HomeMy WebLinkAbout02-3412
KRISTEN E, ST AMY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: NO. 2002- J 'II ~ CIVIL TERM
: CIVIL ACTION - LAW
: IN CUSTODY
JOEL D, RAMP,
Defendant
COMPLAINT FOR CUSTODY
I. Plaintiff is Kristen E. Stamy, an adult individual currently residing at 1152
Belvedere Street, Carlisle, Cumberland County, Pennsylvania 17013,
2. Defendant is Joel D, Ramp, an adult individual whose current residential address
is unknown, His current mailing address is 7800 Wertzville Road, Carlisle, Cumberland County,
Pennsylvania 17013,
3, The parties are the natural parents of the child, Peyton Ann Ramp, born August 9,
2000.
4, The child was born out of wedlock,
5. Since birth, the child has resided with the following persons at the following
addresses for the following lengths of time:
NAMF
Kristen E. Stamy
AnnRFSS
1152 Belvedere Street
Carlisle, P A
nATFS
May 30, 2002 to
present
Kristen E, Stamy
maternal grandparents
7710 Wertzville Road
Carlisle, P A
December 15, 2001 to
May 30, 2002
Kristen E, Stamy
Joel D, Ramp
2577 Spring Road
Carlisle, P A
November 1,2000 to
December 15, 2001
Kristen E. Stamy
maternal grandparents
7710 Wertzville Road
Carlisle, P A
August 9, 2000 to
November 1,2000
6,
single.
7,
single,
8.
The natural Mother of the child is the Plaintiff, who resides as foresaid, She is
The natural Father of the child is the Defendant, who resides as foresaid. He is
The relationship of the Defendant to the child is that of natural Father, It is
unknown where the Defendant currently resides,
9. The relationship of the Plaintiff to the child is that of natural Mother, The
Plaintiff currently resides with the child,
10. The Plaintiff has no information of a custody proceeding concerning the child
pending in any Court of this Commonwealth,
II. The best interest and permanent welfare of the child will be best served by granting
the relief requested as the Plaintiff is better suited to provide a stable environment to foster the
child's well being,
12, The Plaintiff does not know of any person not a party to the proceedings who
claims to have custody or visitation rights with respect to the child,
WHEREFORE, the Plaintiff, Kristen E. Stamy, respectfully requests this Honorable
Court to enter an Order scheduling the Parties for a Custody Conciliation.
Date:
JUL 162882
R~~
Th as S. Diehl, Esquire
Attorney for the Plaintiff
One West High Street, Suite 208
Post Office Box 1290
Carlisle, Pennsylvania 17013
(7 I 7) 240-0833
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa,C,S, S 4904, relating to
unsworn falsification to authorities,
(") 0
c: f',.)
it -"A. s:: '-
~ - -00')
~ Q;1 r1'1 c
z;J:j r-
C;
en....
~;,. CO
~ :.-C
'- :;; (, -..,
Z~ ,;.;;:
- >C)
<::::. ---<:::> c:
...- S4. ~ ""'"
"'" 10
~
C7
-,
<'
--
-
.
o
-n
.~
",.1
i'ii :lJ
,-
-nr"n
;0
(-:~ (~}
{5~~
orn
-",1
"""
:Q
.
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C,S, 9 4904, relating to
unsworn falsification to authorities,
.
I
\
/
I
I
,
i
J
. .
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KRISTEN E. STAMY
v,
02-3412 CIVIL ACTION LAW
JOEL D, RAMP
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Monday, July 22, 2002
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, August 20, 2002 at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Jacqueline M. VernlO" Esq'6
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATIORNEY 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 HELP,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
.~~Jr ~~~
.~~~ ~~
/rf) ~ :!l-~- ~ -r9
f'c? of "-
'('c? o[:L
~c/-02(
\i!N\'~'\l\SNI~3d
-, '~'-""1''''''''
U!.1,'p.,.;---. .("1 ';:.-~-'1-'1,'\! ;v
I I'J' 1,_,.,.' - ,-.' ,
;'I:C \:j or; 1m' 20
AUG 2 1 2002
G
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2002-3412 CIVIL TERM
KRISTEN E. ST AMY,
Plaintiff
JOELD.RAMP,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this 't"L.!dayof ..
consideration of the attached Custody Conciliation
follows:
, 2002, upon
eport, it is ordered arid directed as
1. The Mother, Kristen E. Stamy, arid the Father, Joel D. Ramp, shall have
shared legal custody of Peyton Ann Ramp, born August 9,2000. Each parent shall have
arI equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding her health, education arid religion.
