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HomeMy WebLinkAbout06-5094 SAIDIS, FLOWER &. UNDSAY .... '1.__. .,..lIUAW 26 West High Street Carlisle,PA " ILLIAM HOTHAM, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. be..- ~Oq'f ~-rtN-- : CIVIL ACTION - LAW : IN CUSTODY v. ONNA HOTHAM Defendant NOTICE TO DEFEND OU ARE HEREBY NOTIFIED to plead to the within New Matter and Counterclaim ithin twenty days after service of this New Matter. Respectfully submitted, SAlOIS, FLOWER & LINDSAY ated: r,/2. 4/0& ~~~~ Attorney rd. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, F1.OWER &. IlNDSAY AI.......,~I"W 26 West High Street Carlisle.PA " ILLIAM HOTHAM, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 0(,- ~oq't ~ T...- v. ONNA HOTHAM Defendant : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY I. The Plaintiff is William Hotham, an adult individual currently residing at 537 Appalachian Avenue, Mechanicsburg, Cumberland County Pennsylvania. 2. The Defendant is Donna Hotham, an adult individual currently residing at 537 Appalachian Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant are the parents of two children namely: Brianna Marie Hotham, born December 16, 1998, and Adam Pierce Hotham, born October 23, 2001. The children were born during wedlock. 4. The parties presently share custody of the children, pursuant to a Custody Stipulation and Agreement executed August 3, 2006. 5. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESS FROMITO Plaintiff and Defendant 537 Appalachian Ave. Mechanicsburg, P A 2001-2006 6. The mother of the children is Donna Hotham, currently residing as aforesaid. She is married. SAIDIS, FlOWER &. LINDSAY .....~_.....J'oIAW 26 West High Street Carlisle, PA !1 7. The father of the children is William Hotham, currently residing as aforesaid. He is married. 8. The relationship of the Plaintiff to the children is that of father. The Plaintiff currently resides with the children on a shared custody basis, pursuant to the terms of the Agreement dated August 3, 2006. 9. The relationship of the Defendant to the children is that of natural mother. The Defendant currently resides with the children on a shared custody basis, pursuant to the terms of the Agreement dated August 3, 2006. 10. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the children in this or another jurisdiction. 11. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 12. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 13. The parties desire that the terms of the Custody Stipulation and Agreement executed by them on August 3, 2006 be incorporated into an Order of Court. SAIDIS, F1.OWER. &. UNDSAY "'I~......."........... 26 West High Street Carlisle,PA " , WHEREFORE, the Plaintiff requests this Court to grant him shared physical custody of the children. ated: co!z4/olo Respectfully submitted, SAlOIS, FLOWER & LINDSAY ~'~ Mary 0 atas, Esquire Attorney d.84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS. FlOWER &. LINDSAY ....._,.-......... 26 West High Street Carlisle,PA " VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and orrect on behalf of William Hotham who is outside the jurisdiction of this court and pon information provided to me by him. I understand that false statements herein are ade subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to uthorities. \; 24 O~ ate ~~7:l+ SAIDIS, FlDWER &. LINDSAY AII~""""~""'" 26 West High Street Carlis.ie,PA I' CERTIFICATE OF SERVICE I, Marylou Matas, Esquire, of the law firm of SAlOIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via certified mail, retum receipt requested, postage prepaid, addressed as follows: Donna Hotham 537 Appalachian Ave. Mechanicsburg, PA 17050 SAlOIS, FLOWER & LINDSAY ~ 7V~oko a atas, E quire Suprem Court 10 No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 "" 0 (") = C c:;> -n ~ "" -4 ~;.. ",. :::J:-n ~ -cr:~; c::: r11-::::- ~ l=~.' ; (;") -ofT. ~ , W ~nO ).> c::> L)(-S . ~;j"1-; ~ -0 ?j ::D .... -0'" ~.,. C) ....:\ ~ - ::'~:::rn "'l - .C- 0 ..., ..l ....... .. ~ ~ "n '" 0 '< CO "<) ;3 ...., " .' WILLIAM HOTHAM, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. Oc. - sO? y v. DONNA HOTHAM Defendant : CIVIL ACTION - LAW : IN CUSTODY STIPULATION AND AGREEMENT FOR CUSTODY . THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between DONNA HOTHAM (hereinafter referred to as "Mother") and WILLIAM HOTHAM (hereinafter referred to as "Father"). WHEREAS, the parties are the natural parents of the following two (2) children: Brianna Marie Hotham, born December 16, 1998, and Adam Pierce Hotham, born October 23,2001; WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive stipulation and agreement relative to physical and legal custody of their children; NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as herein set forth, the parties stipulate and agree as follows: 1. Mother and Father shall exercise shared legal custody of the children. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the children including, but not limited to, school and medical records and information. .' 