v;{.,ti1,-, '-1./ ,: ~ . t..t.~ / ,/.J L If 5!u) DaIl\ 7 '-/5- ('.:S- DaIl\ Pa&el Exll/&/I 13 In reference to the fIrst page Adam and I have already agreed to some changes that I would like to address for the record. -March 411> - 6h is Adam's weekend and he has agreed to returnAveri at I 0:00am on Sunday the 6th. -Tuesday, March 8th Adam bas forfeited his visitation on this day. -Adam's weekend August Slh - 'J'h has been changed to the weekend of August 1211> - 1411>. : -Tuesday, August the 2nd has been changed to Lindsay's day. (No day has been traded in return) -Adam's weekend December ~ - 1111> bas been changed to the weekend of December 16h - 18th. -Tuesday, December 6h has been changed to Lindsay's day.(No day bas been traded in return) " -Any other changes that need to be made will be made in our agreement Sincerely, I Lindsay T. Semuta 90 1 Allen Street New Cumberland, P A 17070 (717)-774-3169 \. d /rr/Is 7~~--(" 5 Date Page 2 THE LAW OFFICES OF PATRICK F. LAUER, JR., L.L.C. 2108 MARKET STREET, AZTEC BUlLDING CAMP HD..L, PENNSYLVANIA 17011 (71717~1800 FAJt17171763~247 Reply to Camp Hill Address Satellite 0IJice: 8 S. BaDover Street Carlisle, PA 17013 Patrick F. LaueJ', JJ'., Esq." Madin L. Mukley, Esq."" Sbana M. Pugh, Esq. 1-800-822-4-LAW "" ....-........-..,..,..... '" , .." .-...... _ "ni~ ...",m May 9, 2006 Adam Donahue 2712lisbum Road , Apartment 204 Camp Hill, PA 17011 RE: Donahue v. Semuta, No. 01-3706 Civil Cumberland County Custody Dear Mr. Donahue: " Be advised that I have been retained to represent Lindsey Semuta with respect to the above. referenced rnRft..... This lettec serves as written notice that Mrs. Semula is DO longer in agreement with the custody stipulation dated March 24, 2005. Since Judge Hess' Custody C>rd<< dated August 16,2001, can only be alteled by mutual consent of the parties. Mrs. Semuta will be abiding by1be August 16, 2001, order. I have enclosed a copy offbat order for you. . " . , . '. , . Additionally, I am. -M;1lg a cease and desist letter to Ms. S1aoJey-Hebb. Mrs. Semuta is very upset with1he frequency and coute...d. of telephone calls from Ms. Stanley-Hebb. MIs. Semuta in DO way wishes to limit you telephone contact with,your it,,,,g'/>tP.t:, Averi. However, she does not want any fi.u1:her telephone calls from Ms. Stanley-Hubb. At this time I am. em:ouraging you to contact MIs. Semuta when and iftb.ere are matters fbat concem Averi. Very troly yours, . . ". '.'1 ", M1MI Enclosure Cc: Lindsey Semuta "." I " ' 5xHi8/T t!- ~ "Board. CmtrIMi os a CrinUnaJ 1HaJ AJiv()C(lU' by'the National Board of Trial Advocacy. ....~: Nationalksociation o/Criminal Defense Lawyers ~ ~ -p t:- B 1-~' _ (_ 8 ~ ~ :tJ ~ ~ F \Y 1:: ~ " ,...-\ "!-.'f\ (;< (~\. . i...:' f"" .-~~ (, . I IN THE COUR~ OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I : NO. 01-370~ CIVIL TERM I I ADAM L. DONAHUE, Plaintiff v. LINDSAY A. TAYLOR (SEHUTA), Defendant I I CIVIL ACTIO$-CUSTODY ORDER AND NOW, this {}'5~ay of ~. , 2006, it is ordered that a hearing on plaintiff's petiti~n for special interim relief shall be held on July 2<6, 2016 at C\'-3D a..m. in Courtroom No. ;;2., CUmberland !County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. BY ( THE Cothl~1 /1 ~ ~ ~ I , -P~ --<. -.t., ~~ ~\ 0:-- -L ---<:- \) ---Q ~~ j;?t .i- l ~ 7". (.-". \"-) <..', v. I IN THE COURT OP COMMON PLDS I CUMBERLAND COtJNTY, PENNSYLVANIA I I I NO. 01-3706 CIVIL TERM I I I I CIVIL ACTION-CUSTODY ADAK L. DONAHUE. Plaintiff LINDSAY A. TAYLOR (SEHUTA), Defendant SPECIAL ~ CUB"""" ~2006' """" AND NOW, this ~ day consideration of the plaintiff's petition or special interim relief. it is ordered that plaintiff (-FatherR). Adam L. Donahue. shall have partial custody of the minor child. Averi Alycia Taylor (born October 19) from July 29. 2006 through J J '" ("/1 '.f,~1' 'j August 5. 