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JEFFREY K. WELSCH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 94 - 2389
KAREN R. WELSCH,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
You, JEFFREY K, WELSCH have been sued in court to modify
custody of the children:
Andrea Welsch.
You are ordered to appear in person before M',cl."" I L. /?,,,,,,,,< 181.
, the conciliator, at :p:? <; I '! I k S~. (&omf H; It
on the ~ 1 h. day of "T '" n (!' , 1996 at ,y:VO f ,m, ,
Michelle Welsch, Charlene Welsch and
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,
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...liI'r THE COURT:
Date: ..5:'- 3/-91:-
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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.
Court Administrator, 4th Floor
Cumberland County Courthouse
Carlisle, PA 17013
Telephone Number: (717) 697-0371
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JEFFREY K. WELSCH,
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
V8.
NO, 94 - 2389
KAREN R. WELSCH,
Defendant
CIVIL ACTION - LAW
CUSTODY
TEMPORARY CUSTODY ORDER
AND NOW, this
day of
1996, upon consideration of the Petition for Special Relief, it is
hereby ORDERED AND DECREED that an emergency custody conciliation
be scheduled as soon as possible and that the present Custody Order
is modified such that the father's physical custody of Michelle
Welsch be restricted to those times that she wishes to see her
father until such time as a conciliation conference can be
scheduled between the parties.
By the Court,
, J,
1.
Petitioner is Defendant above,
Karen R, welsch,
JEFFREY K. WELSCH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VB.
NO. 94 - 2389
KAREN R. WELSCH,
Defendant
CIVIL ACTION - LAW
CUSTODY
PETITION FOR SPECIAL RELIEF
Defendant, Karen R. Welsch, by and through her attorneys, Law
Offices of Craig A, Diehl, represents the following:
hereinafter referred to as the mother, who resides at 7103 Salem
Park Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055,
2, Respondent is Plaintiff above, Jeffrey K, Welsch,
hereinafter referred to as the father, who resides at 118 N, Front
Street, Wormleysburg, Cumberland County, Pennsylvania 17043,
3, The parties are the parents of the following children:
Name
Aqe
12
10
7
Michelle L, Welsch
Charlene E, Welsch
Andrea c, welsch
4, In 1994, A Complaint for Custody was filed in the above-
captioned matter by the father. A Custody Order was entered on
July 15, 1994 which provides for the custody of the parties' three
minor children,
5, The mother has been the primary caretaker of the children
since their births,
6, The father has had partial custody of the children as per
the Custody Order dated July 15, 1994,
7, The parties are now divorced and the father was remarried
this month,
8, The father will be relocating to Altoona, Pennsylvania in
July, 1996,
9, The parties have been working with a private mediator in
separate sessions since October, 1995, They have attempted to
resolve various issues regarding the custody schedule of their
children, especially in light of the fact that the father will be
moving very soon, Said mediation regarding the custody schedule
and other issues has been unsuccessful,
10, The relationship between the parties is very hostile,
thus chilling any negotiations regarding the various custody
issues,
11, The hostility between the parties has an adverse effect
on the children in that they have witnessed arguments between the
parties and have witnessed the father tearing up notes left by the
mother regarding changes in the custody schedule prior to reading
them, and have seen overall the hostility between the parties as
evidenced in other incidents.
12, The father has expressed a desire to obtain a change in
custody such that the oldest child, Michelle Welsch, age 12,
(hereinafter the "Child"), would live with her father at some time,
13, On May 30, 1996, the father went to the mother's house to
pick up the child and her belongings to move them to his home, At
that time, the Child told her father that she did not want to move,
After a conversation between father and daughter, he convinced her
to move, stating that her mother did not want her to live with her
anymore, The Child became very upset and ultimately, did not leave
with her father,
14. The pressures of her father to move to his home have
caused the Child to become upset, confused and extremely stressed
about the entire situation, and as a result, has caused a strain on
her relationship with both parents,
15, Because of her confusion and stress, the Child has
recently sought counselling from her guidance counsellor at school,
She has also expressed to her mother that she needs time to clear
her head and think about what she wants to do regarding the move
and has expressed a desire to meet with the parties' private
mediator whom she refused to see in the past.
16. The custody schedule is such that the father will have
custody at 4:30 p,m, today, May 31, 1996,
17, The Child has stated that she does not want to see her
father at this time and hence does not want to go to his home for
his custody period this afternoon because she is very confused and
upset and needs time to think about the matter prior to deciding
with whom she wishes to reside,
18. The mother fears that forcing the child to go to her
father's when she does not want to will have an adverse effect on
her child's well-being and will further cause her stress,
19, Because of the present emotional state of the child it is
not in her best interest to put her in a stressful situation by
forcing her to go to her father's home for a custody period when
she has stated that she does not want to go and that going will
cause her more stress,
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20. The father has expressed to counsel for the mother that
he is presently not willing to negotiate the custody schedule and
shall to defer to the private mediator that the matter be scheduled
for conciliation,
21, The present situation between the parties is such that it
is in the best interest of the children that the issues regarding
custody be resolved immediately and accordingly,
that a
conciliation conference be scheduled as soon as possible,
WHEREFORE, the Petitioner Karen R, Welsch requests that this
court enter a Temporary Custody Order:
1, Ordering that an emergency custody conciliation be
scheduled as soon as possible; and
2, Modifying the present Custody Order such that the
father's physical custody of Michelle Welsch be restricted to those
times that Michelle Welsch wishes to see her father until such time
as a conciliation conference can be scheduled between the parties,
Respectfully submitted,
Date: S-..J/-q(,
inda A,
Attorney I,D, No,
3464 Trindle Road
Camp Hill, PA 17011
(717) 763-7613
JEFFREY K. WELSCH,
Plaintiff
VB.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - 2389
KAREN R. WELSCH,
Defendant
CIVIL ACTION - LAW
CUSTODY
VERIFICATION
I, KAREN R. WELSCH, verify that the statements made in the
foregoing PETITION FOR SPECIAL RELIEF are true and correct to the
best of my knowledge, information and belief. I understand that
false statements herein are made subject to the penalties of 18 Pa,
C,S, Section 4904,
relating to unsworn falsification to
authorities,
Dated: '1h:u;.3/,199h
1&.1 p nIP t/)-LIAJA'" ../
Ka'r n R, Welsch
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LAW OFfICES Of CRAIG A, DIEHL
3484l1l1NDlE ROAD 100 GLENVlEW ROAD
CAMP HIU. PA 17011 SPRING GROVE. PA 17382
17171783-7813 17171 225-1929
FAX 171717llU293
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-
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. q 4 - .;J3g9 C!.-tA."-~ J~
JEFFREY KENT WELSCH,
Plaintiff
KAREN RUTH WELSCH,
Defendant
CUSTODY
ORDER OF COURT
AND NOW, this (,\~ day of ~'l , 1994, upon
consideration of the attached Complaint, it is hereby directed
that the parties apd their respective counsel appear before
SC\."'~ I L. AY\ck~ , Esquire, the Conciliator, at
b. -<;)..,,- f\I. I rl1 h <:, \. L.-f'v-b 1/1 " ,
pennsy"1 vania, on the Cj' h day of 74n r ,
1994, at -:? () .M. 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. Ei ther party may bring the children who
are the subject of this custody action to the conference, but
the children I s attendance is not mandatory. Failure to appear
at the conference may provide grounds for the entry of a
temporary or permanent order.
FOR THE COURT:
DATED:
.4 ct/WLuJi /!, /f~ t:S'I.
Custody Conciliator ~~I
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.
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BY:
Office of the Court Administrator
Cumberland County Court House
One Court House Square
Carlisle, PA 17013
(717) 240-6200
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JEFFREY KENT WELSCH,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO.
CIVIL 1994
KAREN RUTH WELSCH,
Defendant
CUSTODY
COMPLAINT FOR SHARED LEGAL CUSTODY
AND NOW, this
day of
,
1994, comes the
Plaintiff, Jeffrey Kent Welsch, by his attorney, Arthur K. Dils,
Esquire, and respectfully requests the following:
1. The Plaintiff, Jeffrey Kent Welsch, is an adult individual,
who currently resides at 118 North Front Street, Wormleysburg,
Cumberland, County, Pennsylvania, 17025.
2. The Defendant, Karen Ruth Welsch, is an adult individual,
who currently resides at 7103 Salem Park Circle, Mechanicsburg,
Cumberland County, Pennsylvania, 17055.
3. The Plaintiff and Defendant were married on August 16,
1980, in Roselle Park, New Jersey.
4. As a result of said marriage, three children were born;
namely,
-1-
Michelle Louise Welsch, born November 21, 1983;
Charlene Elizabeth Welsch, born June 16, 1985; and
Andrea Christine Welsch, born October 14, 1988.
5. The parties hereto separated on or about January, of 1994;
at which time, the Defendant was cooperating in the partial
periods of custody in the Plaintiff; however, recently, the
Defendant has refused certain periods of partial custody with
the Plaintiff.
6. The Plaintiff believes it is in the best interest of his
children that he receive shared legal custody of his minor
children with partial periods of custody as follows:
(a) Every other weekend from Friday at 3:00 p.m. until
Sunday at 3:00 p.m.;
(b) At least two days during the week, every week after
school until 7:00 p.m.;
(c) Father's day with Father, Mother's day with Mother;
(d) The children's birthdays to be shared;
-2-
(e) Every Christmas Eve with Mother until Christmas day
at noon;
(f) Every Christmas day at noon until December 28th at
8:00 p.m. with Father;
(g) Alternate holidays, including New Year's Day,
Easter, Memorial Day, July 4, Labor Day, Thanksgiving, and Martin
Luther King Day, from the hours of 9:00 a.m. until 7:00 p.m.
(h) Should the father's holiday fall on after a weekend
visi tation, father shall retain the children overnight Sunday
and return them Monday at 7:00 p.m.
( i ) Four weeks in the summertime; however, no more than
two of the four weeks to be consecutive. Father to give Mother
thirty (30) days written notice of the desired four weeks;
(j) Reasonable telephone access with the minor children.
7. There has been no prior action filed for custody or
visitation of the minor child in this or any other jurisdiction.
-3-
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B. The Court of Common Pleas of Cumberland County has full
jurisdiction in this matter as all parties reside in Cumberland
County, Pennsylvania.
WHEREFORE, the Plaintiff, Jeffrey Kent Welsch, respectfully
requests your Honorable Court to grant him shared legal custody
of his minor children.
Respectfully submitted,
BY:
DILS & DIXON
~/U
Arthur K. Dils, Esquire
101 South Second Street
Executive House, Ste.L1
Harrisburg, PA 17101
(717) 232-9724
I.D. NO. 07056
-4-
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YBRIPICA'lIOH
I verify that the statements made in this Complaint for shared
custody
are true and correct.
I understand that false
statements herein are made subject to the penalties of 18 Pa.
C.S.A.~4904, relating to unsworn falsification to auth~rities.
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Dated: May 2, 1994
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JEF~'REY KENT WELSCH,
Plaintiff
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CUSTODY
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs,
NO, 94-2389 CIVIL TERM
,KAREN RUTH WELSCH,
Defendant
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ORDER
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AND NOW, this
~5t~ day of
, 1994, upon receipt of the
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:conciliator's report, it appearing that the parties have agreed to the terms and
: provisions of this order which was dictated in their presence and approved by them and
their counsel, we hereby order as follows:
1, The parties shall share legal custody of their minor children, Michelle Louise
'Welsch, born November 21, 1983, Charlene Elizabeth Welsch, born June 16, 1985, and
Andrea Christine Welsch, born October 14, 1988,
2. Primary physical of the said minor children shall remain with their mother,
"the Defendant, Karen Ruth Welsch,
3, The father of the children, the Plaintiff, Jeffrey Kent Welsch, shall have and
.enjoy the following periods of temporary or partial custody of all three children:
A, Alternating weekends from Friday at 4:30 p,m, until Sunday at 5:00
p,m" commencing on Friday, July 15, 1994,
B, Every Wednesday from 3:30 p,m, until 7:00 p,m, and every alternate
Monday, commencing on Monday, July 25, 1994, from 3:30 p,m, until 7:00 p,m,
C, Every Christmas holiday [or a period o[ three (3) days, commencing
at 5:00 p,m, on December 25th in even-numbered years and ending at 5:00 p,m,
on December 25th in odd-numbered years,
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D, The following holidays on an alternating basis, from 9:00 a.m, until
7:00 p,m,: Presidents Day, Memorial Day, July Fourth, Labor Day, and
Thanksgi ving Day, The father's holiday schedule shall commence with
Thanksgiving in 1994. Whenever the father's scheduled holiday falls adjacent
to one of his weekends of temporary custody, the weekend and holiday shall
expand into the other so the father will have the children for three
consecutive days,
E, During the summer of 1994 for a period of three (3) weeks, which
times have already been arranged by the parties, During the summer of 1995
I and thereafter, the father shall have the children for four (4) weeks of
temporary custody, not more than two (2) weeks of which will be consecutive,
The father will give the mother written notice of his four (4) weeks no later
than the first of May each year, In the event that the father must work or
otherwise is unavailable to have the children for more than two (2) hours
during any of his weeks of summer temporary custody, he will give the mother
the first opportunity to provide babysitting or child care for the children
at that time,
4, Whichever parent does not have custody of any of the children on that child's
birthday shall have a period of four (4) hours with the child if the birthday does not
fall on a school day and, if the birthday falls on a school day, shall have the child
for two (2) hours on the birthday,
5, In the event that either parent places any of the children in daycare on a
regular basis, for four (4) hours or more, with advance arrangements, during any of the
periods of their custody, they shall provide the other parent, in advance, with the
2
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:name, address, and telephone number of the person or agency providing that daycare for
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,the children or the child,
6, Each parent shall have reasonable telephone access to the children while they
,
,are in the custody of the other, Reasonable telephone access shall not mean more than
fifteen minutes total and shall not mean more than one telephone contact per day except
in extraordinary circumstances.
By the Court,
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, Arthur K, Oils, Esquire
Attorney for Plaintiff
,Carl G, Wass, Esquire
'Attorney for Defendant
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JEFFREY KENT WELSCH, ) IN THE COURT OF COHHON
Plaintiff ) PLEAS OF CUHBERLAND
) COUNTY, PENNSYLVANIA
vs, )
) NO. 94-2389 CIVIL TERH
i , KAREN RUTH WELSCH, )
! Defendant ) CUSTODY
JUDGE PREVIOUSLY ASSIGNED: None
CONCILIATOR CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUHBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the
undersigned Custody Conciliator submits the following report:
1, The pertinent information concerning the children who are the SUbject of this
litigation is as follows:
NAHE
BIRTHDATE
CURRENTLY IN
CUSTODY OF
Hichelle Louise Welsch
Charles Elizabeth Welsch
Andrea Christine Welsch
21 November 1983
16 June 1985
14 October 1988
Defendant/Hother
Defendant/Hother
Defendant/Hother
2, A Conciliation Conference was held on 12 July 1994 and the following
individuals were present: the Plaintiff and his attorney, Arthur K. Dils, Esquire; the
,Defendant and her attorney, Carl G, Wass, Esquire,
3, The parties appeared, after having previously exchanged proposals, With a
good bit of patient work by their attorneys, and some commendable adjustment by each of
the parties, we were able to reach agreement upon an order, The attached order was
dictated in their presence and approved by them and their attorneys and, with the entry
of this order, no further action is necessary,
13 July 1994
Q~,~~~
Samuel'L, Andes
Custody Conciliator
JEFFREY KENT WELSCIl, ) IN TilE COURT OF COMMON
PlaintiU ) PLEAS OF CUMBERLAND
) COUN1'Y, PENNSYLVANI A
vs, )
) NO. 94-2389 CIVIL TERM
KAREN RUTIl WELSCH, )
Defendant ) CUSTODY
ORDER
AND NOW, this
day of
, 1994, upon receipt of the
conciliator's report, it appearing that the parties have agreed to the terms and
provisions of this order which was dictated in their presence and approved by them and
their counsel, we hereby order as follows:
1, The parties shall share legal custody of their minor children, Michelle Louise
Welsch, born November 21, 1983, Charlene Elizabeth Welsch, born June 16, 1985, and
Andrea Christine Welsch. born October 14, 1988,
2. Primary physical of the said minor children shall remain with their mother,
the Defendant, Karen Ruth Welsch,
3, The father of the children, the Plaintiff, Jeffrey Kent Welsch, shall have and
enjoy the following periods of temporary or partial custody of all three children:
A, Alternating weekends from Friday at 4:30 p,m, until Sunday at 5:00
p,m" commencing on Friday, July 15, 1994,
B, Every Wednesday from 3:30 p.m. until 7:00 p,m, and every alternate
Monday, commencing on Monday, July 25, 1994, from 3:30 p,m, until 7:00 p,m.
C, Every Christmas holiday for a period of three (3) days, commencing
at 5:00 p,m, on December 25th in even-numbered years and ending at 5:00 p,m,
on December 25th in odd-numbered years,
1
D, The fOllowing holidays on an alternating basis, from 9:00 a,m, until
7:00 p,m,: Presidents Day, Memorial Day, July Fourth, Labor Day, and
Thanksgiving Day, The father's holiday schedule shall commence with
Thanksgiving in 1994, Whenever the father's scheduled holiday falls adjacent
to one of his weekends of temporary custody, the weekend and hOliday shall
expand into the other so the father will have the children for three
consecutive days,
E, During the summer of 1994 for a period of three (3) weeks, which
times have already been arranged by the parties, During the summer of 1995
and thereafter, the father shall have the children for four (4) weeks of
temporary custody, not more than two (2) weeks of which will be consecutive,
The father will give the mother written notice of his four (4) weeks no later
than the first of Hay each year, In the event that the father must work or
otherwise is unavailable to have the children for more than two (2) hours
during any of his weeks of summer temporary custody, he will give the mother
the first opportunity to provide babysitting or child care for the children
at that time,
4, Whichever parent does not have custody of any of the children on that child's
birthday shall have a period of four (4) hours with the child if the birthday does not
fall on a school day and, if the birthday (aIls on a school day, shall have the child
for two (2) hours on the birthday.
