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Home My WebLink About02-3650AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dial despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de en abogado una comparecencia escrita y radicando en Is Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demands o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBELLEVARESTEDOCUMENTO A SU ABOGADOrvIlvIEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGUIENTE OFICINAPARA AVERIGUARDONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 GOLDMRC. KATM4AN & SHRAAN• p.C. paW J. Esposito, Eyq i Sopr Cant ID #25454 320Makst streak p.o. Box 1268 Nftnsbu%PA 17108-1268 AU-eysfmpWntiff JAMIE JO ROSE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER DWAYNE STINE, Defendant NO. 0 t;t' ?(oj o CIVIL ACTION - LAW CUSTODY/VISITATION Li V, I %G 1r n. COMPLAINT FOR CUSTODY I • Plaintiff is JAMIE JO ROSE, who currently resides at 6 White Oak Boulevard, Mechanicsburg, Silver Spring Township, Cumberland County, Pennsylvania 17050. 2. Defendant is CHRISTOPHER DWAYNE STINE, whose current residential address is 912 Nixon Drive, Mechanicsburg, Monroe Township, Cumberland County, Pennsylvania 17050. 3. Plaintiff is the Mother and Defendant is the Father of the children who are the subject of this action. 4. Plaintiff seeks primary physical and legal custody of. Name: Sarah Jessica Rose, DOB: January 11, 1997 Present Residence: 6 White Oak Boulevard, Mechanicsburg, Cumberland County, Pennsylvania Name: Jenna Rayanne Rose, DOB: January 11, 1997. Present Residence: 6 White Oak Boulevard, Mechanicsburg, Cumberland County, Pennsylvania Both children were born out of wedlock. 3. Both children resided with the Plaintiff herein, at 6 White Oak Boulevard, Mechanicsburg, Silver Spring Township, Cumberland County, Pennsylvania until July 28, 2002. Defendant has prevented Plaintiff from having or seeing the children since that time. Since their birth, the children have lived with the following persons and at the following addresses: Birth to June 20, 1998 Mother, Plaintiff, and Maternal Grandparents, James E. Rose, 11, and Gaylen Rose, Maternal Aunt Nicole Rose and 6 White Oak Boulevard, Mechanicsburg, Pennsylvania June 20, 1998, to July, 1999 Mother, Plaintiff, and Scott Conley, Plaintiff's former husband 124 West Portland Street, Apartment 18, Mechanicsburg, Pennsylvania July, 1999, to August, 2000, Mother, Plaintiff and Scott Conley, Plaintiffs former husband 512 Barry Court, Mechanicsburg, Pennsylvania August, 2000, to May 31, 2001 Mother, Plaintiff, and Scott Conley, Plaintiff's former husband Carlisle, Pennsylvania May 31, 2001, to August, 2001 Mother, Plaintiff , and Jessica Mansberger, a friend, and Ms. Mansberger,s children, Anthony Reno Avenue, New Cumberland, Pennsylvania and Jasmine 2 August, 2001, to June, 2002 Mother, Plaintiff , and Travis Clark, former boyfriend, and Mr. Clark's daughter, Emil and his parents, Larry and Sue Clark 1100 Hecks Drive, Dauphin, Y Coon, Pennsylvania June, 2002, to July 28, 2002 Mother, Plaintiff, and Matemal Grandparents, James E. Rose, 11, and Gaylen Rose 6 White Oak Boulevard, Mechanicsburg, Pennsylvania From July 28, 2002, to present Father, Defendant, and his fiance, Denise Wilson and Ms. Wilson's children, K.C. and Gabrielle Wilson 912 Nxon Drive, Mechanicsburg, Pennsylvania From late September/early October, 2001, until July 2g 2002, the parties had verbally agreed that Plaintiff would have primary physical have custody of the children and Defendant would temporary physical custody on alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. 8. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 9. The best interests and permanent welfare of the children will be served by the relief requested. 10. Plaintiff has not participated as a party, witness or in litigation concerning the custody of the children in this or another Court another capacity or in other 11. Defendant currently lives with his fiance, Denise Wilson, K.C. and Gabrielle Wilson. and her two daughters, 3 Rose. 12, Plaintifflives with the children and her parents, James E. Rose, U, and Gaylen VVHEREFOR)E, Plaintiff respectfully requests quests that the court grant prymy? physical and shared legal custody of the children to her. Respectfully submitted, GOLDBERG, KATZMAN & SHIP MAN P.C. By: Paul J s sito, Esquire 320 Market Street, Post Office Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Plaintiff 92745.1 VE C IverifY that the statements contained in the foregoing COWLAINTFOR CUSTODY MUAno are true and correct to the best of my knowledge, information and belief. I under stan d that false statements contained herein are made subject to the penalties of 18 Fa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: 30 0 J* ROSE // -?