HomeMy WebLinkAbout94-00872
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FE B 2 ;; 1994 c:h--.
Jt Nhl
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Jll.J.nt.J.lt
'IN 'l'H. COUR'l' 01' CONNON fLUB 01'
,CUHBBRLAND COUN'l'r, fBNNS'iLVANIA
,
,CIVIL AC'l'ION - LAW
,
,NO. r 7.L CIVIL 199'{
ICUS'l'ODY/VISITATION
* flfV1t/~
V
..I. VIA ,
" Ir/liNd"
Defendant
ORDEJt or COURT
(VI,.rel. I 1'\(,
AND NOW, this (date)' I~, upon consideration of
.tt.ched complaint, it is hereby directed at the par
their respective counsel appear before
the concil~~or, at ,~- . .
on the -; day 0 ,
M.,~r a Prehearing CUB 0 Y Con erence. At uch con erence,
.n effort will be made to resolve the issues in dispute, or J.f
this cannot be accomplished, to define and narrow the issues to be
heard 'by the court, and to enter into a temporary order, Sither
party may bring the child who is the subject of this custody
.ction to the confer'ence, but the child/children's attend/lnce is
not mandatory. Failure to appear at the conference may provide
grounds tor entry of a temporary or permanent order.
the
elf .ncl
do,s t:Y
,
7
FOR THE COURT I
By' . ~L"..f ,A~
~u~t~dy Conciliator. '
rou SHOULD TAKB THIS PAPER TO 'lOUR LAWl'ER AT ONCE. IF rou DO NO'l'
HAVB A LAwrER OR CANNOT AFFORD ONB, GO TO OR TELEPHONE THE OFFICS
SE'l' FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF TilE COURT ADMINISTRATOR
COURTHOUSE, FOUIU'H FLOOR
CARLISLE PA HOll
(717)240-6200
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APR 13 199~
dA-
,J;:
VI.
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IN TNB COUR'f OF COKI\ON
PLB~8 OF CUMBBaL~ND
COUNTY, I'BNN8YIN~NI~
NO, 94-872 CIVIl,
CU8TODY
~BPpaBY 8. MUNDIB,
PlaintUf
~NGBL~ K. MUNDIB,
Defenllant
AND NOlI, t.hls t{'" day of IA..:.J>>D , 1994, both parties having appeared
bofore the conciliator and having aU:-:on the terms and provisions of this order,
which was dictated In their prltKltnCe and approved by the., Wit hereby order and decree
as follows I
1. Legal and physl~al cUKlody of tho parties' minor ~hlld, Tyler B. Mundis, born
~une 9, 1993, shall be with t.he mother.
I
I 2, Father ehall have the following perlode of temporllry or partial cust.ody of the
I chUdl
~. UntU t.ho child Is ltnl'olled in a pre-school pl'ogralll or eleMentary
II school, eVOl'y other week from 10100 a.m. on Prlday until 6tOO P,Ill. on
I Baturday, cOllMl1endng on Pdday, ~prll 15, 1994.
8. For a period of at leael eight (8) hourn evel'Y Christ.mas Day, t.he
precise tl.o to blt determined by t.he parUlts.
C. The following holidays, on an alternating baslsl Independonce Day,
Thankaglvlng Day, New Yoar'a Day, and Easter. The fat.her's holidays nhall
COllllllen(!e with hllll having t.ho child on Independence Day In 1994.
D. ~ny other times and days that. the partlos can mutually agree upon.
3. For each period of. hln part1.l1 or t.emporary cust.ody wlt.h the ehlld, the father
shall pick the child up at tho delllgnated t1mo at t.he mother'lI residence with her
parents and ret.urn the child to t.he samo pI a'le at. the end of h is per lod.
4. Ahould tho father be unable to exerelse any or hill perlodll of part.lal custody,
II he shall give tho mother reasonable ,Idvan,!e nnUee of t.hat.