5, In the event that either parent places any of the children in daycare on a
regular basis, for four (4) hours or more, with advance arrangements, during any of the
periods of their custody, they shall provide the other parent, in advance, with the
2
name, address, and telephone number of the person or agency providing that daycare for
the children or the child,
6, Each parent shall have reasonable telephone access to the children while they
are in the custody of the other, Reasonable telephone access shall not mean more than
fifteen minutes total and shall not mean more than one telephone contact per day except
in extraordinary circumstances,
By the Court,
J,
Arthur K, Dils, Esquire
Attorney for Plaintiff
Carl G, Wass, Esquire
Attorney for Defendant
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JUL 14 1994,/
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Prothon. - 3
JEFFREY K. WELSCH
................................,.......................
Plaintiff
In the Court of COMMON PLEAS of
CUMBERLAND
IXiHlt'"lK County
......................................................to.
YI.
of ..................,........................,.... Term. 19
KAREN RUTH WELSCH,
.... .... ..... .... ..... .....'Dt:!f~*r"1tl~h.t:.... t........
94-2389-Civil Term
........................................
No
......................................................t.
CUSTODY
.......................................................
.......................................................
......................................................t.
To the Prothonotary:
.....................................................................................................................
........... ~ ~.';~ ~~. ..~.~.~ ~::. .r:X.. ~.l'.I?!;~ F:?IJ ~7... ~;? ~.. tl:.9.. H~ f.9nH~ Po t,.. ~~. r.<;n.. ~.,:.t;h.....
Welsch, in the above matter.
.....................................................................................................................
.....................................................................................................................
.....................................................................................................................
.....................................................................................................................
To
CALDWELL
& KEARNS
S~IlXft~
Prothonotary
, 19 .~~.....It.Y.:.......2. .
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A/lorr\ey for mK/D(1(:t Def.
Carl G. Wass, Esquire
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~AY 2 7 1997
CTetf"'re 1 k. l.ue(sc:~ plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9~. c;m'1 CIVIL TERM
CUSTODY
v,
Aarlh R. we(r/-" Defendant
ORDER OF COURT
AND NOW, upon consideration of the attached complaint, it is
hereby directed that the parties and their respective counsel
appear before H,( hOC" \ L, [-',(I(-'C(, c,cIl-,-' the conciliator,
,'Sue) ~, I 'i:)\hSt , (Ul}1JJ..lJ! on the ~ day of --:...\ )\'1
1999', at \ \'.OJ Cl.m., for a Pre-Hearing Custody Conference. At
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.
By the court,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
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.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
30
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Jeffrey K, Welsch, Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
Karen R, Welsch, Defendant
NO, 9'1- ';;':U-7
CUSTODY
CIVIL TERM
PETITION TO MODIFY VISITATION AND CUSTODY
1, The Plaintiff is Jeffrev K, Welsch, residing at 521 57th St.,
Altoona, PA 16602,
2, The Defendant is Karen R, Welsch, residing at 7103 Salem Park
Circle, Mechanicsburq, PA 17055,
3, Plaintiff seeks modification of visitation of the following
children:
NAME
Charlene E, Welsch
Andrea C, Welsch
PRESENT ADDRESS
7103 Salem Park Circle, Mechanicsburg, PA
7103 Salem Park Circle, Mechanicsburg, PA
AGE
11
8
The children were not born out of wedlock, and they are presently
in the custody of Karen R, Welsch, who resides at 7103 Salem Park Circle.
Mechanicsburq, PA 17055,
INCLUDED IN THIS MODIFICATION, Plaintiff seeks to designate which
parent will provide transportation for the children between Altoona and
Mechanicsburg,
ALSO, Plaintiff requests that Michelle L, Welsch. aqe 13, who has
been residing with Plaintiff since January, 1997, be established in the
court as changing her address to 521 57th St" Altoona. PA 16602, Since
Plaintiff and his wife, Jan, are primarily responsible for the care,
nurture, and financial support of Michelle, Plaintiff requests that the
court recognize and establish this change in custody and address.
Michelle was not born out of wedlock, and is presently in the
custody of Jeff and Jan Welsch, who resides at 521 57th St" Altoona, PA
16602,
Since the separation and divorce between the Plaintiff and Defendant
in January, 1994, the children have lived with their mother, Karen R.
Welsch, at 7103 Salem Park Circle, Mechanicsburg, PA. There was
approximately a two month period in which they lived in an apartment in
Colonial Park (Harrisburg), Michelle, now lives with Jeff and Jan Welsch
at 521 57th St" Altoona, Pa" 16602.
Prior to January, 1994, all three children lived with Jeff and Karen
Welsch (Plaintiff and Defendant) at 5513 Silvercreek Dr., Mechanicsburg,
The mother of the children is Karen R, Welsch, currently residing
at 7103 Salem Park Circle. Mechanicsburq, Pa, , 17055. The mother is
divorced,
1
NAME
Janic~ Welsch
Michelle L, Welsch
RELATIONSHIP
Wife
Daughter
The father of the children is Jeffrey K, Welsch, currently residing
at 521 57th St.. Altoona, PA.. 16602, The father is divorced and re-
married,
4, The relationship of the Plaintiff to the children is father,
The Plaintiff currently resides with:
5, The relationship of the Defendant to the children is mother, The
Defendant currently resides with:
NAME
Charlene E, Welsch
Andrea C, Welsch
RELATIONSHIP
Daughter
Daughter
6, Plaintiff has participated as a party in other litigation
concerning the custody of hi~ minor children in this court - Court of
Common Pleas of Cumberland County, PA" docket #94-2389.
7, Charlene and Andrea have a wonderful time when they visit in
Altoona as they participate in numerous church functions, seeing friends,
spending time with their grandparents, aunt, and cousins, and benefitting
from a stable home life with Plaintiff, his wife, Jan, and Michelle, The
best interest and permanent welfare of the children will be served by
granting relief in the following matters requiring modification of
visitation:
A) transportation - Defendant originally agreed with the Mediator to
assume partial driving necessary for visitation between Altoona and
Mechanicsburg, and then at the end of the mediation process withdrew her
agreement (mediation document - page 4, item #6), Plaintiff requests
that the court order the Defendant to assume one-half (50%) of driving,
Plaintiff and Defendant have joint custody of the children, and therefore
both parties should assume responsibility for the travel of children to
be with both parents, Each round-trip between Altoona and Mechanicsburg
is 250 miles, with $13,60 in tolls, With Michelle now living with
Plaintiff and Jan, this amounts to 6 round trips per month for the
Plaintiff, Plaintiff proposes the following schedule, assuming the first
weekend visit would be for Charlene and Andrea to come to Altoona; the
2nd weekend would be for Michelle to go to Mechanicsburg; and the 3rd
weekend of the month would be Charlene and Andrea coming to Altoona
again:
1) Father comes to Mechanicsburg, picks up children at school
dismissal, and comes back to Mechanicsburg, Mother leaves whatever
weekend clothing (typically 1-2 small bags) is necessary for the children
on the porch for father to pick up before he picks up the 2 children,
This will save considerable travel time for father,
Mother must come to pick up children on Sunday at Rax restaurant.
south of Altoona at 3:00, It is necessary for the transfer of children
away from Plaintiff's residence due to a standing police order against
Defendant prohibitinq her anv contact with 58th St. United Methodist
Church property and persons associated with the church (copy enclosed) ,
All exchange of children must take place outside the Al toona area,
Father is willing to save mother approximately 10 miles of driving to
2
meet her outside of Altoona, Lemoyne police have on file a complaint
against Defendant concerning property damage she inflicted on the
parsonage at Plaintiff's last residence, Plaintiff's present church,
58th Street United Methodist, will not tolerate the possibility of
Defendant again causing property damage and contacting church members,
This policy is in effect at the urging of both Becky Emerick, mediator,
and the Rev, Dr, Thomas Irwin, Plaintiff's District Superintendent, The
transfer of children must take place outside Altoona, If mother is later
than 3:30, father has privilege of leaving, and mother must then call
father to arrange new pick-~p time,
2) on the weekend for Michelle to visit in Mechanicsburg, Defendant
(mother) will come to Rax Restaurant on Friday to meet with father and
Michelle at a time of Defendant's choosing, The time designated at the
Conciliator's Conference will be the permanent time, and can only be
adjusted by request of either parties in writinq, No phone conversations
will be permitted to change this schedule, Plaintiff (father) will pick
up Michelle at 3:00 - this is necessary so that Michelle can be back home
to participate in weekly church activities,
3) on the 2nd weekend that Plaintiff has visitation with Charlene
and Andrea, the same schedule as #1 above will be followed (father
picking them up at school, and mother meeting at Rax on Sunday at 3:00
for transfer) ,
B) establish a permanent schedule for Plaintiff's four (4) weeks of
court-ordered summer visitation with Charlene and Andrea, This is
necessary due to the fact that Defendant has refused to supply Plaintiff
with an agreement of proposed dates for this visitation in a reasonable
time, Defendant agreed to fix vacation times no later than May 1 in a
signed document granting Michelle to reside in Altoona with Plaintiff,
Plaintiff supplied Defendant with proposed dates in January, and as of
May 21, 1997, Defendant has not agreed to any dates, Plaintiff's request
is that the court establish a permanent schedule so that Plaintiff will
not have to wait to set vacation time with his employer, and so that
plans for vacation can be accomplished, and that these weeks may have
planned events, As it is now, Plaintiff cannot schedule trips, visits,
etc. because there is not provided enough time to make adequate plans,
Plaintiff proposes that we establish these 4 weeks of summer
vacation with father for Charlene and Andrea on a permanent basis:
I) one week beginning the 2nd Sundav of June, in the afternoon after
Annual Conference - 3:00, However, in 1997 only, this week would begin
June 15, This week also corresponds wi th our church's Vacation Bible
School, of which the children thoroughly enjoy, As established in
transportation issue above, father will pick up children, and mother will
meet at Rax restaurant at 3:00,
II) two weeks beginning on the 2nd Sundav of Julv, with father
qettinq the 2 children at 3:00, Mother will meet at Rax at 3:00 two
weeks later,
I II) one week beginning the 2nd Sunday of Auqust. with father
qettinq the 2 children at 3:00, Mother will meet at Rax at 3:00 on the
following Saturday at 3:00,
These vacation weeks not only take into account Plaintiff's need to
schedule vacation time during winter/spring, but also includes special
activities in the church which the children really enjoy, such as summer
camping,
3
C) throughout the school year, Plaintiff requests to maintain the same
schedule as established in our signed mediation agreement through Becky
Emerick (copy enclosed), Basically, this involves a schedule of every-
other weekend, and several long weekends when the 2 children are out of
school, In fact, Plaintiff requests that the entire mediation document
be admitted as part of this revised court order.
D) plaintiff requests that Michelle L, Welsch be designated to be under
the care and nurture of Jeff (Plaintiff) and Jan Welsch. In these four
months that Michelle has been living in Altoona, she has adjusted very
quickly, become involved in numerous school activities, made many new
friends, and enjoys an active church life, She is doing well at school
and we expect her to be on the honor roll this term, Her Guidance
Counselor, and friends and family all unanimously agree that she has
truly blossomed since moving to Altoona, Michelle has a very loving and
beneficial relationship with her step-mother, Jan, Michelle has a
wonderful relationship with her father (Plaintiff), and is assured that
there would never come a time in which father would treat her cruelly or
with selfish motives - she has complete confidence that father will
always love her and do what is best for her, both physically and
emotionally, Michelle is happy, healthy, and extremely pleased to be in
her Altoona environment, Completely absent at Plaintiff's home in
Altoona are the negative elements Michelle found necessary to leave while
residing with the Defendant, It is fitting and proper that the court
recognize and re-designate Michelle'S change of residence,
B, Parental rights to the children have not been terminated for
either parent and the person who has physical custody of the child have
been named as parties to these actions, The only persons claiming
parental rights are the Plaintiff (father), his wife, Jan (step-mother),
and Defendant (mother), No other person claims parental rights to the
three children.
WHEREFORE, Plaintiff requests this court to grant this modification
of visitation for Charlene and Andrea, and change of residence for
Michelle,
ReEpectfully Submitted,
J.t~ k ~-ek/-'
, 'Plaintiff
4
58th St. & Roselawn Ave.
Altoona, Pa 16602
Jeffrey K, Welsch. pa3tor
office~ 942-.5.586
July 16, 1996
Ms, Welsch,
This letter serves to inform you that you are hereby prohibited from any contact
with 58th St. United Methodist Church in Altoona, Pennsylvania, Contact is defined as
any personal communication with the church and our members either in person or by
phone, You are also prohibited from any physical contact with our church property,
This policy is effective as of the date above, and your failure to comply with this policy
will result in our turning the matter over immediately to the local police,
Sincerely,
{?~ LUJt
Philip Wilt, Trustee President
cc: Altoona Police Chief
cc: Rev, Thomas Irwin
cc: Unda Clotfelter, esquire
cc: Arthur Oils, esquire
June 8, 1996
ANOTHER PRRSPECTNE
ASS 0 erA T E 5
Jeff Welsch
118 N, Front Street
Wormleysburg, PA 17043
Karen Welsch
7103 Salem Park Circle
Mechanicsburg, PA 17055
Dear Jeff and Karen:
You have completed mediation to your satisfaction and both
have stated that you agree to have the following admitted to the
court as a consent order as part of your original divorce and
custody filing, The parties agree that Karen's attorney Linda
Clotfelter will prepare a consent for their signatures. Jeff
Welsch at this time is satisfied with mediation and wishes to
decline his right to separate counsel, Mr, Welsch may at anytime
retain counsel if he wishes,
The following issues were settled in mediation:
1, Children's individual trust funds: All trust funds will be
transferred from the name of father and child to mother and
child. Mother agrees to keep the funds invested with the
Methodist Conference Building Fund and to reinvest the
interest received in $100 increment to the individual child's
account, All sums that exceed $100 increments for a specific
child will be applied to Andrea's account in $100 increments,
or to the children's direct care if it is less than $100,
2, Life insurance: Both parties agree to restate the life
insurance section of their divorce decree as follows: Father
will secure and pay for a $100,000 first to die policy on
himself and mother, with the beneficiary being the opposite
parent, This policy will remain in force until the last child
graduates from college or is age 24, whichever is first,
Father will show proof of this policy, CUrrently, this policy
is with Midland National Life Insurance Company,
Suitt' ~07 . 35-10 "l. I'ro~r"ss """nu" . HMrisbur~, 1''' 17110
Phon,,: (ili) 540.15711 . F.IX: (717) h71-li03
2
Jeff and Karen Welsch
June 8, 1996
3. S'nnm~~ visitation: Summer visitation will be as follows, Each
parent will have the children for two exclusive 14 night
periods, During the summer there will be no weekend or
weekday exchanges as during the school year, The children
will continue to be with Father on Father's Day and Mother on
Mother's Day,
For the summer of 1996, recognizing Father's move to Altoona,
the parties have agreed to the following.
- por June 1996, Father will have the children from:
1.) 8:00 p,m. Sunday, June 9, 1996 until Tuesday
at 4:00 p,m, Tuesday, June 11, 1996,
2,) 6:00 p.m, Saturday, June 15, 1996 until 2:00
p,m, June 19, 1996,
3,) 8:00 p,m, Sunday, June 23,1996 until 7:00
p,m. Monday, June 24, 1996,
Mother will bring the children to Father in June and
Father will return the children to Father after his
visit,
Por July and August 1996, Father will have the
children: 1,) Noon Friday, July 12 until noon on
Friday, July 26, 1996.
2, ) Noon Friday, August 9, 1996 until noon on
Friday, August 23, 1996,
Father will provide all transportation in July and
August,
3
Jeff and Karen Welsch
June 8, 1996
4,) School year visitation: Acknowledging Father's move to
Altoona both parties have agreed to modify the school
year schedule so that Father and Mother may each benefit
from the days the children are not in school, Both
parties acknowledge that this will mean that they will
sometimes receive two weekends in a row, or a period of
three weeks between visits, This 1996-1997 school year
visitation will be as follows,
Father will have the children on the following days,
Father will pick up the children at school or at home
immediately after school and return the children between
4:30 and 5:30 p,m, on his day to return them.
-Friday to Sunday, September 6-8, 1996
-Friday to Sunday, September 20-22, 1996
-Friday to Sunday, October 4-6, 1996
-Friday to Tuesday, October 11-15, 1996
-Friday to Sunday, November 1-3, 1996
-Thursday to Sunday, November 14-17, 1996 (children
have ~ day of class on Thursday)
-Wednesday to Monday, November 27-December 2, 1996.
(Thanksgiving Weekend)
-Friday to Sunday, December 13-15, 1996
-Thursday to Tuesday, December 26-December 31, 1996
-Friday to Sunday, January 10-12, 1996
-Friday to Sunday, January 24-26, 1996
-Friday to Sunday, February 7-9, 1996
-Friday to Sunday, February 21-23, 1996
-Thursday to Sunday, March 6-9, 1996, (Elementary
off Thursday at noon and Friday.)
4
Jeff and Karen Welsch
June 8, 1996
-Friday to Tuesday, March 21-25, 1996. (Elementary
off ~ day on Monday and all day Tuesday.)
-Friday to Sunday, April 4-6, 1996
-Friday to Sunday, April 18-20, 1996
-Friday to Sunday, May 2-4, 1996. (School out at
noon,)
-Friday to Monday, May 23-26, 1996, Memorial Day,
-Friday to Sunday, May 30-June 1, 1996,
-Friday to Monday, June 13-16, 1996, Father's day,
(Return noon to 3:00 p,m" Charlene's Birthday,)
The above schedule maintains the exchange of holidays as
stated in the Divorce agreement. The above schedule gives
Father between six and seven extra days when school is closed,
and Mother between three and seven days, if makeup days are
not needed. It is recognized that bad weather may prevent the
exchange of the children, and both parties agree that there
will be no makeup days if the exchange fails to take place on
the date scheduled,
5,) Other school year visitation: Father may obtain the
children after school on the Wednesday or Thursday of the
week he would not have them on the following weekend, and
return them the same day by 7:00 p,m, Father must give
mother two days notice of his intent to see the children
in this manner.