2006 for the family vacation. L.~/J~, a~v Jlh",11 J.,~t'e.. fJ.'1J.t./ (11).4;1, 1,,0.... ,4v,~j- I},lr/.D(, /4.I'."'i~ IIv~vjf Iii) '2..11 Oil . J. '1 ! \ "> "". "Tl ..->! [-;-1 j""',.: C) C':') ADAM L. DONAHUE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 01-3706 CIVIL ACTION LAW LINDSAY A. TAYLOR (SEMUTA) DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, July 31, 2006 , upon consideration of the attached Complaint. it is hereby directcd that parties and their respective counsel appear before Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, AUj!ust 29, 2006 , the conciliator, at 11:3l!..-AM for a Pre-Hearing Custody Conference. At such confcrence, an cffort will be made to resolve the issues in dispute; or if this cannot bc accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order, All children age five or older may also be present at the conference, Failure to appear at the conference may provide grounds for entry of a temporary or permanent order, The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders. and Custody orders to the conciliator 48 hours prior to scheduled hearin!!. FOR THE COURT. By: Isl Dawn S. Sunday, ESQ. Custody Conciliator p- The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing, YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 32 South Bedford Street Carlisle. Pennsylvania 17013 Telephone (717) 249.3 I 66 4r?"Jtr ~ ~ ~ l)o.l-~ ..;Jrt ?- ~ ~/J-, 'JQ -/.j. "",,!#,I Y f ~ 4kv.(f? 'lO'It> ,J,t. " ,'I ..) \' ,\ \ - ': ')~'" _I"~ ,- 'I ADAM 1. DONAHUE, Plaintiff v. LINDSAY A. SEMUTA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO.: 01-3706 CIVIL TERM : CUSTODY ACTION - LAW IN : CUSTODY PRAEC.IPE TO ENTER APPEARANC.E TO THE PROTHONOTARY: Please enter the appearance of Marlin 1. Markley, Esquire, on behalf of Defendant Lindsay A. Semuta in the above-captioned action. Date: J> -I -2()Dv ./ Marlin . 2108 Mar t Street, Aztec Building Camp Hill, Pennsylvania 17011 ID# 84745 Tel. (717) 763-1800 e i ~ I~~~~ ~t: ~ ~~ :J>o" ::c ~ ~~ ~ ~ -, -~::-~. ,;. .7/_~, ,/ . ~ ADAM L. DONAHUE Plaintiff i SEP Y 10U6 . ~ 3Y -=-o42~~======J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-3706 CIVIL ACTION LAW LINDSAY A. TAYLOR (SEMUT A) Defendant IN CUSTODY ORDER OF COURT AND NOW, this 1"-1 day of ,~_ , 2006, upon consideration of the attache~onciliation~ and directed as follows: 1. The prior Order ofthis Court dated August 16, 2001 is vacated and replace with this Order. 2. The Father, Adam L. Donahue, and the Mother, Lindsay A. Taylor, shall have shared legal custody of Averi Alycia Taylor, born October 19, 2000. 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 her 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 at 6:30 p.m. through Monday morning when the Father shall transport the Child to school. In addition, the Father shall have custody every Tuesday, when the Father (or his fiancee) shall pick up the Child at the maternal grandmother's residence at 4:30 p.m. through Wednesday morning when the Father shall transport the Child to school. The Mother shall transport the Child to the Father's residence every weekday morning at 7:30 a.m. on the way to work and the Father shall transport the Child to school. 5. The parties shall participate in a course of therapeutic family counseling with a counselor at Guidance Associates or other professional selected by agreement between the parties. The purpose of the counseling shall be to assist the parties in establishing sufficient communication and cooperation to enable them to effectively co-parent their Child. The parties shall engage in a minimum of four joint sessions unless otherwise recommended by the counselor. All costs of counseling shall be shared equally by the parties. 