2. Mother and Father shall exercise shared physical custody of the children as follows: The parents shall share custody of the children so that each parent shall exercise custody of the children during his or her time off from work. Specifically, Father works a shift-type work schedule with intermittent days off and Mother works a daylight schedule with regular weekends off. Each parent agrees to cooperate with the other so that the children can share equal time with each parent. It is anticipated that Father will provide care for the children at all times that he is not working. 3. The parent receiving custody shall provide transportation. 4 Holidays: The parties shall share holidays and other special days with the children, such as birthdays, so that each parent has the opportunity to enjoy time with the children on that special day, at times as may be agreed. 5. The Christmas holiday shall be shared so that in even numbered years, Mother shall exercise custody of the children on December 24 at 3:00 p.m. through December 25 at 3:00 p.m. and Father shall exercise custody of the children from December 25 at 3:00 p.m. through December 26 at 3:00 p.m. ill odd numbered years, Father shall exercise custody of the children on December 24 at 3:00 p.m. through December 25 at 3:00 p.m. and Mother shall exercise custody of the children from December 25 at 3:00 p.m. through December 26 at 3:00 p.m. 6 Vacation: Each parent shall be entitled to take at least two (2) non- consecutive vacations with the children, each vacation period to extend for seven (7) days. Said vacation should begin on a parent's regularly scheduled period of custody. The vacationing parent shall provide thirty (30) days notice of the requested vacation ". .' time to the other parent. If both parents have chosen the same time for vacation, the first parent to have chosen the time shall prevail. 7. The parties shall keep each other advised in the event of serious illness or medical emergency concerning the children and shall further take any necessary steps to ensure that the health and well-being of the children is protected. During such illness or medical emergency, both parties shall have the right to visit the children as often as he or she desires consistent with the proper medical care of the children. 8. Neither parent shall do anything which may estrange the children from the other party, injure the opinion of the children as to the other party, or which may hamper the free and natural development of the children's love and affection for the other party. 9. Any modification or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing, and only if executed with the same formality as this Stipulation and Agreement. 10. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor children. 11. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. 12. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. ..... IN WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. WITNESSETH: . />, ~~ ~ ~/'3/d~ ~,~/~ I { 8/?J/dt, I f William Hotham ,. . I." I verify that the statements made in this Stipulation and Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsifications to authorities. /1~ < William Hotham )~ - I verify that the statements made in this Stipulation and Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsifications to authorities. ';"(,' i~L.~ ~~ :::<f (') c:: -~ ~, CB/7i ~"', '. / 'J) C:> c:tl , ~ "'~ "'" "" c::: (j") r...., C:> ::r..:J _.c,', fi? 5! rr, ::n r-' -:Om :'jQ f~~1Cl (-~Y:r/ '~'e~ c) E5r'f -/ ;>~ .1:1 ~ _c-- v. RECEIVEL AUG 3 1 2006 BY: IVIJ : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. Cl~.6o~<j ~ T~ ) .' , , . .. . " WILLIAM HOTHAM, Plaintiff DONNA HOTHAM Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT 51~ AND NOW, this _ day of ~\;~t."'"~t(' , 2006, the attached Stipulation and Agreement for Custody is hereby made an Order of Court. BY THE COURT: ~-lflJ\ , \ \ J. cc: Marylou Matas, Esquire Attorney for Plaintiff Donna Hotham, pro se 537 Appalachian Avenue Mechanicsburg, PA 17055 q-S'-cJ(P C!, 1~6d ~ ~ eN \ \ \ \ \ \ , '\ , " \f!NVl\:1ASNN3d }J-NrJO') ::'8iNro IC:1I Wi S- d3S900Z Ai:lVLCNOrLOdd 3Hl :lO 301:\:10-0311::1 \ i .' , Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ? E l.. ?. r U WILLIAM HOTHAM, Plaintiff DONNA HOTHAM, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Defendant NO. 2006-5094 IN CUSTODY PLAINTIFF'S PETITION TO MODIFY CUSTODY 1. Plaintiff is William Hotham, an adult individual currently residing at 112 Coventry Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Donna Hotham, an adult individual currently residing 6 Locust Street, Shiremanstown, Cumberland County, Pennsylvania. 3. The parties are the parents of Brianna Marie Hotham, born December 16, 1998, and Adam Pierce Hotham, born October 23, 2001. 