6,) Transportation: Father requested that mother meet and
pick up the children every other time Father has the
children for a weekend during the school year, Father
proposed this take place by Mother meeting Father in
, ,
5
Jeff and Karen Welsch
June 8, 1996
Bedford and exchanging the children in mid-afternoon,
Mother originally agreed to pick up the children once
every other time Father had them and Father would provide
all other transportation, At this time, Mother prefers
that Father provide all transportation and has declined
to participate in transportation of the children,
7, ) Christmas: Both parties agree to change the current
Christmas schedule as follows, The parents will
alternate having the children on Christmas with one
parent (Karen in 1996) having the children from December
23 - until noon on December 26 each year; the other
parent would have the children from noon December 26 for
three days until 5:00 p,m, December 29 each year, The
parties agree that whoever has the children over
Christmas will be responsible for bringing the Children
to the other parent on the 26th each year,
8.) Michelle: Michelle is the 12-year-old daughter of the
parties, Both parties acknowledge that Michelle is
comfortable with her Father and is somewhat like him in
personality. Both parties agree that they will be open
to allowing Michelle to live with her Father after
Michelle spends another year with Mother, possibly
beginning September 1997, if that is her desire. Both
parties further agree that should this happen they will
have all the children together during each visit in the
summer and as much as possible during the school year for
continuing sibling development.
9, )
Other:
following
following:
The mediator has privately discussed the
with each party and they agree to the
6
Jeff and Karen Welsch
June 8, 1996
A.) Each parent will cease telling the children
how to live in the other parent's household,
Each parent will be responsible for all
parenting while in their own home,
B,) Each parent, for the psychological health of
their children, will cease criticizing and
talking disparagingly about the other parent
in front of the children, The children love
both parents, and will always be with both
parents, The continuation of derogatory
remarks serves only to alienate the children
from the parent making them, Additionally it
is painful for them to hear, Both parents
will treat the children as their children and
not as personal confidants,
C. ) Each parent will allow the children to call
and talk with the other parent without
interruption, The children should not be
utilized to focus the parent's anger through,
D, ) Each parent will provide a telephone number
for emergencies that the other parent may
utilize to call, Father will provide Mother
with an address and telephone number of where
the children will reside during normal
visitation,
7
Jeff and Karen Welsch
June 8, 1996
E,) Each parent should consider that except during
the two week exclusive summer periods and
special holidays and birthdays, there is no
need for the parent who is not with the
children to constantly call each day. This is
disruptive and not required at the ages of
your children,
Sincerely,
p,r~
Rebecca L, Emerick
M,S" M,B.A., CPA
cc: Linda Clotfelter, Esquire
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JEFFREY KENT WELSCH,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
NO. 94-2389 CIVIL TERM
KAREN RUTH WELSCH,
Defendant
CIVIL ACTION - LAW
CUSTODY/VISITATION
ORDER
AND NOW, this
,-tL
,
day of
~ u 0 -' ~i
, 1997,
upon receipt of the Conciliator's Report, it appearing that the
parties have reached a temporary agreement as to the summer
months, and that the agreement was dictated in their presence and
approved by them, it is hereby ordered and directed as follows:
1, The parties shall share legal custody of their minor
children, Charlene E, Welsch, d,o,b, June 16, 1985, Andrea C.
Welsch, d,o.b, October 14, 1988, and Michelle L, Welsch, d,o,b,
November 21, 1983.
2, The parties acknowledge that currently Michelle is
living primarily with Father and Charlene and Andrea are living
primarily with Mother, The parties have agreed to a summer
schedule in accordance with the following:
A, Father shall have custody of Andrea and Charlene
from July 19th through July 25th, Father shall pick up
Andrea and Charlene at 2:00 p,m, at Mother's residence on
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July 19th, Father will drop off Andrea and Charlene on July
25th at Mother's residence at 2:00 p,m.
B. Mother shall have Michelle from July 12th through
August 3rd. Mother shall pick up Michelle at Father's
residence, However, it is specifically understood that
Mother shall park across the street and shall not be
permitted on church ground, It is the intention of this
Order that the child shall walk to the Mother's car and that
the Mother should only be out of the car for purposes of
helping the child get her luggage in the car and to get
ready for the trip back.
C, Father shall have all the children from August 3rd
through August 17th, Father will be picking up the children
at Mother's residence between 2:00 and 3:00 p,m, on August
3rd, Mother shall pick up Andrea and Charlene on August
17th between 2:00 and 3:00 p,m, at Father's residence,
Again, it is understood that Mother shall park across the
street and shall not be permitted on church ground. It is
the intention of this Order that the child shall walk to the
Mother's car and that the Mother should only be out of the
car for purposes of helping the child get her luggage in the
car and to get ready for the trip back,
3. The parties recognize that there is an estrangement
that is currently occurring between Michelle and her Mother. The
Mother will involve Michelle with appropriate counseling to get
to the bottom of this estrangement. Mother will pick an
appropriate psychologist to assist her in this regard and will
provide Father with the name, address and phone number of that
person as soon as that person is chosen, Mother should provide
that information to Father at least a week in advance of when she
has her first scheduled appointment with that psychologist. Both
parties will evenly share in the expense related to the
psychologist appointments with Michelle, The psychologist should
provide a brief report to the conciliator by the time of the next
conciliation as to what is occurring with Michelle that has
caused this estrangement,
4. The parties will reconvene for another conciliation in
the offices of Michael L, Bangs, Esquire, 302 South 18th Street,
Camp Hill, Pennsylvania, 17011, on the 21st of August, 1997, at
10:00 a.m.
BY THE COURT,
Mr, Jeffrey K, Welsch
Pro Se
~41 .~..{ '?:/!ijr?,
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Jeffrey C, Goss, Esquire
Attorney for Defendant
JEFFREY KENT WELSCH, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
NO. 94-2389 CIVIL TERM
KAREN RUTH WELSCH,
Defendant CIVIL ACTION - LAW
CUSTODY/VISITATION
JUDGE PREVIOUSLY ASSIGNED: The Honorable J. Wesley Oler, Jr.
CUSTODY CONCILIATION CONFERENCE 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 concerning the children who
are the subject of this litigation is as follows:
lW1E
BIRTHDATE
CURRENTLY IN
CUSTODY OF
Charlene E, Welsch
Andrea c. Welsch
Michelle L, Welsch
June 16, 1985
October 14, 1988
November 21, 1983
Defendant
Defendant
Plaintiff
2, A Conciliation Conference was held on July 3, 1997, and
the following individuals were present: the Plaintiff, Jeffrey
K. Welsch, Pro Se; the Defendant appeared with her attorney,
Jeffrey c. Goss, Esquire,
3, Items resolved by agreement: See attached Order.
4, Issues yet to be resolved: See attached Order.
5. The Plaintiff's position on custody is as follows: See
attached Order,
~.
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6, The Defendant's position on custody is as follows: See
attached Order,
7. Need for separate counsel to represent children:
Neither party requested,
8, Need for independent psychological evaluation or
counseling: See attached Order,
9. The parties will reconvene for another conciliation in
the offices of Michael L, Bangs, Esquire, 302 South 18th Street,
Camp Hill, Pennsylvania, 17011, on the 21st of August, 1997, at
10:00 a,m.
Date: July 30, 1997
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
JEFFREY KENT WELSCH,
Plaintiff
NO, 94.2389 CIVIL TERM
KAREN RUTH WELSCH,
Defendant
CIVIL ACTION - LAW
CUSTODY /VISIT A TION
ORDER
AND NOW, this '?rJ II day of J.: c.")',) '-~1
, 1 997, upon receipt
of the Conciliator's Report, it appearing that the parties have agreed to the terms
and provisions of this Order which was dictated in their presence and approved by
them, it is hereby ordered and directed as follows:
1, All prior Orders entered in this case are vacated,
2, The parties shall snare legal custody of their minor children,
Charlene E, Welsch, d,o,b, June 16, 1985, Andrea C, Welsch, d,o,b,
October 14, 1988, and Michelle L Welsch, d,o,b, November 21, 1983.
3, Mother shall have primary physical custody of Andrea and
Charlene, and Father shall have primary physical custody of Michelle;
however, both are subject to a custody schedule in accordance with
the following:
A, Week One: Mother will have Michelle from Friday
until Sunday and Father will have Charlene and Andrea from
Friday until Sunday, The parties will agree to exchange the
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children at 5:30 p,m, on Friday at either the Sideling Exit of
the Turnpike if the Sideling Exit has access from both East and
West, if not at the Ramada Inn off the Breesewood Exit, They
shall return the children at 1 :45 p,m on Sunday,
B, Week Two: Father shall transport Michelle to
Mother's residence by 6:00 p,m, on Friday evening, and
Mother shall then transport Michelle to the drop off point as
indicated above on Sunday at 1 :45 p.m,
C, Week Three: Mother shall drop otf Charlene and
Andrea at 6:00 p,m. on Friday outside of Father's residence,
The parties shall then meet so that Father can drop off
Charlene and Andrea on Sunday at 1 :45 p,m, at the drop off
point as indicated above,
D, We..ek Four: No exchange of visitation,
4, The parties shall alternate custody of the children on the
following holidays: Labor Day, Thanksgiving Day, President's Day,
Memorial Day, and Fourth of July, This holiday schedule shall include
the entire weekend and take precedence over the other schedule, This
alternating holiday schedule shall commence with Father having Labor
Day in 1997, The parties will agree to exchange the children at 5:00
p,m, on Friday at either the Sideling Exit of the Turnpike if the Sideling
Exit has access from both East and West, if not at the Ramada Inn off
the Breesewood Exit, They shall return the children at 5:00 p,m, on
the day of the holiday,
5, Mother shall have the children for Mother's Day, and Father
shall have the children for Father's Day, This period of partial custody
(
and visitation shall take precedence over any other schedule.
6, The Christmas holiday shall be in two segments. Segment A
shall be from December 23rd at 5:00 p,m, until December 26th at
12:00 noon. Segment B shall be from December 26th at 12:00 noon
until December 29th at 12:00 noon, Father shall have Segment A in
1 997 and all odd-numbered years thereafter and Segment B in 1 998
and all even-numbered years thereafter, Mother shall have Segment A
in 1 998 and all even-numbered years thereafter and Segment B in
1997 and all odd-numbered years thereafter.
7, The parties shall share the summer vacation such that Father
shall have three full weeks of custody with the children all together,
and Mother shall have three full weeks of custody with the children all
together. Father shall also be entitled to one uninterrupted week of
vacation with Andrea and Charlene alone, and Mother shall be entitled
to one uninterrupted week of vacation with Michelle alone, Mother
shall provide Father with the weeks in which she intends to exercise
4
~J
her periods of visitation under this schedule no later than April 15th of
each year, and Father shall notify Mother of his schedule no later than
April 22nd of each year, For the remainder of the summer schedule,
there shall be no shifting of the custody between the parties, The
transportation for these periods of summer visitation shall be such that
the parent ending his or her period of custody with the children shall
drop the children off at the other party's residence.
8, Each parent and the children shall have reasonable telephone
access with each other while the children are in the custody of the
other parent. Reasonable telephone access shall not mean more than
fifteen (15) minutes total and shall not mean more than one telephone
contact per day, except in an extraordinary circumstances.
9, Father shall provide Mother with his cellular phone number
to be used only in cases of emergency as it relates to this custodial
schedule,
BY THE COURT,
Ji
(
Mr, Jeffrey K, Welsch, pro se (\~""..",.;w.:.,(, S}:l.9/91,
Jeffrey C, Goss, Esquire - --U .. ..J, 'r'>,
mlb .
JEFFREY KENT WELSCH,
Plaintiff
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
NO, 94-2389 CIVIL TERM
KAREN RUTH WELSCH,
Defendant
CIVIL ACTION - LAW
CUSTODY /VISIT A nON
JUDGE PREVIOUSLY ASSIGNED: The Honorable J, Wesley Oler, Jr,
CUSTODY CONCILIATION CONFERENCE 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 concerning the child(ren) who is(are) the
subject of this litigation is as follows:
NAME
BIRTHDATE
CURRENTLY IN
CUSTODY OF
Charlene E, Welsch
Andrea C, Welsch
Michelle L. Welsch
June 16, 1985
October 14, 1 988
November 21, 1 983
Defendant
Defendant
Plaintiff
2, A Conciliation Conference was held on August 21, 1997, and the
following individuals were present: the Plaintiff appeared pro se; the Defendant
appeared with her attorney, Jeffrey C, Goss, Esquire,
3, Items resolved by agreement: See attached Order,
4, Issues yet to be resolved: See attached Order,
5, The Plaintiff's position on custody is as follows: See attached Order,
6, The Defendant's position on custody is as follows: See attached Order,
7. Need for separate counsel to represent childlren): Neither party
requested,
8, Need for independent psychological evaluation or counseling: None
requested and the Conciliator does not believe any is necessary,
Date: August 25, 1997
Mich el L. Bangs
Custody Conciliator
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~UG 2 7 1997
.
JEFFREY K. WELSCH, . IN THE CXXJRT OF CXJMMCXIl PLEAS OF
.
plaintiff/Respondent . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 94-2389 CIVIL TERM
.
.
.
KAREN R. WELSCH, . CIVIL ACTION - LAW
.
Defendant/Petitioner . IN CUSTODY
.
0ti
upon consideratioon of the attached
ordered and directed as follows:
AND Na'i, this
day of
Custody
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aIDER OF <DIRT
1. The prior order of this Court dated August 27, 1997 is vacated and
replaced with this order.
2. The Father, Jeffrey K. Welsch, and the Mother, Karen R. Welsch,
shall have shared legal custody of Michelle L. Welsch, born November 21,
1983, Charlene E. Welsch, born June 16, 1985 and Andrea C. Welsch, born
October 14, 1988. 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.
3. The Mother shall continue to have primary physical custody of
Andrea and Charlene, and the Father shall continue to have primary physical
custody of Michelle.
4. During the school year, the parties shall have partial physical
custody of the Children in accordance with the following four-week cycle:
A. WEEK I: The Mother shall have custody of Michelle from Friday
at 5:30 p.m. through Sunday at 3:00 p.m. and the Father shall
have custody of Charlene and Andrea from Friday at 5:30 p.m.
through Sunday at 3:00 p.m. Exchanges of custody under this
provision shall take place at Exit 13 (Ft. Littleton) of the
PA Turnpike.
B. WEEK II: The Mother shall have custody of all three Children
frc:m Friday at 6:30 p.m. through Sunday at 3:00 p.m. For
purposes of this provision, the Father shall transport
Michelle to the Mother I s residence on Friday and the Mother
shall transport Michelle to Exit 13 (Ft. Littleton) of the PA
Turnpike on SUnday.
C. WEEK III: 'l11e Father shall have custody of all three Olildren
fran Friday at 6:30 p.m. through Sunday at 3:00 p.m. For
purposes of this provision, the Mother shall transport
Charlene and Andrea to the Father's residence on Friday and
the Father shall transport Olarlene and Andrea to Exit 13 (Ft.
Littleton) of the PA Turnpike on Sunday.
D. WEEK IV: No exchange of custody.
E. The parties shall strictly abide by the custody exchange times
set forth in this Order and aCknowledge the necessity of a
timely exchange particularly on Sundays at 3:00 p.m., due to
the Father's work schedule.
5. The parties shall share or alternate having custody of the
Children on holidays as follows:
A. CIIRIS'DtAS: The Christmas holiday shall be divided into
Segment A, which shall run fran December 23 at 5:00 p.m.
through December 26 at 12:00 noon, and Segment B, which shall
run fran December 26 at 12:00 noon through December 29 at
12:00 noon. The Father shall have custody of the Children
during Segment A in odd nwrbered years and during Segment B in
even numbered years. The Mother shall have custody of the
Children during Segment A in even numbered years and during
Segment B in odd numbered years. The party relinquishing
custody of the Children under this provision shall be
responsible to provide transportation to the other party's
residence, with the exception of the exchange on Decenber 29,
which shall occur at Exit 13 (Ft. Littleton) of the PA
Turnpike.
B. THANKSGIVING: The Father shall have custody of the Olildren
over Thanksgiving in even numbered years and the Mother shall
have custody of the Children over 'lhanksgiving in odd nwrbered
years. In even numbered years, the Mother shall transport
Charlene and Andrea to the Father's residence on the Wednesday
before Thanksgiving at 6:30 p.m. and the return exchange of
custody shall take place at Exit 13 (Ft. Littleton) of the PA
Turnpike on the Monday after Thanksgiving at 3:00 p.m. In odd
nwrbered years, the Father shall transport Michelle to the
Mother's residence on the \~ednesday before Thanksgiving at
4:30 p.m. and the return exchange of custody shall take place
at Exit 13 (Ft. Littleton) of the PA Turnpike on the Monday
after 'l11anksgiving at 3:00 p.m.
C. EASTER: The Easter holiday shall run fran Good Friday at 9:00
a.m. through Easter Sunday at 5:30 p.m. 'l11e Father shall have
custody of the Children over Easter in even numbered years and
the Mother shall have custody over the Easter holiday in odd
numbered years. Custody exchanges for the Easter holiday
,I
shall take place at Ft. Littleton.
D. MlKRIAL DAY/JULY 4th/LAIlOO MY: The parties shall alternate
having custody of the Children on Memorial Day, July 4th and
Labor Day. The Memorial Day and Labor Day holidays shall run
from Friday at 5:30 p.m. through Monday at 5:30 p.m. and the
July 4th holiday shall fall within the extended weeks of
custody under the sunmer schedule. In even numbered years,
the Mother shall have custody of the Olildren on Memorial Day
and Labor Day and the Father shall have custody on July 4th.
In odd numbered years, the Father shall have custody of the
Children on Memorial Day and Labor Day and the Mother shall
have custody on July 4th. Exchanges of custody under this
provision shall take place at Ft. Littleton.
E. MCIl'IIER'S DAY/FATHER'S MY: The Mother shall have custody of
the Children every year on Mother's Day weekend from Friday at
5:30 p.m. through sunday at 6:30 p.m. and the Father shall
have custody of the Children every year on Father's Day
weekend from Friday at 5:30 p.m. through Sunday at 6:30 p.m.
Exchanges of custody under this provision shall take place at
Ft. Littleton.
F. 'ltle holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
6. During the sumner school break each year, each party shall be
entitled to have 3 full weeks of custody with all three Children together.
In addition, the Father shall be entitled to have a 1 week period of
uninterrupted custody with Andrea and Charlene alone and the Mother shall
be entitled to have a 1 week period of uninterrupted custody with Michelle
alone. In even numbered years, the Mother shall provide the Father with
the dates on which she intends to exercise her periods of custody under
this provision no later than March 15 and the Father shall notify the
Mother of his schedule no later than March 22. In odd numbered years, the
Father shall provide the Mother with the dates on which he intends to
exercise his periods of custody under this provision no later than March 15
and the Mother shall notify the Father of her schedule no later than March
22. 'ltle Father shall provide to the Mother the sumner camp schedule for
the Children by February 1 each year. The sumner schedule set forth in
this provision shall supercede the school year schedule (4 week cycle),
which shall be suspended during the sumner. For exchanges of custody under
this provision, the party relinquishing custody shall provide
transportation to the other party's residence.