2. Mother shall have primary physical custody of the child.
3. Father shall have periods of partial physical custody as follows:
A. Beginning August 23,2002 alternating Fridays at 4:00 p,m. to Saturday at
10:00 a.m.
B. Beginning September 13,2002 alternating weekends from Friday at 4:00
p.m. to Sunday at 4:00 p.m.
C. In the event that Father's weekend coincides with his Labor Day or
Memorial Day holiday, then Father shall have physical custody of the
child overnight on Sunday until such time as the parties agree on the
Monday holiday.
4, Mother shall have physical custody of the child on Mother's Day from
9:00 a.m. to 7:00 p.m. Father shall have physical custody of the child on Father's Day
from 9:00 a.m. to 7:00 p.m.
5. The Thanksgiving holiday shall be split such that Father shall always have
physical custody from 9:00 a.m. to 3:00 p.m. arid Mother shall always have physical
custody from 3 :00 p.m. to 9:00 p.m.
6, The Christmas holiday shall be divided into two Blocks. Block A shall be
from Christmas Eve at 12:00 noon to Christmas Day at 10:00 a.m. Block B shall be from
Christmas Day at 10:00 a.m. to December 26 at 10:00 a.m. Mother shall always have
V\NV^lASNN3d
MNn08 ONV1H3ti~ro
SZ :01 W~ tZ ~11~ GO
^b"V10NOi-tLGdd 3H1 30
381:lJQ--C31\:l
physical custody during Block A. Father shall always have physical custody during Block
B.
7. The Easter holiday shall be split and alternated by the parties from 9:00
a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p,m. Father shall have physical custody from
9:00 a,m. to 3:00 p.m. in odd numbered years and 3:00 p.m. to 9:00 p.m. in even
numbered years. Mother shall have 3 :00 p.m. to 9:00 p.m. in odd numbered years and
9:00 a.m. to 3:00 p.m. in even numbered years.
8. The following holidays shall be alternated by the parties: Labor Day,
Memorial Day, July 4th. Mother shall have physical custody of the child on Labor Day,
2002 and the holidays shall be alternated by the parties thereafter at times set by the
parties.
9. Transportation shall be shared as agreed by the parties,
10. In the event either party is in need of a babysitter for a period longer than
two (2) hours, the custodial parent shall notify the non-custodial parent and offer said
time to the non-custodial parent. Prior notification shall be reasonable to allow the non-
custodial parent to accept said offer.
11. Either party may request changes to the custodial arrangement two (2)
weeks in advance and the custodial parent shall not unreasonably refuse to accommodate
the requesting party provided makeup time is offered.
12. Both parties are entitled to fourteen (14) days vacation to be exercised
upon thirty (30) days advance notice, Said vacation requests shall not interfere with the
Thanksgiving or Christmas holiday schedule unless otherwise agreed by the parties.
13. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
cc:..fhomas S. Diehl, Esquire, Counsel for Mother
,/.f"udith F. Dolgos, Esquire, Counsel for Father
"7 l o-piw
<r: - ;(3-0~
AUG 2 1 2002
(,/
KRISTEN E. STAMY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 2002-3412 CIVIL TERM
JOEL D. RAMP,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: None
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Peyton Ann Ramp
August 9, 2000 Mother
2, A Conciliation Conference was held in this matter on August 20, 2002,
with the following individuals in attendance: The Mother, Kristen E. Stamy, with her
counsel, Thomas S. Diehl, Esquire and the Father, Joel D. Ramp, with his counsel, Judith
F. Dolgos, Esquire.
3. The parties agreed to the entry of an Order in the form as attached.
f -dO -0::2-
Date
~~,!~
Custody Conciliator
KRISTEN E, STAMY,
Plaintiff/Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V ANlA
v.