4. A Custody Order dated September 5, 2006, and Stipulation and Agreement for Custody was entered and is attached hereto as Exhibit "A." 5. Plaintiff requests the Custody Order be modified for the following reasons: a. Defendant lost her home in a Sheriffs Sale and Plaintiff believes she will soon be evicted when the new owners take possession of said home; b. Defendant is unemployed; and c. Defendant had back surgery and has been unable to sufficiently care for the children during her week of custody. 6. The Honorable M. L. Ebert, Jr., has signed Orders in this custody matter. 4 a"v -10.00 N 4t &!*a37Y3 Ro asuaLa4 WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a hearing at which Plaintiff requests the Court to grant Plaintiff the Custody Order. Pending said hearing, Plaintiff requests primary physical custody. MARTSON LAW OFFICES By. 1 Jennifer ears, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: '? - z I - ? ( VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. William D. Hotham RTILESTlient9\14280 Hotham\14280 Lcuscomplaint I 1 F:T1LES\C1ients\14280 Hotham\14280.1.pra Revised: 3/22/11 9 50AM WILLIAM HOTHAM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006-5094 c') Ca -n c C-5 DONNA HOTHAM, ?rn 3:10 m- Defendant IN CUSTODY == r :0 N n PRAECIPE try C3 s ?Q - TY ' rn : TO THE PROTHONOTARY OF CUMBERLAND COUN You are directed to attach Exhibit "A" to the Petition to Modify Custody filed chi March 22, 2011. MARTSON LAW OFFICES By Jennifer . pears, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: March 22, 2011 R WILLIAM HOTHAM, Plaintiff V. DONNA HOTHAM Defendant RECEIVED i AUG 3 1 2006 A t, BY. _ IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO, O 6 - Srb y i- Ct 7.?..r. CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ,?_-A day of C ???-r , 2006, the attached Stipulation and Agreement for Custody is hereby made an Order of Court. BY THE COURT: 1 J. 'MW copy "M I? l19r?cl1, here Uft ?. F' cc: Marylou Matas, Esquire Attorney for Plaintiff Donna Hotham, pro se 537 Appalachian Avenue Mechanicsburg, PA 17055 EXHIBIT "A" f THE COURT OF COMMON PLEAS : IN WILLIAM HOTHAM, ERLAND COUNTY, PENNSYLVANIA : CUMB Plaintiff r^-•J N :NO. $1J9Y V. CIVIL ACTION - LAW => r m -t r DONNA HOTHAM : IN CUSTODY - . Defendant ; ter, - f: STIPULATION AND AGREEMENT FOR CUSTODY THIS STIPULATION AND AGREEMENT entered into the day and y d between DONNA HOTHAM (hereinafter referred to as hereinafter set forth, by an ther") and WILLIAM HOTHAM (hereinafter referred to as "Father"). ,,M o arties are the natural parents of the following two (2) children: h e p AREAS, t a Marie Hotham, born December 16, 1998, and Adam. Pierce Hotham, born Briann October 23, 2001; WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive stipulation and agreement relative to physical and legal custody of their children; NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as herein set forth, the parties stipulate and agree as follows: 1. Mother and Father shall exercise shared legal custody of the children. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the children including, but not limited to, school and medical records and information. 2. Mother and Father shall exercise shared physical custody of the children as follows: The parents shall share custody of the children so that each parent shall exercise custody of the children during his or her time off from work. Specifically, Father works a shift-type work schedule with intermittent days off and Mother works a daylight schedule with regular weekends off. Each parent agrees to cooperate with the other so that the children can share equal time with each parent. It is anticipated that Father will provide care for the children at all times that he is not working. 3. The parent receiving custody shall provide transportation. 4 Holidays: The parties shall share holidays and other special days with the children, such as birthdays, so that each parent has the opportunity to enjoy time with the children on that special day, at times as may be agreed. 5. The Christmas holiday shall be shared so that in even numbered years, Mother shall exercise custody of the children on December 24 at 3:00 p.m. through December 25 at 3:00 p.m. and Father shall exercise custody of the children from December 25 at 3:00 p.m. through December 26 at 3:00 p.m. In odd numbered years, Father shall exercise custody of the children on December 24 at 3:00 p.m. through December 25 at 3:00 p.m. and Mother shall exercise custody of the children from December 25 at 3:00 p.m. through December 26 at 3:00 p.m. 6 Vacation: Each parent shall be entitled to take at least two (2) non- consecutive vacations with the children, each vacation period to extend for seven (7) days. Said vacation should begin on a parent's regularly scheduled period of custody. The vacationing parent shall provide thirty (30) days notice of the requested vacation time to the other parent. If both parents have chosen the same time for vacation, the first parent to have chosen the time shall prevail. 