7. The non-custodial parent shall have reasonable and liberal
telephone contact with the Children.
8. 'ltlis order is entered pursuant to an agreement of the parties at a
Custody COnciliation COnference. The parties may modify the provisions of
this ~er by mutual consent. In the absence of mutual consent, the terms
of this order shall control.
BY THE CXlURT,
cc: Diane Rupich, Esquire - Counsel for Father
Linda A. Clotfelter, Esquire - Counsel for Mother ~
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JEFFREY K. WELSCH, . IN THE CXXJRT OF CXlMMON PLEAS OF
.
plaintiff/Respondent . CUI'BERLAND CXXlNTY, PENNSYLVANIA
.
.
.
vs. : NO. 94-2389 CIVIL TERM
.
.
KAREN R. WELSCH, . CIVIL ACTION - LAW
.
Defendant/Petitioner . IN CUSTODY
.
PRI~ JUDGE: J. WeBley Oler, Jr.
CUS'lOOY <XH:ILIATION SlM!ARY REPOOT
IN ACl:DRDANCE WITH CDlBERLAND CXXN.rll RULE OF CIVIL PRO "'J()RB
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
Dl\TE OF BIRl'H
CURRFNrLY IN COS'lOOY OF
Michelle L. Welsch
Charlene E. Welsch
Andrea C. Welsch
November 21, 1983
June 16, 1985
October 14, 1988
Father
Mother
Mother
2. A Conciliation Conference was held on June 28, 2000, with the
following individuals in attendance: The Father, Jeffrey K. Welsch, with
his counsel, Diane Rupich, Esquire, and the Mother, Karen R. Welsch, with
her counsel, Linda A. Clotfelter, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
4. It should be ncted that the parties have serious problems in
communicating with each other, which is affecting their ability to maintain
(and adjust when necessary) the ongoing custody schedule. The Ccnciliator
strongly recOlllllE!nded that the parties obtain counseling to assist them in
develop1ng sufficient communication to enable them to effectively coparent
their Children. The parties agreed to obtain counseling and preliminarily
selected, with the assistance of counsel, Arnold Shienvold, PhD. as their
initial contact.
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Date .
Da~
CUstody COnciliator
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JEFFREY K. WELSCH,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
:
:
:
v.
.
.
: NO: 94-2389 CIVIL TERM
KAREN R. WELSCH,
Defendant/Petitioner
.
.
:
CIVIL ACTION-LAW
IN CHILD CUSTODY
.
.
(Judge previously assigned: The Honorable J, Wesley Oler, Jr,)
ORDER OF COURT
AND NOW, this II..) day of M(\~ ' 2000,
upon consideration of the attached Petition, i is hereby directed
that the Oilrt-; es and their respective coum,el appear .before ,L:Q."'-K"'\
S' ~'-I, ~" the conciliator, at :.\01 W. \--\0'<"\2>\-1) \.-\~i(,)h..-f"
PENNSYLVANIA 17011 on the ;)1'\ day of )Jf'\0 ,J\
2000, at .3 00 -'L.m., for a Pre-Hearing Custody Conference, At
such conference, all effort will be made to resolve the issues in
dispute; or of 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.
FOR THE COURT,
By: I:"'-})\"\}\m J) ~\I(\MIA ,(.l\t '
Cusfoay Concll1ator~nl..J ~ (\'!).)
The Court of Common Pleas of Cumberland County is required by
law to comply with the Americans with Disabilities 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 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
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JEFFREY K. WELSCH,
plaintiff/Respondent
IN THE COURT OF COMMON PLEAS
CUKBERLANDCOUNTY, PENNSYLVANIA
:
.
.
.
.
v.
:
: NO: 94-2389 CIVIL TERM
KAREN R. WELSCH,
Defendant/petitioner
.
.
.
.
.
.
CIVIL ACTION-LAW
IN CHILD CUSTODY
EMERGENCY PETlTION FOR SPECIAL RELIEF AND MODIFICATION
OF CHILD CUSTODY ORDER
AND NOW, comes Defendant, Karen R, Welsch, by and through her
counsel, Law Offices of Craig A. Diehl, and files this Emergency
Petition for Special Relief and Modification of Custody Order,
respectfully stating in support thereof the following:
1. Petitioner/Defendant is Karen R. Welsh, (hereinafter
referred to as the "Petitioner"), an adult individual who resides
at 7103 Salem Park circle, Mechanicsburg, Cumberland county,
Pennsylvania 17055.
2. Respondent/plaintiff is Jeffrey K, Welsch, (hereinafter
referred to as the "Respondent"), an adult individual who resides
at 521 57th street, Altoona, Pennsylvania 16602.
3. The parties are the parent of three minor children,
namely:
Michelle L. Welsch, born November 21, 1983 (age 16);
Charlene E. Welsch, born June 16, 1985 (age 14); and
Andrea C. Welsch, born October 14, 1988 (age 11).
4. On or about August 27, 1997, an Order regarding child
custody was entered by the Honorable J. Wesley Oler, Jr., regarding
the subject children, A true and correct copy of said Order is
attached hereto as Exhibit "A" and is incorporated herein as if
fully set forth verbatim,
5. Said Order of Court awards shared legal custody to the
parties with primary physical custody of Michelle to Respondent
with partial custody to Petitioner and primary physical custody of
Charlene and Andrea to Petitioner with partial custody to
Respondent. (A true and correct copy of said Order is attached
hereto Exhibit "A" and is incorporated herein as if fully set forth
verbatim. )
6. As per the Order of Court, Petitioner is scheduled to
have physical custody of the children on Mernor ial Day, 2000.
However Respondent has indicated that he will refuse Petitioner
custody for that period and moreover, Respondent has made
unreasonable demands regarding alternatives to his refusal of
custody.
7. Petitioner seeks special relief on an expedited basis
such that the Memorial Day holiday dispute may be resolved prior to
said holiday, thereby ensuring continued contact with both parties.
8. Petitioner further alleges that the terms of the Order of
Court in this proceeding are not sUfficiently specific with regard
to time, place, and responsibilities for custody transfers.
9. Respondent makes unreasonable demands with regard to any
modification of the current Order of Court and refuses to
participate in the process of modifying said Order in any capacity.
10, Respondent's conduct in refusing custody for Petitioner's
holiday and with regard to the custody order in general has been
unreasonable.
11. At times, Respondent refuses to communicate in any manner
~~.,:::'~1'" ./
with Petitioner (whether same be by telephone, email, etc.) during
Petitioner's attempts to resolve any and all disputes.
12. Respondent has refused repeated offers of imp~rtial
third-party mediation.
13. The parties to this transaction are unable to amicably
resolve any temporary or permanent modifications to this Order due
to their inability to communicate effectively.
14. Defendant alleges herein that circumstances have changes
such a modification of the current Order is justified,
15. In the period of time since the most recent Order of
court, the children have grown and their various school and
extracurricular activities have changed such that a change in the
subject Order of Court regarding custody is necessary due to a
change in circumstances.
16. It is in the best interest of the children to modify said
Order of Court at this time to accommodate the changes in the
children's various schedules, the children's desires due to their
maturity, and any and all other relevant issues as necessary.
17. Petitioner specifically alleges that the modification of
said Order will ensure continued contact with both parties with
same being effectuated in a manner that is in the best interest of
the children,
WHEREFORE, Petitioner, Karen L. Welsch, respectfully requests
that this Court modify the current Order of custody thereby
changing transfer times, custody periods, and addressing any and
all other related issues that are relevant to this proceeding.
Respectfully submitted,
LAW OFFICES OF CRAIG A. DIEHL
nda A. Cl tfelter, E
torney I.D. No. 7296
3 64 Trindle Road
amp Hill, PA 17011
(717) 763-7613
JEFFREY K. WELSCH,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS
CUKBBRLANDCOUNTY, PENNSYLVANIA
v.
I
I
I
I
I
NOI 94-2389 CIVIL TERM
KAREN R. WELSCH,
Defendant/petitioner
.
.
I
I
CIVIL ACTION-LAW
IN CHILD CUSTODY
VERIFICATION
I, the undersigned, hereby verify that the statements made in
the foregoing document are true and correct to the best of my
knowledge, information and belief.
I understand that the
statements herein are made subject to the penalties of 18 Pa.C.S.
S 4904, relating to unsworn falsification to authorities.
Date: '1iJCUJ-tf), JOtJ()
(f
l!a.lUJ f? '(J..lU66
KJ(REN R. WELSCH
j(~J:."t.,~.."
~,
.
JEFFREY KENT WELSCH,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
NO, 94-2389 CIVIL TERM
KAREN RUTH WELSCH,
Defendant
CIVIL ACTION - LAW
CUSTODY /VISIT A TION
ORDER
AND NOW, this ;)l'!-;U" day of
(L..r
, 1997, upon receipt
of the Conciliator's Report, it appearing that the parties have agreed to the terms
and provisions of this Order which was dictated in their presence and approved by
them, it is hereby ordered and directed as follows:
1. All prior Orders entered in this case are vacated,
2, The parties shall share legal custody of their minor children,
Charlene E, Welsch, d,o,b, June 16, 1985, Andrea C, Welsch, d,o,b"
October 14, 1988, and Michelle L Welsch, d,o,b, November 21, 1983,
3, Mother shall have primary physical custody of Andrea and
Charlene, and Father shall have primary physical custody of Michelle;
however, both are subject to a custody schedule in accordance with
the following:
A, Week One: Mother will have Michelle from Friday
until Sunday and Father will have Charlene and Andrea from
Friday until Sunday, The parties will agree to exchange the
eXHIBIT "^"
"j
. .
children at 5:30 p,m, on Friday at either the Sideling Exit of
the Turnpike if the Sideling Exit has access from both East and
West, if not at the Ramada Inn off the 8reesewood Exit, They
shall return the children at 1 :45 p,m on Sunday,
8, Week Two: Father shall transport Michelle to
Mother's residence by 6:00 p,m, on Friday evening, and
Mother shall then transport Michelle to the drop off point as
indicated above on Sunday at 1 :45 p,m,
C. Week Three: Mother shall drop off Charlene and
Andrea at 6:00 p,m, on Friday outside of Father's residence,
The parties shall then meet so that Father can drop off
Charlene and Andrea on Sunday at 1 :45 p,m, at the drop off
point as indicated above,
D. Week Four: No exchange of visitation,
4, The parties shall alternate custody of the children on the
following holidays: Labor Day, Thanksgiving Day, President's Day,
Memorial Day, and Fourth of July, This holiday schedule shall include
the entire weekend and take precedence over the other schedule, This
alternating holiday schedule shall commence with Father having Labor
Day in 1997, The parties will agree to exchange the children at 5:00
p,m, on Friday at either the Sideling Exit of the Turnpike if the Sideling
~<t:-'tg ~~t'o. 'I
"\
Exit has access from both East and West, if not at the Ramada Inn off
the Breesewood Exit. They shall return the children at 5:00 p,m, on
the day of the holiday,
5, Mother shall have the children for Mother's Day, and Father
shall have the children for Father's Day, This period of partial custody
and visitation shall take precedence over any other schedule,
6, The Christmas holiday shall be in two segments, Segment A
shall be from December 23rd at 5:00 p,m, until December 26th at
12:00 noon, Segment B shall be from December 26th at 12:00 noon
until December 29th at 12:00 noon. Father shall have Segment A in
1997 and all odd-numbered years thereafter and Segment B in 1998
and all even-numbered years thereafter, Mother shall have Segment A
in 1998 and all even-numbered years thereafter and Segment B in
1997 and all odd-numbered years thereafter,
7, The parties shall share the summer vacation such that Father
shall have three full weeks of custody with the children all together,
and Mother shall have three full weeks of custody with the children all
together, Father shall also be entitled to one uninterrupted week of
vacation with Andrea and Charlene alone, and Mother shall be entitled
to one uninterrupted week of vacation with Michelle alone, Mother
shall provide Father with the weeks in which she intends to exercise
Mr, Jeffrey K, Welsch, pro se
Jeffrey C, Goss, Esquire
mlb
schedule,
-,
. .
her periods of visitation under this schedule no later than April 15th of
each year, and Father shall notify Mother of his schedule no later than
April 22nd of each year, For the remainder of the summer schedule,
there shall be no shifting of the custody between the parties, The
transportation for these periods of summer visitation shall be such that
the parent ending his or her period of custody with the children shall
drop the children off at the other party's residence,
8, Each parent and the children shall have reasonable telephone
access with each other while the children are in the custody of the
other parent. Reasonable telephone access shall not mean more than
fifteen (15) minutes total and shall not mean more than one telephone
contact per day, except in an extraordinary circumstances,
9. Father shall provide Mother with his cellular phone number:
to be used only in cases of emergency as it relates to this custodial
BY THE COURT,
IS/~~ ~]v
J, W LEY OLER, JR., J, '
TRlI'= COpy FROM RECORD
In Tt!t ,.: ,'.." ' ! h:.ra unto set my hald
and lhe s,al 0: :;J'd C~urt at Carli!le, Pa,
This..~J~. da~ Of.;~.., ~ 19.n,
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JEFFREY KENT WELSCH,
Plaintiff
vs,
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO, 94-2389 CIVIL TERM
KAREN RUTH WELSCH,
Defendant
CIVIL ACTION - LAW
CUSTODY /VISIT A TION
JUDGE PREVIOUSLY ASSIGNED: The Honorable J, Wesley Oler, Jr,
CUSTODY CONCILIATION CONFERENCE 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 concerning the child(ren) who is(are) the
subject of this litigation is as follows:
NAME
BIRTHDA TE
CURRENTLY IN
CUSTODY OF
Charlene E, Welsch
Andrea C, Welsch
Michelle L. Welsch
June 16, 1985
October 14, 1988
November 21, 1983
Defendant
Defendant
PI ai ntiff
2, A Conciliation Conference was held on August 21, 1997, and the
following individuals were present: the Plaintiff appeared pro se; the Defendant
appeared with her attorney, Jeffrey C, Goss, Esquire,
3, Items resolved by agreement: See attached Order.
4. Issues yet to be resolved: See attached Order,
-,
.. ,
5. The Plaintiff's position on custody is as follows: See attached Order.
6. The Defendant's position on custody is as follows: See attached Order.
7. Need for separate counsel to represent child(ren): Neither party
requested.
8. Need for independent psychological evaluation or counseling: None
requested and the Conciliator does not believe any is necessary.
Date: August 25, 1997
Michael L. Bangs
Custody Conciliator
. .
JEFFREY K. WELSCH,
Plaintiff/Respondent
IN THE COURT OF COHMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO: 94-2389 CIVIL TERM
KAREN R. WELSCH,
Defendant/Petitioner
CIVIL ACTION-LAW
IN CHILD CUSTODY
CERTIFICATE OP SERVICE
I, the undersigned, hereby certify that on this date, a true
and correct copy of the foregoing document was served upon the
opposing parties by way of united states First Class Mail, postage
prepaid, addressed as follows:
Jeffrey K. Welsch
571 57th street
Altoona, PA 16602
LAW OFFICES OF CRAIG A. DIEHL
Date: ~!5 Jrro
By: ~?n MJi-L-;
, S eph n eA. 00 e, Legal secretary
3464 Trindle Road
Camp Hill, PA 17011
(717) 763-7613
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94-2389 CIVIL ACTION LAW
JEFFREY K. WELSCH
PLAINTIFF
V.
KAREN R. WELSCH
DEFENDANT
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
IN CUSTODY
ORDER OF cOt JRT
AND NOW, this 4lh day of December. 2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. ,the conciliator.
at 39 West Main Slrecl, Mechanlcsburg, PAt 7055 on the t 9th dav of Deeember, 2000 ,at J1 :00 a.m.
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 thc issucs to bc beard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conlerence. Failure to appear at the conference may .
provide grounds for entry of a tcmporary or permanent order.
FOR TIlE COURT,
By: /5/
DawII S. SIll/day. E~?
Custody Conciliat~
The Court of Common PIcas 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 busincss before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATroRNEY AT ONCE. IF YOU DO NOT
HAVE AN ATIORNEY OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL liEU'.
Cumberland County Bar Association
2 Libel1y A vcnuc
Carlisle. Pennsylvania 17013
Telcphone (717) 249-3166
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JEFFREY K, WELSCH,
PlalntifflRespondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 94-2389 CIVIL TERM
KAREN R. WELSCH,
Defendant/Petitioner
: CIVIL ACTION - LAW
: IN CHILD CUSTODY
NOTICE AND ORDER TO APPEAR
To: Jeffrey K. Welsch
Legal proceedings have been brought against you alleging you have willfully disobeyed an
Order of Court for Custody.
If you wish to defend against a claim set forth in the following pages, you may but are not
required to file in writing with the Court your defcnses or objections.
Whether or not you file in writing with the Court your defenses or objections, you must
appear in person in Court on , at .m., in
Court Room , Cumberland County Courthouse, One Courthouse Square, Carlisle,
Pennsylvania.
IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR
YOUR ARREST.
I fthe Court finds that you have willfully failed to comply with its Ordcr for Custody, you may
be found to be in contcmpt of Court and committed to jail, fined, or both.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT
HA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
OF THE CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
BY THE COURT:
Dated:
J. Wesley Oler, Jr., J.
JEFFREY K. WELSCH,
Plaintiff/Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 94-2389 CIVIL TERM
KAREN R. WELSCH,
DefendantlPetitioner
: CIVIL ACTION - LAW
: IN CHILD CUSTODY
,'.
PETITION FOR CIVIL CONTEMPT
FOR DISOBEDIENCE OF CUSTODY ORDER
AND NOW comes Petitioner, Karen R. Welsch, Defendant in the above-captio~d ~lter,
by and through her counsel, Law Offices of Craig A. Diehl, and files this Petition for Civil Contempt
for Disobedience of Custody Order, respectfully stating in support thereof the following:
I. PetitionerlDefendant is Karen R. Welsch, (hereinafter referred to as the "Petitioner"),
an adult individual who resides at 7103 Salem Park Circle, Mechanicsburg, Cumberland County,
Pennsylvania 17050.