" I
.
I 5. The parti~a May a9roe at any tiMe to extund, reduce, or otherwise vary frOl
I thia schedule. HlJwever, should at any tllllu the parties filil to Mutually a9ree on the
extent, instance., or tiMes of such partial custody, either party May 'live notice to
the other that the partlill custody ahall be relnstitute.1 strictly In accordance with
tho schedule aa set forth herein alld t.he parties shall, therllllfter, cOIIply with the
schedul~ lIet forth In this ordur until they clIn Mutually a9reo to any other changel,
6. The partlen Bhall dlacuBB and cooperato on lIIatters pertalnln9 to th~ child'.
heal th, education, and gener.11 1101 fare, recolJnldnlJ that the general 11011 bein9 of the
child in of paralllount IntereBt. to thelll. R1ther paront shall have lull accen to
I.edlcal an" other recordB relating to t.he child and t.he cue for the child and tbe
I parties will cooperate In lIIaklng Buch Information available to each other,
I
i 7. Neither party Bhall in any way Interlere with t.he lIIalntenance of the love and
affection blltween t.he child and the other parunt. Ne1the.' will do anything to obstruct
reanonable cOlllllllnicatlon betwl,en the child and the other parent by letter or by
telephone, Neither party "hall Bpeak nelJatively about the other either in front of the
child or to the child. Both will at all t.Il1en encourage the developMent and
continuation o~ a caring parental rel'ltionnhlp bAtween the child and the other pBrent,
I
By the Cou t,
J.
I lJeUrey B, Hundie, pro Be
6404 [,eKington llrlve
I Hechanlcsbur9, PA 170M'>
I,
~I An91lh It. Hundis, pro 8e
'I HeR 67
I Box 166
I Hlftl1n, PA 170~8
I Ralph Gerlllak, EnqUire
, Attorney lor llelendant
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JF.PFRBY S. MUNDIS,
I'ldnt1tf
)
IN THI COURT OF COHHON
PLIAB OF CUHBI!RI,AND
COUNTY, PENNBYLVANIA
I
I ANGllI,A K. MUNllI B I
I Defendant
I
I JUDGI! PREVIOUBl,y ABBIGNEI); None
I
I
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I IN ACCOIlIJANCIl WITH CUMBIlRLAND COUNTY RUlJP, OF CIVIL PROCBIlURB 19l!L 3-8(b) I the
II undersigned Custody Conciliator nubmltn the following report;
'I
1. The pert.inent. infol'm,lUOn concerning the child who Is the subject of this
vs.
NO.
94-87:1 CIVIL
CUSTODY
rntifJ!!U"mL COH'BlIlNClJ.!ItItAIY RBPOl'l
I1tlg8tloll in as followSI
~
CURRBNTI,Y IN
f,UBTODY OF
Defendant/Hother
!!1.RTHDAT~
Tyler S. Hundis
9 Juna 1992
2, A Conciliat.lon Conference WBR held on 7 April 1994 and the following
individuals were prenentl tho PI~intiff and Defendant both appeared without counsel.
3,
Bhortly after these parties separated, each of them filed a custody action,
"
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'I i the father In Cumberland County and thR mother In Juniata county. It appears that the
I parties and the dllld last rllnlded togllther In Cumberland County and that Cumberland
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I County is the hnt county In whl/!h the child resided t1)r six Months continuously, Por
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I that reason, cumberland County Is the propar venue for this action.
,
II 4. Judqll QUigley ntayed the Juniata County action to see whi.t order light be
I,
I entered In this action. After he did so, the parties, with the aS81stanoe of the
"
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. lother I 8 attorney, Ralph IJl.rmak, F:nqul I'll, I'n~(~hlld ~n dgrllllmllnt whl ch HI', Gerlak sent to
"
me the day before our custody conferenue. A copy of that. aqreelllent 18 attached.