6. The parties shall communicate with each other by email every Sunday evening, at a minimum for the purpose of keeping each other apprised of the Child's schedule for the following week and of any significant developments pertaining to the Child during the preceding week. 7. Within sixty days ofthe date of this Order, counsel for either party may contact the conciliator to schedule an additional conference to review the custody schedule and/or establish holiday custody arrangements, if necessary. 8. 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. J. --- cc: ~ent H. Patterson, Esquire - Counsel for Father ~ ~arlin L. Markley, Esquire - Counsel for Mother A, I .,\.., ? , , I (' I l. 'I !..J ,.,; ..::.: ADAM L. DONAHUE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-3706 CIVIL ACTION LAW LINDSAY A. TAYLOR (SEMUTA) Defendant IN CUSTODY Prior Judge: Kevin A. Hess/ Edgar B. Bayley 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 t he subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF A veri Alycia Taylor October 19, 2000 Mother 2. A custody conciliation conference was held on September 7, 2006 with the following individuals in attendance: The Father, Adam L. Donahue, with his counsel, Kent H. Patterson, and the Mother, Lindsay A. Taylor, with her counsel, Marlin L. Markley. 3. The parties agreed to entry of an Order in the form as attached. ~~ I', dOOU Date Da~ Custody Conciliator SHERIFF'S RETURN - REGULAR CASE NO: 2001-03706 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DONAHUE ADAM L VS TAYLOR LINDSAY A DOUGLAS RUZANSKI , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within ORDER & PET FOR SPEC RELI was served upon TAYLOR LINDSAY A the RESPONDANT at 1055:00 HOURS, on the 28th day of July , 2006 at 901 ALLEN STREET NEW CUMBERLAND, PA 17070 by handing to LINDSAY A TAYLOR a true and attested copy of ORDER & PET FOR SPEC RELI together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18.00 14.96 .39 10.00 .00 43.35./07/31/2006 /1 KENT PATTERSON 9. J4-(){, ~ ,r~~ R. Thomas Kline Sworn and Subscibed to By: ,) before me this day of A.D. ADAM L. DONAHUE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. 01-3706 CIVIL ACTION LAW LINDSAY T. SEMUT A, formerly known as LINDSAY A. TAYLOR, Defendant IN CUSTODY CUSTODY STIPULATION AND NOW, comes ADAM L. DONAHUE, (hereinafter Father), who currently resides at 509 Tenth Street, Collingwood, Ontario, Canada L9Y2H2 and LINDSAY T. SEMUT A, (hereinafter Mother), who currently resides at 901 Allen Street, New Cumberland, Pennsylvania 17070, who set forth: WHEREAS, Mother and Father are the parents of a minor child, namely, Averi Alycia Taylor, born October 19, 2000; and WHEREAS, Mother and Father are the parties to a Custody Order, the same of which was entered on September 14,2006; and WHEREAS, Father has relocated to Ontario, Canada; and WHEREAS, as a result of Father's relocation the parties are desirous of modifying said September 14, 2006 Custody Order; AND NOW, THEREFORE, the parties intending to be legally bound, hereby agree and stipulate as follows: 1. The prior Order of this Court dated September 14,2006 is vacated and replaced with this Order. 2. Mother shall have sole legal custody of A veri Alycia Taylor. 3. Mother shall have primary physical custody of the child. 4. Father shall have partial physical custody: a. One weekend per month to be exercised in a location agreed between the parties. The parties shall agree and confirm, via email, the specific dates and times of this one weekend per month custody. It is specifically understood by Mother that Father may not be able to exercise every period of custody contemplated by this paragraph. b. On holidays as agreed between the parties with the specific dates and times confirmed via email no less than 14 days prior to each such holiday. c. Two non-consecutive weeks during the child's summer vacation from school. The specific location, dates, and times of the summer custody shall be confirmed by the parties via email no less than 30 days prior to each week of vacation. 