2. RespondentIPlaintilfis Jeffrey K. Welsch, (hereinafter referred to as the "Respondent"),
and adult individual who resides at 521 57th Street, Altoona, Pennsylvania 16602.
3. The parties are the parcnts of three minor children. namely:
Michelle L. Welsch, born November 21, 1983 (age 17);
Charlene E. Welsch, born June 16. 1985 (age 15); and
Andrea C. Welsch, born October 14,1988 (age 12).
4. On or about July 6, 2000, an Order regarding child custody was entered by the
Honorable J. Wesley Oler, Jr., regarding thc subjcct children. A true and correct copy of said Ordcr
is attached hereto as Exhibit "A" and is incorporated herein as iffully set forth verbatim.
5. As per Exhibit "A" attached hereto, said Ordcr of Court awards shared lcgal custody to
fhe parties with primary physical custody of Michelle to Respondent with partial custody to Petitioner
and primary physical custody of Charlenc and Andrcu to Petitioncr with partial custody to
Respondent.
6. Said Ordcr of Court is vcry specific as to thc various dcsignated weeks of custody, the
specific exchangcs and the manncr oftranslcrs duc to the distancc betwecn the rcsidences of the
parties.
7. Respondent has continually and repeatedly. by willful conduct, shown a wanton
disregard for the Court Order, and has failed to abidc by the Order in numerous ways including but
not limited to the following:
A. Most recently, Respondent has prevented Petitioner's period of custody with Michelle
which was scheduled for the weekend ofNovembcr fourth (4"') and fifth (5"'). This
was done unilaterally by Respondent without Petitioner's consent and with no
alternative suggestions for a substituted custody period. In fact. Respondent has
significantly limited thc number and frequencyofPetitioner'scustody periods with her
daughter, Michelle. to Petitioner's continue frustration. Respondent's failure to
comply with the Order of Court regarding Petitioner's periods of custody with
Michelle detrimentally affects the tmnsportation terms of the Order as Respondent
refuses at times to drive to the agreed-upon point oftransfer (approximately one-half
way) and then Petitioner is forced to drive the entire distance with the other two
children. Moreover. Respondent usually refuses to give Petitioner adequate
consideration when she is required to put forth more than she is required by Order.
B. On Friday, October 5,2000. Petitioner was 10 have custody of allthrce children.
Respondent, with a wanton disregard for the authority ofthe Court. failed to produce
Michelle for Petitioner's custody period on that date. In addition. pursuant to the
notation in the conciliation report, the parties werc scheduled for a counseling session
on that date. Respondent unilaterally, without notice to Petitioner, canceled the
counseling appointment and infonned the counselor that Respondent would not be
returning to this area until December, 2000, despite the Order of Court indicating that
Petitioner would have custody of Michelle during November.
C. On Friday. Sept 8. 2000, Petitioner was 10 have a period of custody with Michelle as
per the Order. with the exchange taking place when the parties met for counseling.
However. withoul notice to Pctitioner, Respondent failed to produce Michelle for the
custody transfer when he appeared for the counseling session. Respondent offered
no legitimafe explanations and no alternativc arrangemcnts for another period of
custody in lieu of the missed period.
.,,,,.,,,,-~.....
D. During thc Labor Day holiday Petitioner was to havc custody of all thrcc children, yct
contrary to thc Ordcr and Petitioner's exprcssed dcsircs, thc custody transfcr of
Michcllc did not takc placc. Thcrc was no noticc of Rcspondent's intcnt and/or
rcqucst to changc the transfer and no tclcphonc calls, c-mails or othcr attcmpts of
contact to Petitioncr by Rcspondent or the child rcgarding samc. Respondent willfully
and intcntionally disregard cd thc Court Ordcr regarding this custody transfcr.
E. On or about August 18. 2000, Respondcnt infonned Pctitioner that hc would not be
complying with the prcsent Custody Order in that he indicatcd that hc would not be
transporting the girls to Petitioner's residence and demanded that Petitioner mect
Rcspondcnt at thc one-halfway meeting point for custody transfcr, dcspitc thc Order
rcquiring Rcspondent to drive thc children to Petitioner's house in Cumberland
County, Pennsylvania. Despitc Pctitioner's requcst through counsel and othcrwise
that Respondcnt comply with thc tcrms of the Order, the custody transfer did not
occur as seheduled because Rcspondent drovc to thc one-half way point and then
returned home. Thereafter, Petitioner was forccd to drivc the cntirc distancc to
Altoona on the day following thc intended datc of transfer because Rcspondent
refuscd to drivc the children pursuant to the terms of the Order.
8. Respondcnt's vcxatious conduct in total disregard for the Court's authority has taken
placc continuously and repeatcdly throughout thc tenn ofthc subjcct Ordcr of Court to such an
extent that a complctc sununary of same would be impossible to compile. This conduct has becn
taking place for six (6) ycars, with Respondent's conduct being cgregious as pcr this Pctition.
9. Respondent's conduct has detrimentally alfected all ofthc childrcn cmotionally and
dcvclopmentally as they arc learning from Respondcnt that a total disrcgard of thc authority ofan
Order of Court is acccptablc behavior, despitc Petitioner's atlcmpts to tcach the childrcn certain
values and respect.
10. Pctitioner has madc repeatcd, substantial cfforts to diseuss thc terms ofthc Order of
Court, possiblc adjustments to thc custody schedulc upon agreement whcn requested by the parties'
children, possiblc counseling and mediation of outstanding issues, and all other aspects ofthc custody
proceeding with Respondent, only to have her cfforts rcfused and ignorcd by Respondent.
'"""""""....".
II. Rcspondent has frustrntcd Pctitioner's cfforts to rcsolvc any and all issues in this
proceeding amicably by disrcgarding tclcphone mcssages, c-mail and othcr corrcspondcncc on a
rcgular basis.
12. Respondent's continucd cgrcgious conduct has left Pctitioncr no altcrnativc but to file
this Pctition for Contempt.
13. Pctitioner has been forced to incur reasonable attorncy's fees of$400.00 in preparing
and presenting this Petition for Contempt.
14. Duc to Respondcnt's willful conduct in completc disregard for this authority of this
Court, Pctitioncr now requests that this Court find Respondent in direct contcmpt ofits Order dated
July 6, 2000, ordcr Respondcnt's compliance with said Order of Court, sanction Respondent as
pennitted by law, award Petitioner reasonable attorney's fecs of$400.00, and grant such other relief
as this Court dccms just and proper.
WHEREFORE, Pp-titioner, Karcn R. Wclsch, respectfully rcqucsts that this Honorable Court
grant Petitioner's Petition for Contempt, find Rcspondent in direct contcmpt of its Order dated July
6,2000, order Respondcnt's compliance with said Order of Court, sanction Rcspondent as pennitted
by law, award Petitioner reasonable attorney's fecs of $400.00, and grant such other relief as this
Court deems just and proper.
LAW OFFICES OF CRAIG A. DIEHL
\
inda A. Clot elter, Esquirc
ttorney 1.0. No. 72963
464 Trindlc Road
Camp Hill, PA 17011
(717) 763-7613
_.._'M,~V"
'.'
JEFFREY K. WELSCH,
PlalntlrrtRespondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 94-2389 CIVIL TERM
KAREN R. WELSCH,
DerendantlPetitloner
: CIVIL ACTION - LAW
: IN CHILD CUSTODY
VERIFICATION
I. KAREN R. WELSCH, verify that the statements made in the foregoing PETITION FOR
CONTEMPT are true and correct to the best of my knowledge, information and belief. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to
unsworn falsification to authorities.
DATED:17o-/..'.;} I, clao 0
(.iaLUl ,2 YL~~ Cv.cA...;
KA EN R. WELSCH
JEFFREY K. WELSCH, . IN THE CXXJRT OF CXX>IMOO PLEAS OF
.
Plaintiff/R~spondent . CUMBERLAND caJNTY, PENNSYLVANIA
.
.
.
vs. . NO. 94-2389 CIVIL TERM
.
.
.
KAREN R. WELSCH, . CIVIL ACTION - LAW
.
Defendant/Petitioner . IN CUSTODY
.
atDBR OF CXXlR'.l'
AND rDf, this I/~
upon consideratiooo of the attached
ordered and directed as follows:
Co~wation
day of
Custody
, 2000,
Report, it is
I. 7he prior Order of this Court dated August 27, 1997 is vacated and
replaced with this Order.
2. 7he Father, Jeffrey K. Welsch, and the Mother, Karen R. Welsch,
shall have shared legal custody of Michelle L. Welsch, born November 21,
1983, Charlene E. Welsch, born June 16, 1985 and Andrea C. Welsch, born
October 14, 1988. 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.
3. 7he Mother shall continue to have primary physical custody of
Andrea and Olarlene, and the Father shall continue to have primary physical
custody of Michelle.
4. During the school year, the parties shall have partial physical
custody of the Children in accordance with the following four-week cycle:
A. WEEK I: 'ltIe Mother shall have custody of Michelle from Friday
at 5:30 p.m. through Sunday at 3:00 p.m. and the Father shall
have custody of Charlene and Andrea from Friday at 5:30 p.m.
through Sunday at 3:00 p.m. Exchanges of custody under this
provision shall take place at Exit 13 (Ft. Littleton) of the
PA Turnpike.
B. WEEK II: The Mother shall have custody of all three Olildren
from Friday at 6:30 p.m. through Sunday at 3:00 p.m. For
purposes of this provision, the Father shall transport
Michelle to the Mother I s residence on Friday and the Mother
shall transport Michelle to Exit 13 (Ft. Littleton) of the PA
Turnpike on SUnday.
FXIIIBIT "A"
. .
C. WEEK III: 'l11e Father shall have custody of all three Children
fran Friday at 6:30 p.m. through Sunday at 3:00 p.m. For
purposes of this provision, the Mother shall transport
Charlene and Andrea to the Father's residence on Friday and
the Father shall transport Charlene and Andrea to Exit 13 (Ft.
Littleton) of the PA Turnpike on Sunday.
D. WEEK IV: No exchange of custody.
E. 'l11e parties shall strictly abide by the custody exchange times
set forth in this Order and acknowledge the necessity of a
timely exchange particularly on sundays at 3:00 p.m., due to
the Father's work schedule.
5. The parties shall share or alternate having custody of the
Children on holidays as follows:
A. CBRIS'.I!IAS: The Chrisbnas holiday shall be divided into
segment A, which shall run fran December 23 at 5:00 p.m.
through December 26 at 12:00 noon, and Segment B, which shall
run fran December 26 at 12:oo noon through DecenDer 29 at
12:00 noon. The Father shall have custody of the Children
during Segment A in odd nurrbered years and during Segment B in
even nurrbered years. The Mother shall have custody of the
Children during segment A in even nurrbered years and during
Segment B in odd numbered years. The party relinquishing
custody of the Qlildren under this provision shall be
responsible to provide transportation to the other party's
residence, with the exception of the exchange on December 29,
which shall occur at Exit 13 (Ft. Littleton) of the PA
Turnpike.
B. TBANKSGIVING: 'l11e Father shall have custody of the Children
over Thanksgiving in even nurrbered years and the Mother shall
have custody of the Children over 'l11anksgi ving in odd numbered
years. In even numbered years, the Mother shall transport
Charlene and Andrea to the Father's residence on the Wednesday
before Thanksgiving at 6:30 p.m. and the return exchange of
custody shall take place at Exit 13 (Ft. Littleton) of the PA
Turnpike on the Monday after Thanksgiving at 3:00 p.m. In odd
nurrbered years, the Father shall transport Michelle to the
Mother's residence on the Wednesday before Thanksgiving at
4:30 p.m. and the return exchange of custody shall take place
at Exit 13 (Ft. Littleton) of the PA Turnpike on the Monday
after Thanksgiving at 3:00 p.m.
C. EASTER: The Easter holiday shall run fran Good Friday at 9:00
a.m. through Easter Sunday at 5:30 p.m. 'l11e Father shall have
custody of the Children over Easter in even numbered years and
the Mother shall have custody over the Easter holiday in odd
numbered years. CUstody exchanges for the Easter holiday
. .
shall take place at Ft. Littleton.
D. MPXlUAL DAY/JULY 4t:h/LABC1t DAY: The parties shall alternate
having custody of the Children on Memorial Day, July 4th and
Labor Day. The Memorial Day and Labor Day holidays shall run
fran Friday at 5:30 p.m. through Monday at 5:30 p.m. and the
July 4th holiday shall fall within the extended weeks of
custody under the sunmer schedule. In even numbered years,
the Mother shall have custody of the Children on Memorial Day
and Labor Day and the Father shall have custody on July 4th.
In odd numbered years, the Father shall have custody of the
Children on Memorial Day and Labor Day and the Mother shall
have custody on July 4th. Exchanges of custody under this
provision shall take place at Ft. Littleton.
E. 1uJ,=<K'S DAY/FM'BER'S DAY: The Mother shall have custody of
the Children every year on Mother's Day weekend fran Friday at
5:30 p.m. through sunday at 6:30 p.m. and the Father shall
have custody of the Children every year on Father's Day
weekend fran Friday at 5:30 p.m. through sunday at 6:30 p.m.
Exchanges of custody under this provisicn shall take place at
Ft. Littleton.
F. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
6. During the surrmer school break each year, each party shall be
entitled to have 3 full weeks of custody with all three Children together.
In addition, the Father shall be entitled to have a I week period of
uninterrupted custody with Andrea and Charlene alone and the Mother shall
be entitled to have a I week period of uninterrupted custody with Michelle
alone. In even nUllbered years, the Mother shall provide the Father with
the dates on which she intends to exercise her periods of custody under
this provisicn no later than March 15 and the Father shall notify the
Mother of his schedule no later than March 22. In odd numbered years, the
Father shall provide the Mother with the dates on which he intends to
exercise his periods of custody under this provision no later than March 15
and the Mother shall notify the Father of her schedule no later than March
22. The Father shall provide to the Mother the sunmer camp schedule for
the Children by February 1 each year. The sunmer schedule set forth in
this provision shall supercede the school year schedule (4 week cycle),
which shall be suspended during the sunmer. For exchanges of custody under
this provision, the party relinquishing custody shall provide
transportation to the other party's residence.
7. 111e non-custodial parent shall have reasonable and liberal
telephone contact with the Children.
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 lIlltual consent. In the absence of mutual consent, the terms
of this order shall control.
BY THE COURT,
IS
J.
J.
cc: Diane Rupich, Esquire - COunsel for Father
Linda A. Clotfelter, Esquire - COunsel for Mother
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In T"!.Fmc~J '..h .:' ,.f. I i', ;,- I)"'I? !...t my hand
and lh~ sea: c; .'ilid Court st Carlisle, Pa.
~~~~
. .
".
JEFFREY K. WELSCH, . IN THE CXlURT OF OOMMON PLEAS OF
.
Plaintiff/Respondent . CtwBERLAND CCXJNTY, PENNSYLVANIA
.
.
.
vs. . NO. 94-2389 CIVIL TERM
.
.
.
KAREN R. WELSCH , . CIVIL ACTIOO - LAW
.
Defendant/Petitioner . IN CUSTODY
.
PRIm JUDGE: J. Wesley Oler, Jr.
CDS'lmY cx:NCILIAn~ &HIARY REPCm.'
IN ACXXlRIlllNCE WITH cnmERLAND cxxmx RULE OF CIVIL PRO""" (JRB
1915.3-8, the undersigned CUstody Conciliator submits the following report:
I. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIm.'B
CIJRRENTLY IN CIlSTCDY OF
Michelle L. welsch
Charlene E. Welsch
Andrea C. Welsch
November 2l, 1983
June 16, 1985
October 14, 1988
Father
Mother
Mother
2. A Conciliation Conference was held en June 28, 2000, with the
following individuals in attendance: '!he Father, Jeffrey K. Welsch, with
his counsel, Diane Rupich, Esquire, and the Mother, Karen R. Welsch, with
her counsel, Linda A. Clotfelter, Esquire.
3. The parties agreed to entty of an Order in the form as attached.
4. It should be ncted that the parties have serious problems in
cOllll1Uflicating with each other, which is affecting their ability to maintain
(and adjust when necessary) the ongoing custody schedule. itle Ccnciliator
strongly reccxrmended that the parties obtain counseling to assist them in
deve10pfng sufficient CClIIIlIUllication to enable them to effectively coparent
their Children. The parties agreed to obtain counseling and preliminarily
selected, with the assistance of counsel, Arnold Shienvold, PhD. as their
initial contact.
.l.J./t\ ~ ;; 7. dJo l') cJ
Date .
Da~
CUstody Conciliator
. .
JEFFREY K. WELSCH,
Plaintiff/Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLANI) COUNTY, PENNSYLVANIA
v.
: NO, 94-2389 CIVIL TERM
KAREN R. WELSCH,
DefendantlPetltioner
: CIVIL ACTION - LAW
: IN CHILD CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this ..30'#- day of 17 f IIi:? '')1h" r .2000, the undersigned
hereby certifies that a true and corrcct copy of the foregoing PETITION FOR CONTEMPT was
served upon the opposing party by hand delivery at the following address:
Diane M. Rupich, Esquire
OILS & RUPICH
1017 North Front Street
H~sburg, PA 17102
LAW OFFICES OF CRAIG A. DIEHL
By, ~~",'4fhnru
.....Stephanie A. Moofc. L gal Secretary
3464 Trindle Road
Camp Hill, PA 17011
(717)763-7613
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upon consideration of the attached
ordered and directed as follows:
day of
Custody
2001
JfttU 2J ~ ' '2000,
COnc 1 at ion Report, it is
.
JEFFREY K. WELSCH, . IN THE a:xmT OF CXJtoIlolCX>l PLEAS OF
.
Plaintiff . CUMBERLAND COONTY, PENNSYLVANIA
.
:
vs. . NO. 94-2389 CIVIL TERM
.
.
.
KAREN R. WELSCH, . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
aIDER OF CXXJRT
1. The prior Order of this Court dated July 6, 2000 is vacated and
replaced with this Order.
2. '!he Father, Jeffrey K. Welsch and the Mother, Karen R. Welsch,
shall have shared legal custody of Michelle L. Welsch, born November 21,
1983, Charlene E. Welsch, born June 16, 1985, and Andrea C. Welsch, born
October 14, 1988. 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.
3. The Mother shall have primary physical custody of Andrea and
Charlene.