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~. The parties agreed that the Court of Cu.burland County should enter an order
incorporating the ter.n of their agreu.ent, I dictated the attached order in their
presence and t.hey agreed to \t,e terlllll and agulId that it be entered in the fon, I
dictated it,
6, Witb tbe entry of tbe attached order, no furtber proceedings are necessary It
thh U..e,
U AprU 1994
~.~
e I I,~ And8ll
Custody Conciliator
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~.f'R.Y ~. MUNDIS I J,. 'J'Hll COURT Oli' CarmON PI,P.MJ OF
I CU"'B~Rl.ANl) COUN'tV, PE"NSn.V~NIA
Plaintiff I
I CIVU.. MTtoN . tAW'
v. I
I
ANGBLA ~. IlUlfDIS I NO. 872 CIVIL 1994
I
Defendant I CUSTODY/VISITATION
- I)nd -
IN TH2 COURT OF CO~IHON PLEAS OF
THE 41BT JUDICIAL DISTRIC~
OF PENNS~LV"NI^
JUNIATA COUNT~ BRANCH
ANGBLA I{. IlUlfDIIJ I
Plaintiff I CIVIL MTION - CUS'X'ODY
v. I
I
JEFfREY S. MUNDIS I NO. 6~ OF 1994
Detendant I
CUSTO.\ll....MB.B.6HE.Ia
THIS AC~UM1!:NT is lIIade betweon Jotfrey S. "lindiG, hereinafter
refured to as "Father", and Anqcla K. Mundis, hereinafter retert'ed
to as "Mother",
WH!J~f:"'S, Father and Mother Ill'C t.ho nntural porents of a llIinor
ohild, TVler S. Mundis, whoso date ot birth is Juno 9, 19921 and,
WHEREAS, Father IInd Mothllr hovo r;\e(Jarnted and Ilgreed to live
separate and apart/ and,
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.
WHEREAS, Father fUeeS II complaint tor CUltody on March 1, 1994
in the court of COlnmQn fleas, cumberland County, Pennlylvanh,
whioh w.. docketed to No. 87~ civil 19941 and,
WHEREAS, Mother filed a Petition for Custody on March 2, 1994
in the 41.t Judioial Dietriot, Juniata county Branoh, which was
docketed to No. 62 of 1994, and,
WHEREAS, the cumberland County mlltt~r WaG referl."ed to custody
conoiliator Samuel L. IondefJ, before whom a Pre"Hearing CUfJtody
conferenoe wao8oheduled for April 7, 1994, and,
WHEREAS, the Juniata county matter was scheduled for a Pre-
Hearinq Conferenoe before Judge l<eith n. Quigley for Karch 21,
19941 and,
WHEREAS, on Maroh 21, 1994, JUdge Reith b. Quigley issued. an
Order, aaid Order b attaohed hereto an ~xhiblt 1111."/ and,
WHEREAS, the parties are aware that the Ct>Urt8 look with favor
on resolut1on Of custody matters by Private Aqreement of the
parties, and,
WHEREAS, the parties are aware that in oustody mattera, the
beet interest. of the ohild is the controlling taotor, end,
WHBREAS, the parties have entered into an A9reement regarding
oustody and visitation which they desire to have inoo~porated into
a court decree, and,
,1-110: P 1 a IIIIlIlB .1)
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NOW THEREfORE, tho partieD intending to bo legally bound Ind
desirillq to have the terms or thl, agreement be inoorporate<1 into
a Court Order agree a. follows.
