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HomeMy WebLinkAbout06-4299Jennifer L. Lehman, Esquire I.D. No. 52784 27 South Arlene Street P.O. Box 6130 Harrisburg, PA 17112-0130 (717) 671-1200 CHRISTIAN K. LILLER, Plaintiff V. DANIELLE CLAUSI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANI NO. 06-ig-9q -CIVIL TERM CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY COUNTI CUSTODY AND NOW, comes Plaintiff, Christian K. Liller, by and through his attorney, Jennifer L. Lehman, Esquire, and files this Complaint, based upon the following: 1. Plaintiff, Christian K. Liller, is an adult individual residing at 130 W. Main Street, Apartment 5, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant, Danielle Clausi, is an adult individual residing at 678 Cumberland Point Circle, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2 3. Plaintiff seeks primary custody of Trey Clausi, born July 24, 2001. Plaintiff is the natural father of the child and Defendant is the natural mother of the child. The child was born out of wedlock. The child is currently in the custody of Plaintiff and Defendant on a shared basis. 4. Since birth, the child has resided with the following persons and at the following addresses: Defendant Defendant's Husband, Maternal Grandmother and Half Brother Plaintiff Paternal Grandmother Paternal Grandfather Paternal Aunt Cumberland County 678 Cumberland Point Circle Mechanicsburg, PA 403 Candlewyck Road Camp Hill, PA Plaintiff 130 W. Main Street Apartment 5 Mechanicsburg, PA 17055 7/24/2001 to unknown time Unknown time to present 7/24/2001 to February 2006 February 2006 to present 5. Plaintiff has not participated as a party or a witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 3 6. Each parent whose parental rights to the child that have not been terminated and the person who has physical custody of the child have been named as parties to this action. 7. The best interest and permanent welfare of the child will be served by granting the relief because Plaintiff can provide a safe home and a stable and loving environment for the child. WHEREFORE, Plaintiff requests Your Honorable Court to grant him shared legal and primary physical custody of the minor child, Trey Clausi, with Defendant having periods of partial physical custody as agreed upon by the parties. COUNT II SPECIAL RELIEF 8. Paragraphs 1 through 7 of Count I are hereby incorporated by reference. 9. For the past three years the parties have shared legal and physical custody of Trey Clausi in that the Plaintiff has had physical custody from Thursday evenings through Monday evenings each and every week. 10. In the past few months the Defendant has married a man whose first name is Mark. 11. Within the past week the Defendant has informed the Plaintiff that her husband, Mark, has enlisted in the Army and must report to Fort Bragg in the state of North Carolina at sometime in August. 4 12. Defendant has informed Plaintiff that she intends to take Trey with her to live in North Carolina. 13. Plaintiff believes that it is in Trey's best interest to remain in Cumberland County and continues to remain in the close family environment in which he has thrived. 14. Plaintiff believes that North Carolina will not have appropriate jurisdiction to determine the custody arrangements for Trey. WHEREFORE, Plaintiff requests Your Honorable Court to enter an Order requiring Defendant to keep Trey Clausi in Cumberland County, Pennsylvania until such time as a Custody Order is established. DATE: 7- a r- Ao Respectfully submitted, Jenfiifer L.'Lehman, Esquire Supreme Court ID No. 52784 27 South Arlene Street Post Office Box 6130 Harrisburg, PA 17112-0130 (717) 671-1200 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. CHRISTLAW It. LILL R °Q w d O( u\ p a Q > O P t^ i1 t. n .`Q b p ?h CHRISTIAN K. LILLER, Plaintiff V. DANIELLE CLAUSI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANI NO. -CIVIL TERM CIVIL ACTION -LAW IN CUSTODY ORDER OF COURT ?? AND NOW this -L $ day of 1 J\ 1, uponto 00consideration of Plaintiff s request for special relief, it is here directed that Trey Clausi, born July 24, 2001, shall continue to reside in Cumberland County until further Order of Court. BY THE COURT: 7 4 t is ... CHRISTIAN K. LILLER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DANIELLE CLAUSI DEFENDANT 06-4299 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, August 01, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, September 06, 2006 at 10:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Dawn S. Sunda Es q. INA Custody Conciliator 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 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Z /? Aop A?P'?