4. During the school year, the Father shall have partial physical
custody of Andrea and Charlene on alternating weekends from Friday at 4:30
p.m. through SUnday at l:30 p.m. beginning January 19, 2ool. The parties
shall make adjustments as necessary to the partial custody schedule in
order to accOlllllCXlate the Children's regular activities schedule. In the
event only one Child is unavailable for a period of custody due to an
activity, the other Child shall be made available for that period of
custody, unless otherwise agreed between the parties.
5. '!he alternating weekend custody schedule shall be suspended during
the slll111ler school break. During the slll111ler school break each year the
Father shall be entitled to have 3 full weeks of custody with the Children
upon notifying the Mother of his selection of dates no later than March 22.
'!he Mother shall be entitled to reserve a period of custody for vacation
each slll11l1er upon providing notice to the Father prior to his selection of
vacation dates. '!he p3rty providing notice first shall be entitled to
preference on his or her selection of dates. The parties acknowledge that
the Mother has reserved a period of custody from July 26, 2001 through
August 5, 2001.
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6. 'l11e parties shall share or alternate having custody of Andrea and
Charlene on holidays as follows:
A. CIIRISDW;: 'l11e O1ristmas holiday shall be divided into
Segment A, which shall run from DeceJrber 23 at 4:30 p.m.
through December 26 at 12:00 noon, and Segment B, which shall
run from December 26 at 12:00 noon through DeceJrber 29 at
12:00 noon. The Father shall have custody of the Children
during Segment A in odd numbered years and during Segment B in
even numbered years. The Mother shall have custody of the
Children during Segment A in even numbered years and during
Segroont B in odd numbered years.
B. '.l'IIANItSGIVI: 'l11e 'l11anksgiving holiday shall run from
Thanksgiving Day' at 10:00 a.m. through the following Monday at
1:30 p.m. The Father shall have custody of the Children over
Thanksgiving in even numbered years and the Mother shall have
custody of the Children over Thanksgiving in odd numbered
years.
C. EllS'l'ER: 'l11e Easter holiday shall run from the 'l11ursday before
Easter at 4:30 p.m. through Easter Sunday at 5:30 p.m. The
Father shall have custody of the Children over Easter in even
numbered years and the Mother shall have custody over the
Easter holiday in odd numbered years.
D. ME'X:RIAL DAY/JULY 4th/LAIlCR DAY: The parties shall alternate
having custody of the Children on Memorial Day, July 4th and
Labor Day. The Memorial Day and Labor Day holidays shall run
from Friday at 4:30 p.m. through Monday at 4:30 p.m. and the
July 4th holiday shall fall within the extended weeks of
custody under the sumner schedule. In even numbered years,
the Mother shall have custody of the Children on Memorial Day
and Labor Day and the Father shall have custody on July 4th.
In odd numbered years, the Father shall have custody of the
Children on Memorial Day and Labor Day and the Mother shall
have custody on July 4th.
E. l'U!lIm('S DAY/FATHER'S DAY: The Mother shall have custody of
the Children every year on Mother's Day weekend from Friday at
4:30 p.m. through Sunday at 4:30 p.m. and the Father shall
have custody of the Children every year on Father's Day
weekend from Friday at 4:30 p.m. through Sunday at 4:30 p.m.
F. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
7. The parties acknowledge that their 17 year old daughter, Michelle,
is currently living independently outside either of their households. Each
party shall be entitled to have periods of partial custody with Michelle as
arranged by agreement between Michelle and each parent.
8. Both parties shall encourage ongoing contact between Michelle,
Charlene and Andrea.
9. Unless otherwise agreed between the parties, the party receiving
custody of the Child or Children, shall be responsible to provide
transportation for the exchange of custody. The parties shall cooperate in
adjusting exchange times as necessary to accommodate the Children's
activities. All exchanges, unless agreed otherwise, shall take place at
the respective parties' residences.
10. The IlOn-custodial parent shall have reasonable and liberal
telephone contact with the Children.
11. The parties shall participate in a course of mediation with Bonnie
Howard or other mediator selected by agreement of the parties. The purpose
of the mediation shall be to improve communications between the parties and
to address conflicts which have arisen with respect to parenting of the
Children. The parties shall attend a minimum of 6 mediation sessions and
shall contact the mediator within 2 weeks of the date of this Order to
schedule the first session. The parties shall follow the recommendations
of the mediator with regard to the duration and frequency of sessions.
12. 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 CDURT,
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cc:
Diane M. Rupich, Esquire - Counsel for Father
Linda A. Clotfelter, Esquire - Counsel for Mother
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JEFFREY K. WELSCH,
Plaintiff
: IN THE CXlURT OF ~ PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
: NO. 94-2389 CIVIL TERM
.
.
KAREN R. WELSCH,
Defendant
: CIVIL ACTION - LAW
: IN cusrooy
PRIOO JUDGE: J. Wesley Oler, Jr.
CUSTODY CXtiCILIATION SlNIARY REPCRl'
IN ACXXIIDl\NCE WITH comERLAND CXXmY RULE OF CIVIL m:.... (JRE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. Tbe pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
CURRENl'Ly IN aJSTCVY OF
Michelle L. welsch
November 21, 1983
Charlene E. Welsch
Andrea C. Welsch
June 16, 1985
October 14, 1988
Currently living
independently
Mother
Mother
2. A Conciliation Conference was held on January 10, 2001, with the
following individuals in attendance: The Father, Jeffrey K. Welsch, with
his counsel, Diane M. Rupich, Esquire, and the Mother, Karen R. Welsch,
with her counsel, Linda Clotfelter, Esquire. The parties' 17 year old
daughter, Michelle L. Welsch, also participated in a portion of the
Conference.
3. Tbe parties agreed to entry of an Order in the form as attached.
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Date
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Dawn S. Sunday, Esquire
Custody Conciliator
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JEFFREY K. WELSCH
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
94-2389 CIVIL ACTION LAW
KAREN R. WELSCH
DEFENDANT
IN CUSTODY
ORDER OF COtJRT
AND NOW,
Thursday, Augusl 01, 2002
. upon consideration of the attached Complaint,
it is hcreby directed that parties and thcir respective counsel appcar before Dawn S. Sunday, Esq. , the conciliator,
at 39 Wesl Main Slreel. Meehanluburg. PA 17055 on Thursday, August 22, 2002 at 1:00 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. 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 pemlanentorder.
The court hereby directs the parties 10 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 TilE COURT.
By: /,/
Dawn S. Snnd4J'. Esq.'n/
Custody Conciliator U
The Court of Common Pleas ofCumbcrland County is requircd 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 arrangem~nts
must be made at least 72 hours prior to any hearing or business belore tbe court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE TIllS PAPER TO YOUR AnORNEY AT ONCE. IF YOU DO NOT
HA VE AN A nORNEY OR CANNOT AFFORD ONE. GO TO OR TELEplIONE THE OFFICE SET
fORTH BELOW TO FIND OUT WIIERE YOU CAN GET I.EGAI. HELP.
Cumberland County Ilar Association
2 Liberty Avenue
Carlisle. Pennsylvania 17013
Telephone (717)249-3166
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IUL 1 5 200~ r
Dear Cumberland County Court Administrator,
I feel it necessary to give a brief explanation of a special
need I have concerning the enclosed request for a Conciliator's
hearing.
The request comes so that my daughter, Andrea, will be able to
reside with my wife and I in Bedford. However, we certainly hope
this can be accomplished before the school year begins. Therefore,
with Andrea's mother and myself being away for the next few weeks,
we cannot honor a court date before August ~1. If at all possible,
a court date set for sometime that week would be ideal, and the
earlier the better. I recognize this only gives us a 2-week window
of opportunity to schedule in the midst of what I imagine is a full
schedule, but it is crucidl that this custody issue be determined
before the school year begins. Any help you can offer in this
matter will be greatly appreciated. I do thank you in advance for
your kind consideration.
Sincerely,
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JeffJ:) K. Welsch
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Jeffrey K. Welsch, Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. q''f- ~ 3'8'7 CIVIL TERM
v.
Karen R. Welsch, Defendant
CUSTODY
PETITION TO MODIFY VISITATION AND CUSTODY
1. The Plaintiff is Jeffrev K. Welsch, residing at 149 Arandale St..
Bedford. PA 15522.
2. The Defendant is Karen R. Welsch, residing at 7103 Salem Park
Circle. Mechanicsburq. PA 17055.
3. Plaintiff seeks modification of visitation of the following
children:
NAME
Charlene E. Welsch
Andrea C. Welsch
PRESENT ADDRESS
7103 Salem Park Circle, Mechanicsburg, PA
7103 Salem Park Circle, Mechanicsburg, PA
Mili
17
12
The children were not born out of wedlock, and they are presently
in the custody of Karen R. Welsch, who resides at 7103 Salem Park Circle.
Mechanicsburq. PA 17055.
Charlene and Andrea were not born out of wedlock, and are presently
in the custody of Karen R. Welsch, who resides at 7103 Salem Park Circle.
Mechanicsburq, PA 17055.
Prior to January, 1994, all three children lived with Jeff and Karen
Welsch (Plaintiff and Defendant) at 5513 Silvercreek Dr., Mechanicsburg.
The mother of the children is Karen R. Welsch, currently residing
at 7103 Salem Park Circle. Mechanicsburq. Pa.. 17055. The mother is
divorced.
The father of the children is Jeffrev K. Welsch, currently residing
at 149 Arandale St.. Bedford, PA 15522. The father is divorced and
re-married.
4. The relationship of the Plaintiff to the children is father.
The Plaintiff currently resides with:
NAME
Janic~ Welsch
RELATIONSHIP
Wife
5. The relationship of the Defendant to the children is mother. The
Defendant currently resides with:
NAME
Charlene-E. Welsch
Andrea C. Welsch
RELATIONSHIP
Daughter
Daughter
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6. Plaintiff has participated as a party in other
concerning the custody of his minor children in this court
Common Pleas of Cumberland Countv. PA.. docket H94-2389.
7. Charlene and Andrea have a wonderful time when they visit in
Bedford as they participate in numerous church functions, seeing friends,
spending time with their grandparents, aunt, and cousins, and benefitting
from a stable home life with Plaintiff, his wife, Jan, and older sister,
Michelle. The best interest and permanent welfare of the children will
be served by granting relief in the following matters requiring
modification of visitation:
litigation
- Court of
A) plaintiff requests that Andrea C Welsch be designated to be under the
care and nurture of Jeff (Plaintiff) and Jan Welsch. Andrea desires to
permanently reside in Bedford with her father and step-mother. This is
not a sudden decision, as she has pondered it for the entire year that
the Plaintiff and Jan have lived in Bedford. She has made the formal
decision to move before the new school year, and her decision is
supported by our court-appointed counselor, Dr. Howard. Andrea has a
very loving and beneficial relationship with her step-mother, Jan; and
has a wonderful relationship with her father (Plaintiff), and is assured
that there will not be times in which father would treat her cruelly or
with selfish motives - she has complete confidence that father will
always love her and do what is best for her, both physically and
emotionally. Andrea is happy, healthy, and extremely excited about
living in Bedford. Completely absent at Plaintiff's home in Bedford are
the negative elements Andrea desires to leave while residing with the
Defendant. It is fitting and proper that the court recognize and
re-designate Andrea's change of residence.
8. Parental rights to the children have not been terminated for
either parent and the person who has physical custody of the child have
been named as parties to these actions. The only persons claiming
parental rights are the Plaintiff (father), his wife, Jan (step-mother),
and Defendant (mother). No other person claims parental rights to the
two children.
WHEREFORE, Plaintiff requests this court to grant this modification
of residence and custody of Andrea.
Respectfully Suhmitt~d.
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Plaintiff
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JUL 1 5 2002 r
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Jeffrey K. Welsch, Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. CN- ~ 3'i1'1 CIVIL TSRM
v.
Karen R. Welsch, Defendant
CUSTODY
PETITION TO MODIFY VISITATION AND CUSTODY
'..
1. The Plaintiff is Jeffrey K. Welsch, residing at 149 Ara~dal~ St .'.
Bedford. PA 15522.
2.
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The Defendant is Karen R. Welsch, residing at 7103 Salem Park
Mechanicsburq, PA 17055.
3. Plaintiff seeks modification of visitation of the following
children:
NAME
Charlene E. Welsch
Andrea C. Welsch
PRESENT ADDRESS
7103 Salem Park Circle, Mechanicsburg, PA
7103 Salem Park Circle, Mechanicsburg, PA
AGE
17
12
The children were not born out of wedlock, and they are presently
in the custody of Karen R. Welsch, who resides at 7103 Salem Park Circle,
Mechanicsburq, PA 17055.
Charlene and Andrea were not born out of wedlock, and are presently
in the custody of Karen R. Welsch, who resides at 7103 Salem Park Circle.
Mechanicsburq. PA 17055.
Prior to January, 1994, all three children liyed with Jeff and Karen
Welsch (Plaintiff and Defendant) at 5513 Silyercreek Dr., Mechanicsburg.
The mother of the children is Karen R. Welsch, currently residing
at 7103 Salem Park Circle. Mechanicsburq. Pa. , 17055. The mother is
divorced.
The father of the children is Jeffrey K. Welsch, currently residing
at 149 Arandale St. , Bedford. PA 15522. The father is divorced and
re-married.
4. The relationship of the Plaintiff to the children is father.
The Plaintiff currently resides with:
NAME
Janic~ Welsch
RELATIONSHIP
Wife
5. The relationship of the Defendant to the children is mother. The
Defendant currently resides with:
NAME
Charlene E. Welsch
Andrea C. Welsch
RELATIONSHIP
Daughter
Daughter
1
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. .
6. Plaintiff has participated as a party in other litigation
concerning the custody of his minor children in this court - Court of
Common Pleas of Cumberland County. PA.. docket 1194-2389.
7. Charlene and Andrea have a wonderful time when they visit in
Bedford as they participate in numerous church functions, seeing friends,
spending time with their grandparents, aunt, and cousins, and benefitting
from a stable home life with Plaintiff, his wife, Jan, and older sister,
Michelle. The best interest and permanent welfare of the children will
be served by granting relief in the following matters requiring
modification of visitation:
A) plaintiff requests that Andrea C Welsch be designated to be under the
care and nurture of Jeff (Plaintiff) and Jan Welsch. Andrea desires to
permanently reside in Bedford with her father and step-mother. This is
not a sudden decision, as she has pondered it for the entire year that
the Plaintiff and Jan have lived in Bedford. She has made the formal
decision to move before the new school year, and her decision is
supported by our court-appointed counselor, Dr. Howard. Andrea has a
very loving and beneficial relationship with her step-mother, Jan; and
has a wonderful relationship with her father (Plaintiff), and is assured
that there will not be times in which father would treat her cruelly or
with selfish motives - she has complete confidence that father will
always love her and do what is best for her, both physically and
emotionally. Andrea is happy, healthy, and extremely excited about
living in Bedford. Completely absent at Plaintiff's home in Bedford are
the negative elements Andrea desires to leave while residing with the
Defendant. It is fitting and proper that the court recognize and
re-designate Andrea's change of residence.
8. Parental rights to the children have not been terminated for
either parent and the person who has physical custody of the child have
been named as parties to these actions. The only persons claiming
parental rights are the Plaintiff (father), his wife, Jan (step-mother),
and Defendant (mother). No other person claims parental rights to the
two children.
WHEREFORE, Plaintiff requests this court to grant this modification
of residence and custody of Andrea.
Respectfully Submitt~d,
7 !;d. /0:::1
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Date
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2
KAREN R. WELSCH,
Defcndant
IN CUSTODY
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-2389 CIVIL ACTION LAW
JEFFREY K. WELSCH,
Plaintiff
ORDER OF COURT
AND NOW, this \ L~ day of ~,.- r.. '- ~ r ,2002, upon
considcration ofthc attached Custody Conciliation Report, it is ordcr~~cted as follows:
A Hearing is scheduled in Court Room 111, ofthc Cumbcrland County Court House, on
thc .:JJ b[ day of )1,t~, "nil"....... , 2002, at Z; 3t' 0 'clock,
~.m., at which timc testimony will be taken. For purposes of this Hearing, thc Father, Jeffrey K.
Wclsch, shall be deemed to be the moving party and shall procced initially with testimony. Counsel
for the parties or a party Pro Sc shall tile with thc Court and opposing counsel a Memorandum setting
forth each party's position on custody, a list of witncsses who arc expectcd to testify at thc Hcaring,
and a summary of the anticipated testimony of cach witness. Thesc Mcmoranda shall be tiled at Icast
ten (10) days prior to the Hearing date.
BY THE COURT,
J
cc: Jeffrey K. Welsch, Father
Linda A. Clotfeltcr, Esquire - Counsel for Mother
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vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
JEFFREY K. WELSCH,
Plaintiff
: 94-2389
KAREN R. WELSCH,
Defendant
IN CUSTODY
PRIOR JUDGE: J. Wcsley Oler, Jr.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits thc following report:
I. The pertinent infornlation concerning the Childrcn who arc thc subjects of this litigation is
as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Charlene E. Welsch
Andrea C. Wclsch
June 16, 1985
Octobcr 14,1988
Mother
Mother
2. A Conciliation Conferencc was held on August 27, 2002, with the following individuals in
attendance: The Mother, Karen R. Welsch, with her counsel, Linda A. Clotfelter, Esquire, and the
Fathcr, Jeffrey K. Welsch, who was not represented by counsel.
3. The Father filed this Petition Pro Se seeking primary physical custody of the parties' 13 year
old daughter, Andrea. The Father, who is rcmarried, has been living in Bcdford, Pennsylvania and the
Mother is in the process of moving to Middletown with her fianec', Andrea, and the parties' 17 year
old daughter, Charlene. Following a prior Conciliation Conference, the parties engaged in mediation
with Bonnie Howard. However, thc parties were not able to reach an agreement at the Conference and
it will be necessary to schedule a Hcaring.