1. Le9Al and physical custOdY of tho JIIinor ohild of the
~arri.qe, Tyler B. Hundie, Ohal\ be w th mother. Father 81'1.11 h,ve
the right of visitation with the child or to take partial oustody
of the ohild AS tolloWSI
A. until the ohild is enrolled in
elel1lentllry school, every other weokond from
Friday until 6100 p.m. on Saturday,
B. For a period ot lit Uast eiqht
Chdstmas Day,
c, Beginnin9 on July 4, 1994, on overy other one of ~he
tollowi n9 holidaYlill Independence Day, 'thanksqlving, New
Year's Day, and Easter,
pre-school or
10100 a,m. on
(8) houro on
D. All othet' days thot the partiills can agree.
;I. For oaoh period of parthl oustody, Fathor phall pick the
ohild up at the designated time at Mother's ro.idonce and ret~rn
him at tho dosignated time to Mother's residenoe,
3. Should Father be unable to exercise partial oustody on
any partioular oooasion, he shall noUfy ,",other a roasonable amount
of time before the time for partial custody.
4. Tho parties JIIay agroe at any time to extend or reduoe
this sohedule. However, should at any time the parties tail to
aqreo on the extent, lnatanc$$, or timos ot partial oustody, either
part~ lIIay give notice to the other that partial cU8tody ahall be
reinstituted striotly in nccordance with the sohedula as set forth
in this Paragraph.
5. It is agroed by tho particD that they will discuss and
cooperate on matters pertaining to the ohild'8 health, eduoation,
ond general weltare, acknowlcdqing that tho general well-being of
tho ohild is ot paramount im~ortftnce,
.
,JBFFRBY S. HUNIlIS, IN THE COURT OF COHHON
Plaintl.U PL~~S Of CUHBERLANIl
COUNTY, PENNSYLVANIA
VS.
i: NQ, 94-87:1 CIVIL
!I ANGELA K. HUNIlIS,
Defendant CUSTODY
II "
II Q&>>B
,I
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Ii AND NOV, tbis day of , 1994, both parties havinq appeared
Ii before the conciliator and having agreed upon the terms and provisions of this order,
I: which was dictated in tbeir presence and approved by them, we b'lreby order and decree
I, as follows r
1, Legal and physical custody of the parties' minor child, Tyler 8, Hundis, born
,
: ,June 9, 199:1, shall be with the mother,
I :/, Father Ilhall have the following periods of temporary or partial custOdy of tbe
I: chlldr
A, Until the child is enrolled in a pre-school program or elementary
school, every other week from 10:00 a.m, on Priday until 6100 p,m. on
Saturday, commencing on Priday, April 15, 1994.
.
&, for a period of at least eight (8) hours every Chrilltmas Day, the
precille time to be determined by the parties,
C. The following holidaYIl, on an alternating basis: Independence Day,
Tbanksgiving Day, New Year's Day, and Easter. The father's holidaYIl shall
commence with him having the child on Independence Day in 1994,
0, Any other times and days that the parties can mutually agree upon,
~. For eacb period of his partial or temporary custOdy w1th the chlld, the father
shall pick the child up at the designated time at the mother's residence with her
parents and return the child to the same place at the end of his periOd.
4. Should the father be unable to ex'ercise any of hin periods of partial custody,
he shall give the mother teasonable advance notice of that.
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~, The partlea may agree at any time to extend, reduce, or Qtherwlae vary from
th1a achedule, However, ahould at any time the parties fall to mutually agree on the
extent, inatancea, or timea of luch partial cuatody, either party may give notice to
the other that the partial cuatody 8hall be reinatltuted 8trictly In accordance with
the 8chedule as 8et forth herein 8nd the partiea 8hall, thereafter, cOMply with the
Ichedule aet forth In thia order until th8Y can mutually agree to any other changel,
6, The partiea ahall dlacuaa and cooperate on mattera pertaining to the child'a
health, education, and general welfare, recognizing that the general well being of the
child la of paraMOunt interest to them. Bither parent shall have full accea. to
.edlcal and other records relating to tho child and the care for the child and the
I' parties will cooperate in making such information available to each other,
7. Neither party 8hall in any way Interfere with the maintenance of the lQve and
affection between the child and the other parent. Neither will do anything to ob8truct
'I rea80nable communication between the child and the other parent by letter or by
telephone, Neither party 8hall speak negatively about the other either in front of the
chUd or to the chUd. Bolh will at all time8 encourage the developnlltnt and
I continuation of a caring parental relationship between the child and the other parent.