5. Each parent shall pennit reasonable telephone access to the child when she is in his or her custody. 6. Each parent shall encourage the child to love and respect the other and shall not make, nor allow others to make in the presence of the child, derogatory comments about the other parent. Further, each parent shall encourage the child to have contact with the other parent and shall make certain that the child is ready on time for the transfer of physical custody from one parent to the other. 7. The parents agree that at the current time the custody arrangement set forth above is in the best interest of the child. 8. Each parent reserves the right to seek modification of these custody and visitation arrangements in the future upon appropriate showing of changed circumstances. 9. The parties agree that this Stipulation shall be entered and adopted as an Order of Court pursuant to an agreement of the parties. WITNESS: d . Do ahue ~~ , . '. C 4/l1-fJ H!~ f'~'Jllv~i,t.J /(eS,~ , ONTARIO, CANADf~ ) ) SS: ) On this the ~l day of ~ 6,.."-;! , 2007, before me, a Notary Public, the undersigned officer, personally appeared ADAM L. DONAHUE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing instrument and acknowledged that helshe executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notorial seal. .... MC"E' ~1:~ y ommlSSlon xplres: COMMONWEALTH Of PENNSYLVANIA NOTARiAl SEAl ROBERTA E, BIESECKER, NotBfy Public Camp Hill Boro, Cumberland County ~y Com!."jssj~~:f_~~I~~~J.uix..23.._ 20Q9 COUNTY OF CUMBERLAND On this the J)YfJ day of ) ) SS: ) h~~ undersigned officer, personally appeared I.:INDSA Y T. SEMUT A, known to me (or , 2007, before me, a Notary Public, COMMONWEALTH OF PENNSYLVANIA the satisfactorily proven) to be the person whose name is subscribed to the foregoing instrument and acknowledged that helshe executed the same for the purposes therein contained. IN WITNESS WHEREO~: her.:WZd and nOlorial seaL My Commission Expires: co NWEALTH OF PENNSYLVANIA Notarial Seal Sue J. Kotalik, Notary Public Hampden Twp., Cumberland County My CommIssion Expires Sept. 16, 2007 Member, Pennsylvania Association of Notaries to-.) = <:= -oJ ::;: :;po. ;;0 N I.D o -n .-1 :ell f11p -Om :~26 ~~~~ (3m --I ~ -a .......,.. ~ <2 co .. ... MAR 30 2007 4,/ )- ADAM L. DONAHUE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. 01-3706 CIVIL ACTION LAW LINDSAY T. SEMUTA, formerly known as LINDSAY A. TAYLOR, Defendant IN CUSTODY ORDER AND NOW, this ~ day of -M--, 2007, upon consideratiou of the within Custody Stipulation entered between the parties in which they have set forth their agreement regarding legal custody, primary physical custody, partial physical custody and visitation of their minor child, namely, Averi Alycia Taylor, it is hereby Ordered and Decreed that said attached Stipulation shall Dated: J. become an Order of Court, and the Court does hereby adopt said Custody S . Attest: >- ~ t--= U.J C) ~2~~ (ck; r-::= ,'(J Dei: wD- :d lLl u... -- r:= u.. o M lJ"') ,- M x: 0- M I n:::: 0- <: r-- = = c--.l {:A ~ => u ADAM L. DONAHUE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. 01-3706 CIVIL ACTION LAW LINDSAY T. SEMUTA, formerly known as LINDSAY A. TAYLOR, Defendant IN CUSTODY CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date, a true and correct copy of the foregoing Court Order and Custody Stipulation was served by first class mail to the following: Kent H. Patterson, Esquire 221 Pine Street Harrisburg, PA 17101 By: !iP------ ~--S- Herbert P. Henderson, II, Esquire Date: Lf/ttJ /D '7 I ~ = = --J o 11 .-'1 ..... ___ -n rnp :S!j."; j)X ;~~~\ ~f';, <;:~ ?,~l br-n -\ \> ~:o -=-< :.tP -0 ?J o -0 :x: c:> .s:-