` ; jtr -2 ''fi'r t?- et i ~a ;;••;?r ?O r° ? CHRISTIAN K. LILLER, Plaintiff V. DANIELLE CLAUSI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-4299 CIVIL ACTION - LAW IN CUSTODY AFFIDAVIT OF SERVICE I, Jennifer L. Lehman, Esquire, hereby certify that a true and correct copy of the Complaint for Custody was served on the Defendant by certified mail, restricted delivery, return receipt requested, on August 3, 2006, at the Defendant's last known address of: Danielle Clausi 678 Cumberland Point Circle Mechanicsburg, PA 17055 The return receipt card is attached hereto as Exhibit "A". xn,, fig a ? J fer . Lehman, Esquire Attorney for Plaintiff EXHIBIT "A" • ComPIMe Nerrre 1, 2, and i Also owrvWe A. nut ttem 4 if Restricted Oeliv y is desired. ? Agent ¦ Print Your name and address on the reverse ? Addressee so that Yre can return the card to you. Mb (PrMlsd Name) C. Date of Drewry ¦ Attach this Card to the back of the malipiece, or on the front if speece permits.! D. Is Ram 17 C3 Yes 1. Article Addressed to: If YES, delivary addre?q ? No . N .. C t 3. 06 Express Mail l7 Rep Krum Rxrpt for Mmhandise / 17 smeared 'n C.O.D. 4. Restr%led De16ry7 XE &v Feel es 2. Article Nuro 7006 0100 0002 4043 1499 (fisnsbr {rem m service rabe) PS Forth 3811, August 2001 Domestic Return Reorpt 102505-01-WOW AFT, ?`: SEP 1 3 2006 CHRISTIAN K. LILLER IN THE COURT "ON? OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 06-4299 CIVIL ACTION LAW DANIELLE CLAUSI Defendant IN CUSTODY ORDER OF COURT `` AND NOW, this 15 _ day of S t,0tt.m ac.4` , 2006, upon consideration of the attached Custody Conciliation Report i is ordered and directed as follows: The Father, Christian K. Liller, and the Mother, Danielle Clausi, shall have shared legal custody of Trey Clausi, born July 24, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. Until such time as the Mother relocates to North Carolina, the parties shall continue sharing physical custody of the Child, with the Father having custody every week from Friday at 5:00 p.m., when the Father shall pick up the Child at the Mother's residence, through Monday before school. In the event there is no school on Monday and the Father is not working, the Father shall retain custody until 5:00 p.m., when the Mother shall pick up the Child. If there is no school and the Father is working, the Father shall transport the Child to the Mother's residence before work. The Mother shall pick up the Child after school on Mondays and shall have custody for the remainder of the week until Friday at 5:00 p.m. 3. At such time as the Mother relocates to North Carolina as planned, the Child shall remain in the Father's primary custody pending further agreement of the parties or Order of Court. 4. The parties shall cooperate in scheduling a period of Thanksgiving holiday custody for the Mother. The parties acknowledge that their agreement to the provisions of this Order was negotiated in contemplation of the Mother's impending move to North Carolina and that it is their intention to maintain stability for the Child during the transitional moving period and to review the custodial arrangements after the Mother is settled in 5 her new residence to determine the best interests of the Child at that time. To that end, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference within 3 months of the date of the Mother's relocation to review the custody schedule. 6. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, )? ?a , ? M. L. Ebert J. cc: 46?nifer L. Lehman, Esquire - Counsel for Father ,6race D'Alo, Esquire - Counsel for Mother n?r,r; _??, ,?-. r?? :, ._L _., CHRISTIAN K. LILLER Plaintiff vs. DANIELLE CLAUSI Defendant Prior Judge: M. L. Ebert IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-4299 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Trey Clausi July 24, 2001 Mother/Father 2. A custody conciliation conference was held on September 5, 2006, with the following individuals in attendance: The Father, Christian K. Liller, with his counsel, Jennifer L. Lehman, Esquire, and the Mother, Danielle Clausi, with her counsel, Grace D'Alo, Esquire 3. The parties agreed to entry of an Order in the form as attached. ?!?ep" Date Dawn S. Sunday, Esquire Custody Conciliator APR 1 5 2007 CHRISTIAN K. LILLER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 06-4299 CIVIL ACTION LAW DANIELLE CLAUSI Defendant IN CUSTODY ORDER OF COURT AND NOW, this I S1 day of ?\ a , 2007, upon consideration of the attached Custody Conciliation Report, it Is ordered and directed as follows: 1. The prior Order of this Court dated September 15, 2006 is vacated and replaced with this Order. 