: CIVIL ACTION - LAW
JOEL D, RAMP,
Defendant/Petitioner
: NO, 2002-3412 CIVIL TERM
: IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
AND NOW, comes Petitioner, Joel D, Ramp, by and through his legal counsel of record,
Brian C, Bornman, Esquire, and the law firm of Griffie & Associates and petitions the Court as
follows:
1. Your Petitioner is the above-named Defendant, Joel D, Ramp, an adult individual
currently residing at 1812 Sterrits Gap Avenue, Carlisle, Cumberland County,
Pennsylvania,
2, Your Respondent is the above-named Plaintiff, Kristen E, Stamy, an adult individual
currently residing at 1152 Belvedere Street, Carlisle, Cumberland County,
Pennsylvania,
3, The parties are the natural parents of one Child, Peyton Ann Ramp, born August 9,
2000,
4. The parties are subject to an Order of Court which was entered following a custody
conciliation conference on August 22, 2002, A copy of this Order is attached hereto
and incorporated herein by reference as Exhibit "A."
5, Since the entry of the aforementioned Order, the parties have consistently modified
the arrangements for Petitioner's periods of partial physical custody of the Child such
that Father had overnight periods of custody three to four nights per week until late
October 2004, at which point Mother refused to permit Father any periods of custody
outside what is set forth in the Custody Order,
6, Since the entry of the Order in August 2002, the parties, through their conduct, have
established a modified custody arrangement whereby Father has substantially more
periods of custody than is set forth in the Order.
7, Petitioner would like to have the Order amended to represent what has been the
custody arrangements since the entry of the prior Order until late October when
Respondent unilaterally cut off the custody arrangements that were in effect.
8, Respondent has recently contacted Petitioner and advised him that she does not feel
like working any longer and wants him to pay substantial support and that this is the
reason for limiting his access to the Child,
9. Respondent took out all of the Child's money from the Child's account, which had
been put away for the Child, while on vacation in Mexico,
10, Petitioner believes that Respondent's sudden decision to refuse to work and apparent
lack of concern for the welfare of the Child is a result of a new relationship she
became involved in,
II, Petitioner believes that he is best suited to provide for the Child's physical, emotional,
and social well-being and that it would be in the Child's best interest to be placed in
his primary, physical custody,
12, It is in the best interest and permanent welfare of the Child to provide Father with
primary physical or residential custody of the Child and set forth periods of limited
partial physical custody with Mother.
WHEREFORE, Petitioner requests your Honorable Court to schedule a conciliation
conference at which time an order should be entered providing him with primary physical or
residential custody of the Child,
Respectfully submitted,
~ ..::<' I.:::' . ..;.~
. .
"/,/" _. .,;".c'.e<,"'" "'7..-... _"-
p,;?; .' A:~~~ "'_:7_--
Brian C. Bornman, Esquire
Attorney for Petitioner/Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, P A 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verifY that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa,C,S,
Section 4904, relating to unsworn falsifications to authorities.
DATE: jZl/m-
/7 ?" /J
~.? --
J~L D. RAMP.
"I " ','.!Jll,
,14. il: .
KRISTEN iii:. STAMY,
l'laintiff
: IN THE COllRT OJ? COMMON PLEAS 01'
: CUMBERLAND COUNTY, J'ENNS\'LVA~' L\
v,
: NO, 2002-3412 CIVIL TERl\-1
JOEL I), RAMP,
Defendant
: CI VIL ACTION - LA W
: IN CUSTODY
ORDER OF COURT
AND NOW, this ;:Xo.i1day of .v1~AAf)h ' ,2002, Up.Hl
(",,,"'dc""")" .,f'tl'" "l ""h,,(! C'I"to(ly COlle'I'I,'"t,'ollC'l)()"t :t:c 'Jl'("'>l.,od 'll"j rl"e<'l('cl, ",
.,~,J.hJl .,_u.~,,, H "'d. ..... a c~.,."l'" l~" . ~1 ~ ~" __'" - ,-,_ ~ ..' - .h_'_ -' -
folluws
I. Tile Muther, Kristen E, Stamy, and the Father, Jod D. Ramp, shall tw, e
slmrecllegal cllstody of Peyton Ann Ramp, born August 9, 2000, Each parent ,:hall h:1V',
Ct!l equal right, to be exercised jointly with the other parent, to make all l11(jOl' nOll-
emc:rg,ency declsions atTecting tbe Child's general well-being including, tut not hnit;d
tu, all decisions regarding her bealth, education and religion,
2, Mother shall have primary physical custody of the chi!d,
3. Father shall have periods ofpartiai pbysical custody [1:; follows
A, Beginning August 23, 2002 alternating Frid:1Ys at 4:0(' p,m, to :,atllrd.ty.. [
10:00 a.m.