,
"
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By the Court,
I:
': Jeffrey 8. Hundh, pro II
" 6404 LeXington Drive
, Heehanlcaburg, PA 170~~
Ii Angela IC, Hundh, pro Be
HCR 67
Box 166
HiUlin, PA l70~B
J.
"
. Ralllh Oerllak, BsqUI re
Attorney for Defendant
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II
J~FFR~Y S. MUNDIS,
Plaintiff
IN THE COURT OF COMMON PL~AS OF
CUMBERl,AND COUNTY, PENNSYLVANIA
NO, 94-872 CIVIL
v.
ANGELA ~. HUNDIS,
Defendant
CUBTODY
"
COMPLAINT rOR CUITODY
AND NOW, comes the Plaintiff, Jeffrey S. Mundis, by and
through his attorneys, Saidis, Guido, Shuff & Masland, and
respectfully avers the followingl
(1) Plaintiff is Jeffrey S. Mundis, an adult individual
residing at 6404 Lexington Drive, Mechanicsburg, PennsylvAnia
i
l7055.
I
(2) Defendant is Angela K, Mundis, an adult individual
residing at RR *l, Box 87, E, Waterford, Pennsylvania l702l.
(3) Plaintiff is seeking custody of Tyler S. Mundis, Date
of Birth June 9, 1992.
The child was not born out of wedlock,
Tho child is presently in the custody of the Defendant at
R~ *l, Box 87, E, Waterford, Pennsylvania l702l,
During the past five years the child has resided with
the following persons at the following address~
Person
Addreee
I2AU
Birth to
8-2-93
SAIIIIS, C;UIllO
.. MASUNIl
26W, Ifl~h SII'"
C"II.'.. "^
Jeffrey S, Mundis &
Angela K, Mundis
Jeffrey B. Mundis &
Angela K, Mundis
Angela K. Mundis &
Kevin MaM
9-5-93 to
10-11-93
8-2-93 to
9-~-93
6403 Glenwood St,
Mechaniceburg, PA l7055
6403 Glenwood St,
Mechanicsburg, PA 17055
Bome motel in Oillsburg
Angela K, Mundis'
Ben Deiter & Sandy
Deiter
HeR 67, Box l66
Mifflin, PA 17058
lO~ll-93 to
5-1-'il4
Angela K. Mundis'
Some unknown man
RR 11, Box 87
E. Waterford, PA 17021
~~l-94 to
Present
The mothsr of the child in the Defendant, c~rrently
residing at RR il, Box 87, E, Waterford, Pennsylvania 1702l.
Bhe is currently separated,
The father of the child is the Plaintiff, currently
residing at 6404 Lexington Drive, Mechanicsburg, Pennsylvania
l705~, He is currently separated.
(4) The relationship of the Plaintiff to the child is
that of natural father, The Plaintiff currently resides with
the following personsl
HAIlll
Relationship
Parents
Barry L. Mundis &
Joan L. Mundis
(5) The relationship of the Defendant to the child is
that of natural mother. The Defendant currently resides with
some unknown man,
SAmlS, (il! mo
a MASl.ANU
16 W. 1Ii.h SI"'I
('atIl5ht, PA
(6) ~laintiff has participated in other litigation
concerning the custody of the child, namely a prior custody
petition filed on or about March 1, 1994.
Plaintiff has no information of a custody proceeding
concerning the child pending in any other court of this
Commonwealth.
Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the child or claims to
have custody or visitation rights with respect to the child,
t,
,
YI~I' ;CATION
.
I verl~f th.t the .t.t.mente m.4e 1n th1. Comp1.1nt .te
tr~e .n4 oorreot. I ijn4eretand that t.l.o .t.toment. heroln
are m.de e~bjeot to tho pen.ltlee of 18 PI. C.S. Seot1on 4904,
relatln; to uneworn t.l.ltloatlon to the authotlt1e..