4. The Father's position on custody is as follows: The Father statcd that he has filed this
petition based on Andrea's request to Iivc with the Father and his wifc in Bedford. According to the
Father, the Child is adamantly opposed to beginning the new school year in Middlctown as a result of
the movc with her Mothcr. Even beforc the Mother's decision to move, the Father stated that Andrea
expressed her desire to begin this school ycar in Bedford. The Father assured thc Mother that ifhe had
primary custody, Andrea would be available for all periods of partial custody with thc Mother. He
further proposed that primary custody could automatically be transferred back to the Mother if the
Child was not present for all schcdulcd periods of custody. The Father belicves that disrcgarding
Andrea's strong preference in the custody arrangement would be dctrimcntal to thc Child and will
causc resentmcnt toward thc Mother. Thc Fathcr denied the Mother's allcgations that hc had
prcviously interfered with periods of partial custody between thc Mother and thc parties' oldest Child,
Michelle, when Michelle was transferred to the Father's primary custody at Andrea's age.
5. The Mother's position on custody is as follows: The Mother belicves that it would be in thc
Child's best intercst to continue to reside with the Mother the Mother's fiance', and hcr 17 year old
sister, Charlene. Thc Mother expressed conccrn that Andrea may ncvcr fcel at home in thc new family
unit thc Mother is creating if she docsn't spend at least onc year living in Middlctown on a primary
basis. The Mothcr stated that she would be willing to transfer primary custody of the Child (if the
Child still dcsired to do so) at thc cnd of thc 2002-2003 school year. The Mother also expressed
eonecrn for Charlenc's bcst interests as the two sisters havc a very close rclationship. Finally, thc
Mothcr stated that when Michelle wcnt to live with thc Father, the Mother's relationship with Michelle
deteriorated due to her habitual unavailability for periods of partial custody with thc Mother. The
Mother fears that the samc situation may develop with Andrea if she wcrc to live primarily with fhe
Father.
matter.
6. The Conciliator recommends an Order in the form as attached scheduling a Hearing in this
It is cxpected that the Hearing will requirc at least one-half day.
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Dawn S. Sunday, Esquire d
Custody Conciliator
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JEFFREY K. WELSCH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LA W
KAREN R. WELSCH,
Dcfcndant
NO. 94-2389 CIVIL TERM
IN RE: CUSTODY
ORDER OF COURT
AND NOW, this 26th day of Novcmbcr, 2002, upon considcration ofthc attachcd
Icttcr from Dianc M. Dils, Esq., the hearing scheduled for November 27, 2002, is
continucd gcnerally.
COUNSEL ARE requested to contact the court if they desire a hearing in this
matter.
BY THE COURT.
Jbiane M. Dils, Esq.
1017 North Front Street
Harrisburg, P A 17102
J.
I Linda A. Clotfclter. Esq.
3464 Trindle Road
Camp 1-1iI1. PA 17011
Attorney for Dcfendant
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HOY-26-2002 03:13 PM DILS&DILS
71723321567
P.02
Q1~ &, ar~.
ATTO"N!YS AT LAW
ARTHUR K. OILS
DIANe M. DIL3
1017 NORTH FIlONT lITlleeT
HARRISIIURG. PFNN!lVI VANIA 17102
PHONE: (717)233-87'3
FAX' (717) 233.2557
November 26, 2002
The Honorable J. Wesley Oler, Jr,
Cumberland County Courthouse
1 Courthouse! Square
Carlisle, PAl 70 13
RE: Jeffrey K. Welsch VS. Karen R. Welsch
No. 94-2389 Civil Tefm
near Judge DIeT:
I represent Jeffrey K. Welsch; Karen R. Welsch is represented by Attorney Linda
A. Clotfelter. A custody trial j" !lchectuled hefore your Honorable Court for
Wednesday, November 27, 2002.
The parties have reached an agreement and it is respectfully reque!\ted that the
above matter be continued generally so that counsel hus un opportunity to preparc a
Stipulatiun and Agreement for signamre by the parties, which we will be
submitting to your Honorable Court to be made an Order.
I llJTI faxing a copy of this letter to Attol'lley Linda A. Clutfelter; however, Attorney
Clotfelter has given me authorization to convey this representation to your
Honorahle Court.
Thank you for your assistance in this matter.
~trulY yours
I .
cy1.
Diane M. Oils
DMD/daf
cc: Linda A, Clotfelter, Esquire
., ~'.~ ~:~... - , ."
JEFFREY K. WELSCH,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 94-2389 Civil Tcnn
KAREN R. WELSCH,
Dcfcndant
CIVIL ACTION - LA W
CUSTODY
PRAECIPE
TO THE PROTHONOTARY:
Please enter the appearance of Diane M. Oils, Esquire, 1017 North Front
Street, Harrisburg, Pennsylvania 17102, on behalf of the Plaintiff, Jeffrey K.
Welsch, in connection with the above-captioned custody action.
Respectfully submitted,
BY:
Diane M. i1s, Esquire
1017 North Front Street
Harrisburg, P A 17102
(717) 232-9724
I.D. No. 71873
Date: November 12, 2002
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JEFFREY K. WELSCH,
Plaintiff
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
VS.
No. 94..23119 Civil Terlll
KAREN R. WELSCH,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
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AND NOW, this --UlL day of Deesmoer 2002, the above-captioned matter
having been previously set for Trial on November 27, 2002, and this Court having been
informed that the parties reached an agreement through their counsel, it is hereby
ORDERED:
I. The prior Order of this Court dated January 20, 2000, is vacated and replaced with
this Order.
2. The father, Jeffrey K. Welsch, and the mother, Karen R. Welsch, shall have shared
legal custody of Charlene E. Welsch, born June 16, 1985, and Andrea C. Welsch,
born October 14, 1988. 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.
3. The mother shall have primary physical custody of Charlene E. Welsch and the
father shall primary physical custody of Andrea C. Welsch commencing
December 26, 2002. The parties' oldest daughter, Michelle L. Welsch, has
reached majority and therefore, is not a part of this Order of Court. (It is noted
that the mother, Karen R. Welsch, docs not believe that it is in the best interest of
Andrea C. Welsch to change her primary residence; however, mother does consent
to this Order and change of custody of Andrea C. Welsch as evidenced by her
signature to the Stipulation and Agreement.)
4. Charlene E. Welsch is currently 17 years of age and will soon be 18 years of age
and therefore, partial custody periods between Charlene E. Welsch and father,
Jeffrey K. Welsch, shall be arranged by agreement among Charlene and mother
and father. Transportation shall be provided to father's home by mother during
Charlene's custody periods and father shall return Charlene to her mother's home
upon the conclusion of partial custody periods.
5. Mother shall have partial custody of Andrea C. Welsch as follows:
(a.) Alternating weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m.;
(b.) During the summer months, the alternating weekend custody schedule shall
be suspended and mother shall be entitled to five (5) non-consecutive weeks
of partial custody periods with Andrea C. Welsch. Mother shall provide
notification of said desired five (5) weeks on or before April 15 of each year
to father;
2
(c.) Mother shall be entitled to have any missed partial custody periods with
Andrea rescheduled;
(d.) Mother shall be entitled to time with Andrea C. Welsch for mcals or similar
activities ifmother is in the Bedford area upon reasonable prior notice.
6. Mother and father will alternate having custody of Andrea the holidays as follows:
(a.) Christmas: The Christmas holiday shall be divided into segments, Segment
A. which shall run from December 23 at 4:30 p.m. until December 26 at
12:00 noon; and Segment B, which shall run from December 26 at 12:00
noon through December 29 at ] 2:00 noon. The father shall have custody of
the children during Segment A in odd numbercd years and during Segment B
in even numbered years. The mother shall have custody of the children
during Segment A in even numbered years and during Segment B in odd
numbered years.
(b.) Thanksgiving: The parties shall alternate the Thanksgiving holiday which
shall begin on Wednesday prior to Thanksgiving at 5:00 p.m. and shall
continue until Monday after the holiday at 5:00 p.m., provided that school is
not in session. Adjustments shall be made depending upon the school
schedule. Father shall have custody for Thanksgiving in even numbered
years and mother shall have custody for Thanksgiving in odd numbered years.
(c.) Easter: The parties shall alternate the Easter holiday which shall begin on
Wednesday prior to Easter at 5:00 p.m. and shall continue until Monday atter
the holiday at 5:00 p.m. provided that school is not in session. Adjustments
shall be made depending upon the school schedule. Father shall have custody
3
for Easter in the even numbered years and mother shall have custody for
Easter in odd numbered years.
(d.) Memorial Day/July 4/Labor Day: The parties shall alternate having custody
of the children on Memorial Day, July 4, and Labor Day. The Memorial Day
and Labor Day holidays shall run from Friday at 4:30 p.m. through Monday at
4:30 p.m. and the July 4 holiday shall fall within the extended weeks of
custody under the summer schedule. In even numbered years, the mother
shall have custody of the children on Memorial Day and Labor Day and father
shall have custody on July 4. In odd numbered years, the father shall have
custody of the children on Memorial Day and Labor Day and mother shall
have custody on July 4.
(e.) Mother's Day/Father's Day: Mother shall have custody of the children every
year on Mother's Day weekend from Friday at 5:30 p.m., when mother shall
pick Andrea up at father's home and father shall pick Andrea up at mother's
home on Sunday at 5:30 p.m. of the Mother's Day holiday. Father shall have
custody of the children every Father's Day weekend from Friday at 5:30 p.m.
through Sunday at 5:30 p.m., with the transportation for Father's Day to
continue as hereinafter set forth in this Order.
(f.) In-Service Days: Mother shall have the option to elect In-Service Days as an
additional long weekend custody period with Andrea C. Welsch. The custody
period shall begin at 5:30 p.m. on the first day of school prior to the period
and shall continue until 5:30 p.m. on the day prior to school reconvening.
Mother shall be limited to three (3) In-Service Days per school year, and shall
4
give notification of her desired three (3) In-Service Days to father at least two
weeks in advance.
(g.) The holiday custody scheduled shall supercede and take precedence over the
regular custody schedule.
7. Mother and father shall continue with parenting sessions utilizing the services of
Bonnie L. Howard, Ph.D., Clinical Psychologist. The parties shall participate in a
continued course of mediation with Dr. Howard or other mediator selected by
agreement of the parties. The purpose of the mediation shall be to improve
communications between the parties and to address conflicts which have arisen
with respect to parenting of the children.
8. Unless specifically set forth above, the parent relinquishing custody shall be
responsible for transportation to the other parent's home.
9. The non-custodial parent shall have reasonable and liberal telephone contact with
the children.
10. Both mother and father will encourage contact between Charlene E. Welsch and
Andrea C. Welsch.
II. For purposes of a change in primary custody of Andrea C. Welsch, mother shall
enjoy the weekend of December 20, 2002, with Andrea C. Welsch at her home,
5
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and father shall commence primary physical custody of Andrea C. Welsch as of
December 26, 2002, which is the commencement of his Christmas holiday period.
BY THE COURT:
Distribution:
Linda A. Clotfelter, Esquire, 3464 Trindle Road, Camp Hill, PA 17011 .l't"~ ~
Diane M. Dils, Esquire, 1017 North Front Street, Harrisburg, PA 17102 /..71.0-" 9-.
6
JEFFREY K. WELSCH,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
\'s.
No. ;/4-2389 Civil Term
KAREN R. WELSCH,
Dcfcndant
CIVIL ACTION - LA W
CUSTODY
STIPULATION AND AGREEMENT
OF THE PARTIES
AND NOW, this Ic'-f}.;day of December 2002, the parties, after conferring
with their counsel, Jeffrey K. Welsch, father, and his counsel, Diane M. Dils,
Esquire, and Karen R. Welsch, and her counsel, Linda A. Clotfelter, Esquire,
hereby agree and stipulate as to the custody of their children as follows:
I. The prior Order of this Court dated January 20, 2000, IS vacated and
replaced with this Order.
2. The father, Jeffrey K. Welsch, and the mother, Karen R. Welsch, shall have
shared legal custody of Charlene E. Welsch, born June 16, 1985, and
Andrea C. Welsch, born October 14, 1988. 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.
3. The mother shall have primary physical custody of Charlene E. Welsch IInd
the father shall primary physical custody of Andrea C. Welsch comlllencing
Deccmber 26,2002. The parties' oldest daughter, Michelle L. Welsch, has
rcached majority and therefore. is not a part of this Order of Court. (It is
noted that the mother, Karen R. Welsch, docs not believe that it is in the
bcst intcrest of Andrea C. Welsch to change her primary residence;
howcvcr, mother docs consent to this Order amI change of custody of
Andrca C. Welsch as evidenced by her signature to the Stipulation IInd
Agrecmcnt. )
4. Charlcne E. Welsch is currently 17 years of age and will soon be I X years
of agc and therefore, partial custody periods between Charlene E. Welsch
and father, Jeffrcy K. Welsch, shall be arranged by agreement IImong
Charlcnc and 1II0ther and father. Transportation shall be provided to
fathcr's home by mother during Charlene's custody periods and fhther shall
return Charlcnc to hcr mother's home upon thc conclusion of partial
custody periods.
5. Mothcr shall havc partial custody of Andrea C. Welsch liS lilllows:
(a.) Altcrnating weckcnds from Friday at 5:00 p.lII. until SundllY lit 5:00
p.m.;
(b.) During thc summcr lIIonths. the alternating weckend custody schedule
shall be suspended and mother shall be cntitled to five (5) non-
consccutive wceks of partial custody periods with Andrea C. Welsch.
,
-
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Mother shall provide notification of said desired five (5) weeks on or
before April 15 of each year to father;
(c.) Mother shall be entitled to have any missed partial custody periods with
Andrea rescheduled;
(d.) Mother shall be entitlcd to time with Andrea C. Welsch for mcals or
similar activitics if mothcr is in the Bedford area upon reasonable prior
notice.
6. Mother and father will alternate having custody of Andrea the holidays as
follows:
(a.) Christmas: The Christmas holiday shall be divided into segments,
Segment A, which shall run from Decembcr 23 at 4:30 p.m. until
December 26 at 12:00 noon; and Segmcnt B, which shall run from
December 26 at 12:00 noon through December 29 at 12:00 noon. The
father shall have custody of the children during Segment A in odd
numbered years and during Segment B in even numbered years. The
mother shall have custody of the children during Segment A in even
numbered years and during Segment B in odd numbered years.
(b.) Thanksgiving: The parties shall alternate the Thanksgiving holiday
which shall bcgin on Wcdnesday prior to Thanksgiving at 5:00 p.m.
and shall continue until Monday after the holiday at 5:00 p.m.,
provided that school is not in session. Adjustments shall be made
depending upon the school schedule. Fathcr shall have custody for
3
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Thanksgiving in cvcn numbcrcd ycars and mothcr shall havc custody
for Thanksgiving in mid numbcrcd ycars.
(c.) Eastcr: Thc partics shall altcrnatc thc Eastcr holiday which shull bcgin
on Wcdncsday prior to Eastcr at 5:00 p.m. and shall continll'~ until
Monday aftcr thc holiday at 5:00 p.m. providcd that school is not in
scssion. Adjustmcnts shall bc madc dcpcnding upon thc school
schcdulc. Fathcr shall havc custody till' Eastcr in thc cvcn numbcrcd
ycars and mothcr shall havc custody lill' I ~astcr in odd numbcrcd ycars.
(d.) Mcmorial Day/July 4/Labor Day: Thc partics shall altcrnatc having
custody of thc childrcn on Mcmoriall>ay, July 4. and Labor Day. Thc
Mcmorial Day and Labor Day holidays shall run from Friday at 4:30
p.m. through Monday at 4:.1() p.m. and thc .fuly 4 holiday shall fall
within thc cxtcndcd wccks of custody undcr thc summcr schcdulc. In
cvcn numbcrcd ycars. thc mothcr shall havc custody of thc childrcn on
Memorial Day and Labor Day and ththcr shall havc custody on July 4.
In odd numbcrcd ycars, thc tillhcr shall havc custody of thc childrcn on
Mcmorial Day and Labor l>ay and lI10thcr shall havc custody on July 4.
(e.) Mothcr's Day/Fathcr's Day: Mothcr shall havc custody of thc childrcn
evcry ycar on Mothcr's Day wcckcnd froll1 Friday at 5:]0 p.m., whcn
mothcr shall pick Andrca up at Iillhcr's homc and fathcr shall pick
Andrca up at mothcr's hOll1c on Sunday at 5:]0 p.m. of thc Mothcr's
Day holiday. Fathcr shall havc custody of thc childrcn cvcry Father's
Day wcckcnd thlll1 Friday at 5:.1() 1'.111. through Sunday at 5:30 p.m.,
4
.
,
with the transportation for Father's Day to continue as hereinafter set
forth in this Order.
(f.) In-Service Days: Mother shall have the option to elect In-Service Days
as an additional long weekend custody period with Andrea C. Welsh.
The custody period shall begin at 5:30 p.m. on the first day 0' school
prior to the period and shall continue until 5:30 p.m. on the day prior to
school reconvening. Mother shall be limited to three (3) In-Service
Days per school year, and shall give notification of her desired three (3)
In-Service Days to father at least two weeks in advance.
(g.) The holiday custody scheduled shall supercede and take precedence
over the regular custody schedule.
7. Mother and father shall continue with parenting sessions utilizing the
services of Bonnie L. Howard, Ph.D., Clinical Psychologist. The parties
shall participate in a continued course of mediation with Dr. Howard or
other mediator selected by agreement of the parties. The purpose of the
mediation shall be to improve communications between the parties and to
address conflicts which have arisen with respect to parenting of the
children.
8. Unless specifically set forth above, the parent relinquishing custody shall be
responsible for transportation to the other parent's home.
5
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9. The non-custodial parent shall have reasonable and liberal telephone contact
with the children.
10. Both mother and father will encourage contact between Charlene E. Welsch
and Andrea C. Welsch.
II. For purposes of a change in primary custody of Andrea C. Welsch, mother
shall enjoy the weekend of December 20, 2002, with Andrea C. Welsch at
her home, and father shall commence primary physical custody of Andrea
C. Welsch as of December 26, 2002, which is the commencement of his
Christmas holiday period.
IN WITNESS WHEREOF, the parties hereto sign their hands and seals the
day and year first above written.
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O.(enP,
K.afen R. Welsch
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ATTORNEYS AT LAW
1017 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102
ARTHUR K OILS
DIANE MOILS
PHONE (717)233.8743
FAX: (717) 233.2567
January 15, 2003
The Honorable J. Wesley Oler, Jr.
Cumberland County Courthouse
I Courthouse Square
Carlisle, P A 17013
RE: Jeffrey K. Welseh vs. Karen R. Welseh
No. 94-2389 Civil Term
Dear Judge Oler:
I represent Jeffrey K. Welsch; Karen R. Welsch is represented by Attorney Linda
A. Clotfelter. A custody trial had been scheduled before your Honorable Court for
Wednesday, November 27, 2002; however, the parties reached an Agreement
prior to that date.