2. The Father, Christian K. Liller, and the Mother, Danielle Clausi, shall have shared legal custody of Trey Clausi, born July 24, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well being including, but not limited to, all decisions regarding his health, education and religion. Each parent shall be entitled to have equal access to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 3. The Father shall have primary physical custody of the Child during the school year, with the Mother having periods of custody with the Child at times to be arranged by agreement between the parties. 4. The Mother shall have primary physical custody of the Child during the summer school break, until no later than the second to the last weekend in July, when custody shall transfer to the Father for the remainder of the summer and the school year. 5. The parties shall share or alternate having custody of the Child on holidays as arranged by agreement. 6. This Order is entered pursuant to an agreement of the parties based upon the Mother's temporary relocation to Kentucky. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, ?N I M. L. Eb J. fer L. Lehman, Esquire - Counsel for Father cc: A " m DA race D'Alo, Esquire - Counsel for Mother 05, Z 1 • °7 d 1- AVW LOOZ h! l1G;T,X-dU?ci 3H1 J0 CHRISTIAN K. LILLER Plaintiff VS. DANIELLE CLAUSI Defendant Prior Judge: M. L. Ebert IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-4299 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Trey Clausi July 24, 2001 Mother/Father 2. A custody conciliation conference was held on March 21, 2007 with the following individuals in attendance: the Father, Christian K. Liller, with his counsel, Jennifer L. Lehman, Esquire and the Mother, Danielle Clausi, with her counsel, Grace D'Alo, Esquire. 3. At the conclusion of the conference, the Father requested additional time to further consider custodial arrangements for the school year and it was agreed that the conciliator would hold the report and order in this matter pending notification from either counsel. Having received notice from counsel that the parties agree that an Order now be entered based upon their agreements, the conciliator submits an Order in the form as attached reflecting the agreed upon custodial arrangements. r Y, Date Dawn S. Sunday, Esquire Custody Conciliator CHRISTIAN K. LILLER, PLAINTIFF/RESPONDENT VS. DANIELLE CLAUSI aka, DANIELLE L. TRAVITZ, DEFENDANT/PETITIONER : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 2006-CV-4299-CU : CIVIL ACTION -LAW : ACTION IN CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Petition and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Petition or for any other claim or relief requested by the Defendant/Petitioner. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 (717) 249-3166 1-800-990-9108 CHRISTIAN K. LILLER, PLAINTIFF/RESPONDENT VS. DANIELLE CLAUSI aka, DANIELLE L. TRAVITZ, DEFENDANT/PETITIONER : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA NO. 2006-CV-4299-CU CIVIL ACTION -LAW ACTION IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW, TO WIT, comes the Defendant/Petitioner, DANIELLE CLAUSI (now known as DANIELLE L. TRAVITZ), by and through her counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and files this Petition for Modification of Custody Order upon a cause of action of which the following is a statement: 1. The Defendant/Petitioner, (sometimes also known as Mother), is DANIELLE CLAUSI aka DANIELLE L. TRAVITZ, who currently resides at 3057 A Forrest Road, Fort Campbell, Kentucky, 42223. 2. The Plaintiff/Respondent, (sometimes also known as Father), is CHRISTIAN K. LILLER, who currently resides at 301 North Market Street, Apt B, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Defendant/Petitioner seeks Joint Legal Custody and Primary Physical Custody of the following child: Name Present Residence Date of Birth TREY CLAUSI 301 North Market Street, Apt B July 24, 2001 Mechanicsburg, PA 4. The child was born out of wedlock. 5. Trey Clausi is presently in the Primary Physical Custody of the Plaintiff/Respondent. 6. The mother of the child is Defendant/Petitioner who currently resides at 3057 A Forrest Road, Fort Campbell, Kentucky, 42223. 9. The father of the child is Plaintiff/Respondent who currently resides at 301 North Market Street, Apt B, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 10. Defendant/Petitioner has remarried. Defendant/Petitioner was married to Mark J. Travitz on June 27, 2006. Plaintiff/Respondent is not married. 11. The relationship of the Plaintiff/Respondent to the child is that of natural father. The Plaintiff/Respondent currently resides with only the child when he is there. 