DATIDI ,1.,- - /.;) . 9t.J
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" MAILAN.)
I. W, MI.~ II,HI
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JUL 0 8 199~J
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JBFFRBY 8, KUNDI8,
I Plaintiff
I VI.
I ANOllLA It. KUNDI8,
I Defendant
I
IN THB COUaT OF COHMON
PLBA8 OF CUKBERLAND
COUNTY, PBNN8YLVANIA
NO. 94-873 CIVIL TBRH
CU8TODY
9I>>Il
AID NOlI, this It ~ day of ~ , 1994, upon receipt of the
conciliator's report, it appearing ~h~~~e parties have agreed to the terMI and
provisions of this order which has been approved by the~ and their counsel, we bereby
vacate our order of April 14, 1994, and replace it with the followingl
1. The parties will share legal c~stody of their minor child, Tyler 8, Mundis,
born June 9, 1993,
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I 3.
II the Defendent, Angela K. Kundis.
Primary physical custody of the said minor child shall remain with his .other,
3. The father of the child, the Plaintiff, Jeffrey S, Mundis, shall have and
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i enjoy the following periods of temporary or partial custody of the child I
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A, Alternating weekends from Thursday morning at 10100 a,m.
until noon on Sunday, cOMmencing on Thursday, July 7, 1994,
B. For a period of at loast eight (8) houri every Christmas
Day, the precile time to be determined by the partiel.
C, The following holidays, on an alternating basisl
Independence Day, Thanksgiv illg Day, New Year' 0 Day, and Balter,
The father's next holidlY shall be on New Year's Day, 199~.
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D. ~t other tiles and days that the parties .ay lIutually
agree.
3, For each period of hls partiai or temporary custody with the child, the fBthu
ahall pick the child up at the designated time at the mother's residence in Bait
Waterford, Pennaylvania, or at auch other place an the partios may at that tile agree,
II and return the child to the sanle place or at such other place lIB the partiel lilY th.n
agree,
4. Should the father be unable to exercise any of hin periods of temporary or
partial custody, he shall give the mother reasonable advance notice of that,
5. The parties may agree at any time to extend, reduce, or otherwiae vary frOll
thil Ichedule, However, should at any time the parties fail to mutually agroe on the
extent, instanc.., or times of such partial custody, either party may give notice to
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the schedule an set forth herein and the parties shall, thereafter, comply with the
Ichedule set forth in this order until they can mutually agree to any other change..
6. The parties shall discuss and oooperate on matters pertaining to the child'~
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! health, education, and general welfare, rec09ni~inq that the general w.ll being of the
I child ls of paramount interest to them.
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Either parent shall have full access to
medical Bnd other records relating to the child and the care for the cbild and the
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'I parties will cooperate in making such information available to each other.
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7. Neither party shall in any way interfere with the maintenance of the love and
affection between the child and the other parent. Neither will do anything to obstruct
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I! ulIBonable clltllMunication between the l!hlld and the other parent by letter or by
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JBffRBY B, MUNDIB,
Plaintiff
IN THB COURT Of COHHON
PLB~S Of CUMBBRL~ND
COUNTY, PBNNBYLVANIA
NO. 94-81~ CIVIL TBRH
vs,
~NGEL~ K. MUNDIB,
Defendant CUSTODY
JUDGB PREVIOUSLY ~SSIGNBD; The Honorable George E. Hoffer
CONCILIATOR CONfBRDlCB BUlllAJY RBP.9U
IN ~CCORDANCE WITH CUHBBRLANll COUNTY RULE Of CIVIL PROCBllU_B 191b.3-8(b), the
undersigned CUstody Conciliator submits the following report;
1. The pertinont Information concerning tho child who is the sUbject of this
litigation is as followsl
rwm
CURRENTLY IN
~lll
!l!1!.'!'JillA'EE
Tyler B, Mundie
9 June 199~
llefondant/Mother
~. A Conciliation Conference was held on 5 July 1994 and the fOllowing
individuals were prosentl the Plaintiff and hie attorney, Johnna J, Deily, Bsquire/
the Defendant and her attorney, Ralph Germak, Esquire.