B, Beginning September 13,2002 alternatlng weekends (rom Friday:11 4:0,
p,m. to Sunday at 4:00 p.m.
e, ln the event that Father's weekend coincides with his '"Clbor Oity or
Memorial Day holiday, then Father shall have physicd ellstod)' o( tnt'
child overnight on Sunday until such time as the parti",s agr<:e on 1h.:
Monday holiday.
I
4. Mother shall have physicai custody of the child on J\.1,)ther's Day fio] 11
1):00 am. to 7:()(J p.m. Father shall have physical custody of1he.child on Father',; DolY
I'rom 9:00 a.m. to 7:00 p.m.
S. The Thanksgiving holiday shall be split sllch that Fat'1cr "hall "h"~IY'; hJ 1'''
physical custllLiy li'o:n 9:00 a.m, to 3:00 p.m. and Mother shall alwa:,s have phy:;:.ca
CUS[oc'y'rom 3:0() p.m. to 9:00 p.m.
6. The Christmas hoiiday shall be divided into two Blocks. Blo,: k I\, ill 111 b"
fr()n~. Christmas Eve at 12:00 noon to Christmas Day at 10:00 a.m, Block B ,;lwll bl. fj"lI!
Christmas Day at 10:00 a.m, to December 26 . shall alway:: ha ie
EXHIBIT . ,,'
J A
phy,ical C\\s\Jely e1uring Block A. Fatber shall always have pbysical cusndy durillg nlo\ k
B.
7. The Easter holiday shall be split and alternated by the pan ies .'rorn 9:lill
a.m. to 3:0,) p.m. alld3:00 p.l11. to 9:00 p.m. Father shall have physical clIstedy li,)Jl.
9:00 a.m. tl) 3:00 p.m. in odd numbered years and 3:00 p.m. to 9:00 p.I11, in even
numbered 'leurs. Mother shall have 3:00 p.m. to 9:00 p.m. in odd numbered fear:> and
9:0(J a.m. to 3:00 p.m. in even numbered years.
H. Tl1e f(,llowing holidays shall be alternaled by the panics: l.abor D~./,
l\1emonallla~l, July 4lh Mother shall bave physical custody of the cbild I)n Labor D,y.
200:? and lYe holidays shall be alternated by the pmties thereafter at times set by th,;
panJcs.
9. Transportation shall be shared as agreed by the panies.
10. In the event either party is in need of a babysitter for a peri.ld longer thall
two (2) holL's, the custodial parent shall notify the non-custodial parent and olTer s,lid
time to the non-custodial parent. Prior notification shall be reasonable to ,1l10w the nOli,
cu:;todial pacent to accept said olTer.
] ]. Either pany may request changes to the custodial arrangenL'nt two en
weeks in advance and the custodial parent shall not unreasonably refuse to ace Jmmod.1\.;
the reC[ucstirg party provided makeup time is offered.
I
12. Both parties are entitled to fourteen (14) days vacation to be eXcJ'cis"J
upon thirty (:10) days advance notice. Said vacation requests shall not interfere wit:' the
Thanksgiving or Chri,tmas holiday schedule unless otherwise agreed by th;~ parties.
D. 'rhis Order is entered pursuant to an agreement of the panie:; at a Cu,tody
ConciliatiulI ::onference. The parties may modify the provisions of this Order)y mutual
consenl. In the absence of mutua] consent, the terms ofthi, Order shall control
/:5 .
t
/
~L~~.-,--~-
1'1.
cc: Thomas S. Diehl, Esquire, Co un,,,] for Mother
Judith F. Dolgos, Esqulre, Counsel for Father
KRISTEI'I E. STAMY,
Plaintiff
: IN THE COURT OF COMMON FLEAS OF
: CUMBERLAND COUNTY, PENNSYILV,\.NIIA
V.
: 2002-3-112 CIVIL TERM
JOEL D. RAMI',
Dcfcndant
: CIVIL ACTION - LA W
: IN CUSTODY
PRIOR J UJLlGE: Nonc
CUSTODY CONCILlA nON SUMMARY REPOl<T
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF OVIL
PHOCEDURE 1915,3-8, the undersigned Custody Conciliator submits the following
report:
I The pertinent information concerning the Child who is the subject of :his
litigation i;; as follows:
NAlvlE
DATE Of BIRTH
CURRE"lTL Y IN C USTOD Y OF
l'eYlOn An1 Ramp
August 9, 2000
Motber
2. A Conciliation Conference was held in this matler on August :20, 2:JW,
\vith the foJowing individuals in attendance: The Mother, Kristen E. Stmny, with ber
counsel, Thornas S. Diehl, Esquire and the Father, Joel D. Rm11p, with hi:; counsel, Judith
f. Dolgos, Esquire.