12. The relationship of the Defendant/Petitioner to the child is that of natural mother. The Defendant/Petitioner currently resides with her husband, Mark Travitz and their son, Anthony Travitz. 13. Defendant/Petitioner has participated as a party in a prior custody agreement concerning the custody of the child in this court. The court, term and number, and its relationship to this action are as follows: the court was Cumberland County, the docket number is 2006-CV-4299-CU, the result was a custody order dated May 1, 2007 (which is attached hereto and made a part hereof as Exhibit "A"). 14. Defendant/Petitioner has no information of a custody proceeding concerning the child pending in a court of this Commonwealth at this time. 15. Defendant/Petitioner 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. 16. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Father is an alcoholic and not able to provide a safe or stable environment for the child; B. Frequently, Father is not able to get out of bed due to his alcoholism to take care of the child and/or send him to school. Father reports to the school the child is ill, but the child states he is not ill, his Father will just not get out of bed to help the child get ready for and get to school; C. Father will not get out of bed to assist the child to go to the bathroom to get a bath or shower or brush his teeth. Father gives the child a bottle to pee in so Father does not have to get out of bed to take care of the child; D. The child frequently attends school without any bath or shower in the same dirty clothes the child has worn for several days; E. The child rarely is able to or encouraged to brush his teeth and suffers from toothaches due to untreated cavities. The Maternal Grandmother took the child to the dentist while caring for him. The child had a cavity so large a piece of his tooth had broken off, F. Recognizing his problems, Father, to his credit took this child to the home of his parents, the Paternal Grandparents who gave the child to the Maternal Grandmother, from March 17th, 2008 to April 24th, 2008, because he realized he was not able to provide a safe home or provide the necessary care for this child. But, Father then took the child back April 24th, 2008 and will not allow the Maternal Grandmother to have the child again; G. When the child is with the Maternal Grandmother, the child is frequently scared and worried he will have to return to Father's home; H. Mother believes Father's physical and psychological health is not well due to his alcoholism; 1. Mother fears greatly for her son's physical safety while in Father's home and Father's care; J. Mother has the ability to provide a stable, loving, safe and secure home for her son; K. Mother believes Father is not able to provide her son with a physical or psychologically safe environment, conducive to her son growing into the young man he is capable of being. 16. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Defendant/Petitioner, DANIELLE CLAUSI, requests this Honorable Court grant her FULL LEGAL CUSTODY and PRIMARY PHYSICAL CUSTODY with Plaintiff/Respondent, CHRISTIAN K. LILLER having PARTIAL PHYSICAL CUSTODY of the minor child, TREY CLAUSI. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: May , 2008 Susan Kay Candi o, squire Counsel for Defen a /Petitioner PA I.D. # 64998 4010 Glenfinnan Place Mechanicsburg PA 17055 (717) 724-2278 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of his knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. DATED: _ ?? - U 'APR 2 5 20071 CHRISTIAN K. LILLER Plaintiff VS. DANIELLE CLAUSI Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-4299 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this day of - consideration of the attached Custody Conciliation Order. 1. The prior Order of this Court dated September 1 2007, upon ordered and directed as follows: is vacated and replaced with this 2. The Father, Christian K. Liller, and the Mother, Danielle Clausi, shall have shared legal custody of Trey Clausi, born July 24, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well being including, but not limited to, all decisions regarding his health, education and religion. Each parent shall be entitled to have equal access to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 3. The Father shall have primary physical custody of the Child during the school year, with the Mother having periods of custody with the Child at times to be arranged by agreement between the parties. 