7. The parties shall keep each other advised in the event of serious illness or medical emergency concerning the children and shall further take any necessary steps to ensure that the health and well-being of the children is protected. During such illness or medical emergency, both parties shall have the right to visit the children as often as he or she desires consistent with the proper medical care of the children. 8. Neither parent shall do anything which may estrange the children from the other parry, injure the opinion of the children as to the other party, or which may hamper the free and natural development of the children's love and affection for the other party. 9. Any modification or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing, and only if executed with the same formality as this Stipulation and Agreement. 10. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor children. 11. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. 12. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. IN WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. r, WITNESSETH: nna Ho 8 William Hotham .r I verify that the statements made in this Stipulation and Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities. William Hotham I verify that the statements made in this Stipulation and Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities. CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Donna Hotham 6 Locust Street Shiremanstown, PA 17011 MARTSON LAW OFFICES By Tricia ckenroad Ten Ea High Street C Carlisle, PA 17013 (717) 243-3341 Dated: March 22, 2011 WILLIAM HOTHAM IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA C') -te C o n V ? F . 2006-5094 CIVIL ACTION LAW Z rn _<> w ° DONNA HOTHAM r-7: IN CUSTODY 3 r>-n >n DEFENDANT DC a ri tV r ORDER OF COURT AND NOW, Wednesday, March 23, 2011 , upon consideration of the attached Compla int, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 28, 2011 _ at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to 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/ john. Man an r. 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. 3 Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 NP, /? ao' WILLIAM HOTHAM, Plaintiff V. DONNA HOTHAM, Defendant Prior Judge: AfI. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 06-5094 CIVIL ACTION LAV IQ IN CUSTODY Mm Z: _V ?r c-? ti .C" ORDER OF COURT `' `r' AND NOW this 13 ' day of May 2011, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: rn? C 1. All prior Orders of Court entered in this matter are hereby VACATED and replaced with the instant Order. 2. Legal Custody: The Father, William Hotham, and the Mother, Donna Hotham, shall have shared legal custody of Brianna M. Hotham, born 12/16/1998 and Adam P. Hotham, born 10/23/2001. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: Father and Mother shall arrange physical custody of the Children on a repeating two week schedule as follows unless otherwise mutually agreed upon: a. During the school year, in week one, Mother shall have custody of the Children Monday from 4 pm until 7 pm, from after school Wednesday until Thursday morning bring the Children to school, and Friday from after school until Monday morning. b. During the school year, in week two, Mother shall have custody of the Children on Monday from 4 pm until, 7 pm and from after school Wednesday until Thursday morning. C. During the summertime, starting 2012, the parents shall share physical custody on a week on/week off basis from Sunday 6 pm until the following Sunday 6 pm. d. The parties may alter the above schedule by agreement. 4. Absent agreement otherwise, the Children shall continue in the South Middleton School District. The non-custodial parent shall have liberal telephone/email/text contact with the Children on a reasonable basis. 6. Counseling: The parties have agreed to, and shall, engage in therapeutic family counseling with Mock Mays, or some other mutually agreed to professional. 6. Holidays: The parents shall arrange the holiday schedule as mutually agreed upon. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. 8. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 9. This Order is entered pursuant to 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, G.- " Distribution: ' ? Jennifer Spears, Esquire Donna Hotham, 138 Sable Drive, Carlisle, PA 17013 MQl? John J. Mangan, Esquire ?oples V Q'14111 0 r6 J. ti i- WILLIAM HOTHAM, Plaintiff V. DONNA HOTHAM, Defendant Prior Judge: M. L. Ebert, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 06-5094 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Brianna M Hotham 12/16/1998 Father and Mother Adam P. Hotham 08/23/2001 2. A stipulated Order of Court was issued September 05, 2006 and a Conciliation Conference was held with regard to Father's Petition to Modify on May 11, 2011, an Order issued May 25, 2011 and a conference was held August 09, 2011 with the following individuals in attendance: The Mother, Donna Hotham, self-represented party The Father, William Hotham, with his counsel, Jennifer Spears, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date John J. an, Esquire Custody C ncihator