Enclosed herewith are an original and three copies of a fully executed Stipulation
and Agreement with an Order of Court attached thereto.
It is respectfully requested that your Honorable Court approve the Order of Court.
Thank you for your assistance in this matter.
Very truly yours,
(tllt/v;~' I /.;;
I Diane M. Dit~../
,
DMD/daf
cc: Linda A. Clotfelter, Esquire
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JENNIFER BEAMAN INTRIERI.
Plaintiff
IN HIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LA W
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SCOlT NASTELLl,
Defendant
94-3357 CIVIL
IN RE: PREHEARING CONFERENCE
ORDER
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AND NOW, this
c.{ , day of December. 2002, at the request of counsel for the
defendant, a prchearing confcrencc in thc abovc captioned mattcr is sct for Friday. January 3,
2003, at 9:00 a.m. in Chambers ofthc undersigned.
UY THE COURT,
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I' Ruby D. Weeks. Esquire
For the Plaintiff L O"pJO 1))
/ Carol L. Cingranclli, Esquire )> -m 0.. ~ ~~
For the Delendant I . L ~ I f
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JEFFREY K, WELSCH,
Plaintiff
: IN THE COURT OF COMMON I)LEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
\IS.
: 94-2389 CIVIL ACTION - LAW
KAREN R. WELSCH,
Defendant
: IN CHILD CUSTODY
DEFENDANT'S MEMORANDUM FOR CUSTOI)Y HEARING
Submitted by: Linda A. Clotfelter. Counsel for Defendant.
I. Party is natural mother, Karen R. Welsch., hereinafter referred to as "Mother".
2.
Children:
Charlene E, Wclsch, born June 16, 1985 (age 17 years).
Andrea C. Wclsch, born October 14, 1988 (agc 14 years).
3. Plaintiff, Jefferey K. Welsch hereinaftcr rcferrcd to as "Father" pctitioned to Court seeking
primary physical custody of the parties' 14 year old daughter, Andrea. Mother opposes
Father's Petition for Modification and wishes to retain the status quo such that the parties'
two minor children continue to reside primarily with Mother and that the parties continue with
the custody Order that presently exists.
4. Defendant's Witnesses:
a. Karen R. Welsch - Will testifY as to the status quo, the nature of the household where
the children currently reside, the current school, social, and extracurricular activities
of the subject child, the prior complications and contempts when the parties' eldest
daughter moved to Father's residencc at the sanle age, the resulting difficulties for the
parties and the children, Fathcr's unilateral dceisions on custody on othcr occasions,
and in general the best interest of both minor children.
b. Charlene E. Welsch - Will tcstifY as the eflcct that a possible custody change would
have on her, the status quo, thc nature of the household where the children currently
reside, the prior complications and contcmpts when the parties' cldest daughter
moved to Father's residence at thc same age. the resulting difficulties for the parties
and the children, and in general the best interest of both minor children.
c. Barrv Hoffman - The nature ofthc houschold where the childrcn currently rcside, and
the interactions within the household.
d. Matthew Hoffman - The naturc of the household where the children currently reside,
and the intcractions within the houschold.
e. Michelle Welseh - (Possibly as on eross-examination) Will testify as to the nature of
both households including the lack of supcrvision at Father's home, her prior
experiences when Father obtained a similar modification for her custody, facts
surrounding noncompliancc with prior Order when shc rcsided primarily with Father,
her experienccs with Father and Stcpmother rcfusing hcr housing and financial
support whilc she was still a minor, and generally thc best intercst ofthc subject child.
f. Andrea C. Welsch - As on cross-exwnination. Will testify as to the status quo,
general facts ofthc current situation and her preferencc.
g. Jefferev K. Welsch - As on cross-exwninntion. Will testify as to the status quo, prior
events and complications in thc custody schcdule when a similar modification was
made with the parties' eldest daughter, Father's treatment of the eldest daughter's
pregnancy, Father's rcfusal to provide housing and finnncial support for the eldest
daughter due to her pregnancy and her resulting in her emancipation for the purposes
of custody.
h. Jan Welseh - As on cross-examination. Will testifY as to the status quo, prior event
between the parties, prior difficulties with the parties' eldest daughter, Father's refusal
to provide housing and finaneial support for the eldest daughter due to her pregnancy.
her emaneipation for the purposes of custody, and various communications with
Mother of their position throughout several disputes.
i. Others - Defendant reserves the right to question PlaintilT's witnesses and also
reserves the right to call additional witnesses upon proper notice as permitted.
Respectfully submitted,
LAW OFFICES OF CRAIG A. DIEHL
Date: I' lIt / OJ.-
I ,
nda A. Clotfe ter, Esquire
ttorney I.D. No. 72963
464 Trindle Road
Cwnp Hill. PA 17011
(717) 763-7613
Attorney for Defendant
.
JEFFREY K. WELSCH.
Plain lifT
: IN TilE COURT OF COMMON !>LEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
VI.
: 94-2389 CIVIL ACTION. LAW
KAREN R. WELSCH,
Defendant
: IN CHILD CUSTODY
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that on this date, a true and correct copy ofthe Defendant's
Memorandum for Custody Hearing was scrved upon the opposing party by way of ftrst class mail,
postage pre-paid and addressed as follows:
Jeffrey K. Welsch
149 Arandale Road
Bedford, PA 15522
(Plaintiff. Pro Se)
LAW OFFICES OF CRAIG A. DIEHL
Date: 111/5 / OJ-
/
mda A. Clotfelter, Esqutre
464 Trindle Road
nmp Hill, PA 17011
(717) 763-7613
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NOV 1 5 2002
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JEFFREY K. WELSCH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: 94-2389 CIVIL ACTION - LAW
KAREN R. WELSCH.
Defendant
: IN CHILD CUSTODY
DEFENDANT'S MEMORANDUM FOR CUSTODY HEARING
Submitted by: Linda A. Clotfelter, Counsel for Defendant.
I. Party is natural mother, Karcn R. Welsch.. hcreinaftcr referred to as "Mother".
2.
Children:
Charlene E, Welsch. born June 16, 1985 (age 17 years).
Andrea C. Welsch, born October 14, 1988 (age 14 years).
3. Plaintiff, Jefferey K. Welsch hereinafter referred to as "Father" pctitioned to Court seeking
primary physical custody of the parties' 14 year old daughtcr, Andrea. Mother opposes
Father's Petition for Modification and wishes to retain the status quo such that the parties'
two minor children continue to reside primarily with Mother and that the parties continue with
the custody Order that presently exists.
4. Defcndant's Witnesses:
a. Karen R. Welsch - Will testify as 10 the status quo, the naturc of the household where
the children currently residc, the current school, social, and extracurricular activities
of the subject child, the prior complications and contempts when the parties' eldcst
daughter movcd to Father's residcncc at the same age, the resulting difficulties for the
parties and the childrcn, Father's unilateral decisions on custody on othcr occasions,
and in general the best interest of both minor children.
b. Charlene E. Welsch - Will tcstify as thc effect that a possible custody change would
have on her, the status quo, the nature of the houschold where the children currently
rcsidc, the prior complications and contcmpts whcn the parties' eldest daughtcr
moved to Fathcr's rcsidence at thc same age. the resulting difficulties for the parties
and the childrcn. and in general the best interest of both minor children.
c. Barrv Hoffinan - Thc nature of the household wherc thc childrcn currcntly rcside, and
the interactions within the household.
d. Matthew Hoffinan - Thc nature of the household where thc children currcntly rcside.
and the intcractions within thc household.
.
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Law Offices of
CRAIG A. DIEHL
3464 TRINDLE ROAD
CAMP HILL. PA 17011
(717) 763.7813
119W. HANOVER STREET
SPRING GROVE. PA 173e2
(717) 225.1929
NOV 1 5 2011
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e. Michelle Welsch - (Possibly as on cross-examination) Will tcstify as to the nature of
both households including the lack of supervision at Father's home, her prior
experiences when Father obtained a similar modification for her custody, facts
surrounding noncompliance with prior Order when she resided primarily with Father,
her cxperiences with Father and Stepmother rcfusing her housing and financial
support while she was still a minor, and generally the best interest 0 fthe subject child.
f. Andrea C. Welsch - As on cross-examination. Will testify as to the status quo,
general facts ofthc current situation and her preference.
g. Jefferev K. Welsch - As on cross-exumination. Will tcstify as to the status quo, prior
events and complications in the custody schedule when a similar modification was
made with the purties' eldest daughter, Father's treatment of the eldest daughter's
pregnaney, Father's refusal to provide housing and finaneial support for the eldest
daughter due to her prcgnancy and her resulling in her emancipation for the purposes
of custody.
h. Jan Welsch - As on cross-exumination. Will testilY us to the status quo, prior event
between the purties. prior difficulties with the parties' eldest daughter, Father's refusal
to provide housing and fmancial support for the eldest daughter due to her pregnancy,
her emancipation for the purposes of custody, and various communications with
Mother of their position throughout several disputes.
i. Others - Defendant reserves the right to question Plaintiffs witnesses and also
reserves the right to call additional witnesses upon proper notice as permitted.
Respectfully submitted,
LAW OFFICES OF CRAIG A. DIEHL
Dute: II /11/ OJ-
I I
da A. Clotfe ter, Esquire
ttorney J.D. No. 72963
464 Trindle Road
Camp Hill, PA 1701 I
(717) 763-7613
Attorney for Defendant
JEFFREY K. WELSCH,
Plaintiff
: IN THE COURT OF COMMON I)LEAS OF
: CUMBERLANI) COUNTY, I)ENNSYLVANIA
V!.
: 94-2389 CIVIL ACTION - LAW
KAREN R. WELSCH,
I)cfcndant
: IN CHILI) CUSTOI)Y
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that on this date, a true and correct copy of the Defendant's
Memorandum for Custody Hearing was served upon the opposing party by way oflirst class mail,
postage pre-paid and addressed as follows:
Jeffrey K. Welsch
149 Amndale Road
Bedford. P A 15522
(Plaintiff, Pro Se)
LAW OFFICES OF CRAIG A. DIEHL
Date: 11/15 / ()J-
I
mda A. Clotfelter, EsqUire
464 Trindle Road
amp Hill. PA 17011
(717) 763-7613
,AI'4<......s,.
.' .
NOV 1 5 2002
JEFFREY K. WELSCII.
l'lalntlff
: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLANI) COUNTY,I)ENNSYLVANIA
VS.
: 94-2389 CIVIL ACTION. LAW
KAREN R. WELSCH,
Defendant
: IN CHILI) CUSTODY
DEFENDANT'S MEMORANI)lJM FOR ClJSTOI>Y HEARING
Submilled by: Linda A. Clotfelter. Counsel for Defendant.
1. Party is natural mother, Karcn R. Welsch., hereinaftcr referred to as "Mother".
2.
Childrcn:
Charlene E. Welsch, born June 16. 1985 (agc 17 years).
Andrea C. Welsch. born October ]4, 1988 (age 14 ycars).
3. Plaintiff, Jeffercy K. Welsch hercinafter referred to as "Father" pctitioned to Court sceking
primary physical custody of the parties' 14 year old daughtcr. Andrca. Mother opposes
Father's Petition for Modification and wishes to retain the status quo such that the parties'
two minor children continue to reside primarily with Mother and that the parties continue with
thc custody Ordcr that prescntly cxists.
4. Defcndant's Witnesses:
a. Karen R. Welsch - Will testifY as to the status quo, the nature ofthe household where
the ehildrcn currently reside. the current school. social, and extracurricular activities
of the subject child, the prior complications and contempts whcn the partics' eldest
daughter movcd to Father's residence at the same agc, thc resulting difficulties for the
parties and the children, Fathcr's unilateral decisions on custody on other occasions,
and in general the best interest of both minor children.
b. Charlene E. Welsch - Will testify as the cffect that a possible custody change would
have on her, the status quo, the nature of the household where the children currently
reside, the prior complications and contempts when the parties' eldest daughter
moved to Father's residence at the same age. the resulting difficulties for the parties
and the children, and in general the best intercst of both minor children.
c. Barrv Hoffinan - The nature of the household where the children currcntly reside. and
the interactions within the household.
d. Mallhew Hoffinan - The nature of the household where the children currcntly reside.
and the interactions within the household.
..
."
e. Michelle Welsch - (Possibly as on cross-cxamination) Will testilY as to the nature of
both households including the lack of supervision at Father's home, her prior
experiences when Father obtained a similar modification for her custody, facts
surrounding noncompliance with prior Order when she resided primarily with Father,
her experiences with Father and Stepmother refusing her housing and fmancial
support while she was still Ii minor, and generally the best interest of the subject child.
f. Andrea C. Welsch - As on cross-examination. Will testify as to the status quo,
general facts of the current situation and her preference.
g. Jefferev K. Welsch - As on cross-examination. Will testilY as to the status quo, prior
events and complications in the custody schedule when a similar modification was
made with the parties' eldest daughter, Father's treatment of the eldest daughter's
pregnancy, Father's refusal to provide housing and financial support for the eldest
daughter due to her pregnancy and her resulting in her emancipation for the purposes
of custody.
h. Jan Welsch - As on cross-examination. Will testilY as to the status quo, prior event
between the parties, prior difficulties with the parties' eldest daughter, Father's refusal
to provide housing and fmancial support for the eldest daughter due to her pregnancy,
her emancipation for the purposes of custody, and various communications with
Mother of their position throughout several disputes.
i. Others - Defendant reserves the right to queslion Plaintiff's witnesses and also
reserves the right to call additional witnesses upon proper notice as penni!ted.
Respectfully submitted,
LA W OFFICES OF CRAIG A. DIEHL
Date: II / 11/ OJ-
, ,
nda A. Clotfe ter. Esquire
!torney 1.0. No. 72963
464 Trindle Road
Camp Hill, PA 17011
(717) 763-7613
Attorney for Defendant
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JEFFREY K. WELSCH.
Plaintiff
: IN TIlE COURT OF COMMON I)LEAS OF
: CUMIJERLANI> COUNTY, I)ENNSYLVANIA
VS.
: 94.2389 CIVIL ACTION. LAW
KAREN R. WELSCH,
Defendant
: IN CHILD CUSTODY
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify thut on this date, a true and correct copy of the Defendant's
Memorandum for Custody Hearing wus scrved upon the opposing party by way of first class mail.
postage pre-paid and addressed as follows:
Jeffi'cy K. Welsch
149 Arandale Road
Bedford, PA 15522
(Plaintiff. Pro Se)
LAW OFFICES OF CRAIG A. DIEHL
Date: /11/5 / OJ-
I
mda A. Clotfelter, EsqUire
464 Trindle Road
amp Hill, PA 17011
(717) 763-7613
..
JEFFREY K. WELSCH,
Plaintiff
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 94-2389 Civil Ternl
KAREN R. WELSCH,
Defendant
CIVIL ACTION - LA W
CUSTODY
MEMORANDUM PURSUANT TO THE
ORDER OF COURT DATED SEPTEMBER 12.2002
AND NOW, this ~ay of November 2002, pursuant to the Order of
Court dated September 12, 2002, this Memorandum is filed on behalf of the
Plaintiff, Jeffrey K. Welsch, by his attomey, Diane M. Dils, Esquire:
I. Jeffrey K. Welsch, Plaintiff, believes that the best interest of his daughter,
Andrea C. Welsch, born October 14, 1988, will be served by granting him
primary physical custody, with partial custody in the Defendant, Karen R.
Welsch.
2. Jeffrey K. Welsch, Plaintiff, will testify as to why he believes that it is best
for his daughter, Andrea, to be in his primary custody. Jeffrey K. Welsch
will further testify as to the faet that there will be no interruption in the
education of Andrea Welsch in that the academic courses in which she
would commence in January 2003, are at least synonymous with the
academic courses she is currently carrying at the Middletown High School.
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3. Janice M. Welsch, is the wife of the Plaintifl~ and she will testify as to their
home, her relationship with Andrea Welsch, and her role as step-mother to
Andrea.
4. Michelle Welsch, the oldest daughter of Jeffrey K. and Karen R. Welsch,
will testify as to her relationship with her mother, Karen R. Welsch. her
reasoning for residing primarily with her father, Jeffrey K. Welsch, her
upbringing in the home of the father, Jeffrey K. Welsch, her current life, and
her relationship with both her father, mother, sisters, and step-mother.
5. Ruby Cooper, Andrea's Sunday school teacher and/or Tammy Beagle,
Youth Leader, both in association with the Bedford United Methodist
Church. One or both of these parties will testify as to their relationship with
Andrea Welsch in Bedford, Pennsylvania, and her involvement with the
Bedford United Methodist Church, the Sunday school and the Youth Group.
6. Bonnie L. Howard, Ph.D., Clinical Psychologist, of Riegler, Shienvold &
Associates, will testify as to her counseling with Andrea Welsch and as to
Andrea's thought process in concluding that she desires to reside with her
father on a full time basis. Dr. Howard will further testify as to any
anticipated problems if primary custody is granted to the father.
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7. Brian Nollan, the step-brother of Andrea Welsch (the son of Janice M.
Welsch - step-mother), will testify as to his relationship with Andrea and the
home of Jeffrey K. and Janice M. Welsch.
8. Lastly. it is requested that the minor child, Andrea Welsch, be permitted to
speak with your Honorable Court in chambers to explain her desires, how
and why she has made this decision.
Respectfully submitted,
/: . ~
BY: ~/~. I
/Diane M. Is, Esquire
1017 North Front Street
Harrisburg, P A 17102
(717) 232-9724
J.D. No. 71873
Attorney for Plaintiff,
Jeffrey K. Welsch
CERTIFICATE OF SERVICE
I, Diane M. Oils, Esquire, hereby certify that a true and correct copy of the
within Memorandum has been served upon the following individual by first class,
United States mail, postage prepaid, by depositing same at the post office in
Harrisburg, Pennsylvania, on the !It day of November 2002, addressed as
follows:
The Honorable J. Wesley Oler, Jr.
Cumberland County Courthouse
I Courthouse Square
Carlisle, P A 17013
Linda A. Clotfelter. Esquire
3464 Trindle Road
Camp Hill, PA 17011
Respectfully submitted,
BY:
Date: November 14, 2002
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