4. The Mother shall have primary physical custody of the Child during the summer school break, until no later than the second to the last weekend in July, when custody shall transfer to the Father for the remainder of the summer and the school year. 5. The parties shall share or alternate having custody of the Child on holidays as arranged by agreement. 6. This Order is entered pursuant to an agreement of the parties based upon the Mother's temporary relocation to Kentucky. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terns of this Order shall control. BY THE COURT, AA.4. ( -.JMA M. Il Eder( I J. cc: Jennifer L. Lehman, Esquire - Counsel for Father In rr" mm y hand Grace D'Alo, Esquire - Counsel for Mother an 0 C7 r C.;, c -a 1 t7 a Q (,.tl Ri 0 CO = G? CHRISTIAN K. LILLER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2006-4299 CIVIL ACTION LAW DANIELLE CLAUSI A/K/A DANIELLE L. TRAVITZ IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, June 03, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, June 17, 2008 at 3:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Es . Custody Conciliator 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 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 07 6, M?l A AIN ?? n*,n = ?tf' ZZ :Zl kid h- ' 84U 'W'O" C l40 30 JUN S 0 2006 CHRISTIAN K. LILLER Plaintiff vs. DANIELLE CLAUSI A/K/A DANIELLE L. TRAVITZ Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2006-4299 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this S? ? day of S J1 2008, upon consideration of the attached Custody Conciliation Report, it i ordered and directed as follows: 1. The prior Order of this Court dated May 1, 2007 is vacated and replaced with this Order. 2. The Father, Christian K. Liller, and the Mother, Danielle Travitz, shall have shared legal custody of Trey Clausi, born July 24, 2001. Major decisions concerning the Child including, but not necessarily limited to, his health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, 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 or information given to either party as a parent as authorized by statute. 3. The Mother shall have primary physical custody of the Child. 4. The Father shall have partial physical custody of the Child as follows: A. The Father shall have custody of the Child during the summer school breaks beginning in 2009 from after the last day of school through no later than August 1. The Father shall provide the Mother with at least seven (7) days notice of the date on which his summer period of custody will begin each year. B. The Father shall have custody of the Child for most of the Child's Christmas holiday break, with the Mother having custody for her family Christmas Eve celebration and the Father having custody from Christmas Eve after the Mother's celebration through Christmas Day and the remaining share of the Father's holiday custodial period. C. The Father shall have custody of the Child during the Child's spring break from school. D. The Father shall have custody of the Child at any additional times as arranged by agreement between the parties. 5. The parties shall share transportation for exchanges of custody at a mutually agreeable halfway point or as otherwise agreed between the parties. 6. The non-custodial parent shall be entitled to have liberal telephone and email contact with the Child. 7. The Mother shall provide the Father with any website information for the Child's school. 8. At the Mother's request from time to time, the Father shall promptly provide the Mother with written confirmation of the Father's compliance with the treatment program recommended by his physician/psychiatrist. 9. The Father shall refrain from consuming alcohol during his periods of custody with the Child. 10. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, hk - ?_ M. L. Ebert, Jr. J. cc: ?'J??nnnnifer L. Lehman, Esquire - Counsel for Father Susan K. Candiello, Esquire - Counsel for Mother 0_0 F I-C S rnl,c LL A111le txyn? t? IT ?r act I c :c d i - 7nr o9oz hods G,' .?.Ldd 3Hi jG CHRISTIAN K. LILLER Plaintiff vs. DANIELLE CLAUSI A/K/A DANIELLE L. TRAVITZ Defendant Prior Judge: M. L. Ebert, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2006-4299 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Trey Clausi July 24, 2001 Father/Mother 2. A custody conciliation conference was held on June 17, 2008, with the following individuals in attendance: the Father, Christian K. Liller, with his counsel, Jennifer L. Lehman, Esquire, and the Mother's counsel, Susan K. Candiello, Esquire. The Mother, Danielle Travitz, formerly Clausi, resides in Kentucky and participated in the conference by telephone. 3. The parties agreed to entry of an Order in the form as attached. Date 7 Dawn S. Sunday, Esquire Custody Conciliator