3, The parties appeared before me, without counsel, in April of 1994, At that
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,I tiMo they agreed upon an order which I prepared and was entered by the court,
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4. Since that time a few of the details of thoir arrangements have Changed and
I they have agreed to expand the father's time with the child, This time they ap~eared
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with counsel and were ablo to agree upon tho changes they wished to make, The attached
order was dictated in their presence and approved by them. With the entry of this
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Jllf'f'Rt:Y S. MUNDIR, IN THE COURT OF COHMON
Plaintl tf PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
VI.
NO. 94-873 CIVIL TERM
ANGELA K. MUNDIS,
Defendant CUSTODY
9J>>JlI
AND NOlI, this
day of
, 1994, upon receipt of the
conciliator's report, it appllaring that the parUes hsve agreed to the terms and
proviB1ons of this order which haB been approved by them and their counsel, we hereby
vacate our order of April 14, 1994, and replace it with the followingl
l. The parties viII share legal custody of their minor child, Tyler S. Mundis,
born Juno 9, 1993,
2. Primary phyuical custody of the said minor child shall remain vith his mother,
the Defendant, Angela K. Mundis.
3. The father of the child, the I>laintlff, Jeffrey S. Mundis, shall have end
enjoy the following perlodu of temporary or partial custody of the child:
A. Alternating weekends from Thursday morning at 10100 a.m.
until noon on Sunday, commencing on Thursday, July 7, 1994.
B. For a period of at least eight (8) hours every Christmas
Day, the precise time to be determined by the parties.
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C. The lollowlng holidays, on an alternating basis:
Independence Day, 1'hanksgl v Ing Day, New Year's Ilay, and Easter.
Tbe father's next holiday shall be on New Year'u Ilay, 1995,
I), At other timea and daya that. the parties may mutually
a9ree.
3, For each period of hia partial or t.emporary cuatody w1th the child, the father
shall pick the child up at the denlgnated time at the mother'a residence in East
Water ford, Pennaylvania, or at such other place as the partiea may at that time agree,
and return the child to the aame place or at such other place aa the partiea may then
agree.
4. Should the father be anable to exercine any of hin perioda of temporary or
partial caatody, he shall give the mother reasonable advance notice of that.
5. The parties may agree at any time to extend, reduce, or otherwise vary from
thia schedule, However, should at any time the parties fail to mutually agree on the
extent, instancen, or times of such partial custody, either party may give notice to
the other that the partial custody shall be reinstituted strictly in accordance with
the schedule as set forth herein and the parties shall, thereafter, comply with the
schedule set forth in this order until they can mutually agree to any other changes.
6. Thl! parUes shall discuss and cooperate on matters pertaining to the child's
health, education, and general welfare, recognizing that the general well being of the
child is of paramount interest to them. Either parent shall have full access to
medical and other records relating to the child and the care for the child and the
parties will cooperate in making 8uch information available to each other.
1. Neither party shall in any way interfere with the maintenance of the love and
affection between the child and th.. other parent. Nelther will do anything to obstruct
reasonable communication hetween the child and Lhe other paront by letter or by
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telephone, Neither party shall Rpeak ne~ative1y about the other either !n front of th.
ohild or to the ohi1d. Both vi1l at all limeR encQura~e the development and
continuation of a carin~ parental relationRhip betve~n the child and the otber parent.
By the court,
J.
Johnna J. Dei~y, Eequire
Attorney for Plaintiff
Ralpb Oermak, ERquire
Attorney for Defendant
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