3. The parties agreed to the entry of an Order in tbe form as aUJcl1ecl.
f/ -J ..
----.::..~ () :..{:?...-
Date
, c.l.o,- 1/
y"<---"L_____L j II.. Vi.......-tL-.------.,
_.--~'.7---
acqlleline M. Verney, Esqu.re <:J
Custody Conciliator
. '''',
~.
~
~
~
~
\)
w
~
~
~
~.
~
~
\)
C')
'b
"-
~
""'>
c::::)
<..:.'-:l-
<:;J'I
'-
::;':".','
:.;;,'~
C)
~'1.1
.....
ffi :'1]
l~
;g[5
~~~"~ C^)
n.) --~
r,~:i3
?-"~, ~,'~~
;::'{
",;p
'J
.<
c..)
"'0
::J~
f--
C)
KRISTEN E. STAMY
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
02-3412 CIVIL ACTION LAW
JOEL D. RAMP
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Friday, February 04, 2005
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Ja"queliue M, Verney, Esq, ,the conciliator,
at 4th Floor, Cumberlaud Couuly Courthouse, Carlisle on Thursday, March 03, 2005 at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existin!: Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl1,
FOR THE COURT,
By: Isl
facqueline M. Vern!'L..~q, _ ,/11\
Custody Conciliator ... -~
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, pleas(~ contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
~.~ ~ ~~ 5~-11 e
~~ ~ ;;PiT?7"1,' ~7r7'{J 50,/7("
l'C-7
:-.J'I__
1_ ('\'11
,",_'~1
"_;.. ~:', I
ty
MAR (I ~ 20lJ5
~f
KRISTEN E. STAMY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: NO. 2002-3412 CIVIL TERM
JOEL D. RAMP,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this ~ day of v1J12' .. ~ ,2005, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
I, The prior Order of Court dated August 22, 2002 shall remain in full force
and effect with the following modifications and additions:
2. Paragraph 3 of the prior Order of Court shall be deleted in its entirety and
replaced with the following: Father shall have periods of partial physical custody as
follows:
A, Beginning March 14, 2005 and alternating thereafter, Monday at 11:30
a,m, to Tuesday at 5:00 p.m,
B. Beginning March 18, 2005 alternating weekends from Friday at 4:00 p,m.
to Monday morning when Father will transport the child to preschool.
C, Such other times as the parties agree,
3, The parties shall cooperate with a custody evaluation to be performed by
an evaluator agreed to by counsel. Father shall be responsible for paying the retainer.
Mother agrees to pay for the cost to have her current boyfriend included in the evaluation,
Father reserves the right to ask the court to apportion the remaining cost among the
parties,
4, 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. Either
party may contact the Conciliator and request another Conciliation Conference once the
Custody Evaluation is complete,
c:)
,"
(<-.1
t.L
C!
~--..~-~
BY THE COURT,
],
cc:~~ornman, Esquire, Counsel for Father
,/ilizabeth S, Beckley, Esquire, Counsel for Mother
V~
03-11-05
],
MAR 0 9 2005
~('
KRISTEN E. STAMY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 2002-3412 CIVIL TERM
JOEL D. RAMP,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: J. Wesley Oler, Jr., J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
I, The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Peyton Ann Ramp
August 9, 2000 Mother
2, A Conciliation Conference was held in this matter on March 8, 2005, with
the following individuals in attendance: The Mother, Kristen E. Stamy, with her counsel,
Elizabeth S, Beckley, Esquire and the Father, Joel D, Ramp, with his counsel, Brian
Bornman, Esquire,
3, The Honorable J, Wesley Oler, Jr. entered a prior Order of Court on
August 22, 2002 providing for shared legal custody, with Mother having primary
physical custody and Father having partial physical custody every weekend.
4. The parties agreed to the entry of an Order in the form as attached,
3% /tU- ill, tI ~
Date cq ine M, Verney, Esquire
Custody Conciliator