- 0 C7 I' „ 0 cD? o v o R CI- -I o(? ff Q JAMIE JO ROSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CHRISTOPHER DWAYNE : STINE, Defendant NO. 02-3650 CIVIL TERM ORDER OF COURT AND NOW, this 31" day of July, 2002, upon consideration of the within Emergency Petition for Special Relief, a Rule is hereby issued upon Respondent to show cause, if any he has, why the relief sought herein should not be granted. RULE RETURNABLE at a hearing scheduled for Monday, August 26, 2002, at 9:00 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. PENDING the hearing, Plaintiff shall have primary physical custody of the children, Sarah Jessica Rose and Jenna Rayanne Rose, and Defendant shall have temporary or partial physical custody of them on alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m., commencing on Friday, August 9, 2002. Paul J. Esposito, Esq. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for Plaintiff BY THE COURT, ,y?y 14 eO-!£= L r ? ? C lilA i U 1 :?'a ?.... 4 lilt Christopher Dwayne Stine 912 Nixon Drive Mechanicsburg, PA 17055 Defendant, Pro Se :rc JAMIE JO ROSE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 02-3650 CIVIL ACTION LAW CHRISTOPHER DWAYNE STINE DEFENDANT CUSTODY AND NOW, _ Tuesday, August 06, 2002 it is hereby directed that parties and their respective counsel appear before fore upon consideration of the attached Complaint, r e Melissa P. Greevy, Esq the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, September 09, 2002 at 12:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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: ls/ Me 1i ug P, r 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. must be made at least 72 hours prior to any hearing scheduled conference or hearing or business before the court. You must attend the . YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 All arrangements ? z lfp ow A ?v l°a$$ 7, -A? f72 ?''NbnusNN?d AJ.Nn Ano JAMIE JO ROSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CHRISTOPHER DWAYNE STINE, Defendant NO. 02-3650 CIVIL TERM PLAINTIFF'S EMERGENCY PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 13'' day of August, 2002, upon consideration of the attached letter from Paul J. Esposito, Esq., attorney for Plaintiff, the hearing previously scheduled for August 26, 2002, is CONTINUED GENERALLY. COUNSEL are requested to contact the court if they desire a hearing in this matter. BY THE COURT, G ? J. esley Oler, J. ,Paul J. Esposito, Esq. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for Plaintiff J g _Q a RKS iGregory Hazlett, Esq.. 22 S. Market Street Mechanicsburg, PA 17055 Attorney for Defendant 1, t! rti V,IO.".SNN:ld 4?? 320 MARKET STREET • STRAWBERRY SQUARE P.O. BOX 1268 • HARRISBURG, PENNSYLVANIA 17108-1268 717.234.4161 0 717.234.6808 (FAX) GOLDBERG, KATZMAN & SHIPMAN, P.C. ATTORNEYS AT LAW August 121 2002 OF COUNSEL F LEE SHIPMAN COUNSEL JOSHUA D. LOCK The Honorable J. Wesley Oler ARNOLD B. KOGAN Judge Cumberland County Courthouse ARTHUR L. GOLDBERG One Courthouse Square (1951-2000) Carlisle, PA 17013-3387 HARRY B. GOLDBERG (1961-1998) Re: Rose v. Stine Cumberland County Docket No. 02-365 RONALD M. KATZMAN CustodyNisitation PAUL J. ESPOSITO NEIL HENDERSHOT Dear Judge Oler: J. JAY COOPER THOMAS E. BRENNER A hearing in the above-referenced matter is scheduled for Monday August 26 2002 9 JOHN A. STATLER APRIL L. STRANG-KUTAY , , , at :00 a.m. Pursuant to the Emergency Petition for Special Relief, which was filed in behalf of my client, Jamie Jo Rose. GUY H. BROOKS JEFFERSON J. SHIPMAN As a result of discussions between counsel, we have agreed that th h i JERRY J. RUSSO e ear ng scheduled for August 26 should be continued pending the parties' a MICHAEL J. CROCENZI ppearance at a custody conciliation conference. We would ask that the hearing be co ti d THOMAS J. WEBER n nue generally. The parties are adhering to the Order your Honor issued in this matte STEVEN E. GRUBB r. JOHN DELORENZO JOHN R If the parties are unable to resolve their differences at the conciliation confere i . NINOSKY nce, t may be necessary to have the hearing. However we want to a il ROYCE L. MORRIS D , va ourselves of the opportunity to resolve this matter fully and finally or at least in th i t i AVID M. STECKEL e n er m without resort to the court for a hearing on the Plaintiff s Petition HEATHER L. PATERNO . As I indicated, Attorney Hazlett and I have discussed this matter and it i s our mutual request that the hearing be continued. CARLISLE OFFICE: 717.245.0597 • YORK OFFICE: 717.843.7912 ft 13 M02 The Honorable J. Wesley Oler Page 2 August 12, 2002 Thank you for your kind consideration in this matter. Yours very PJE/rkr cc: Greg Hazlett, Esquire 83317.1 GOLDBERG. KATZMAN & SHRUAN P.C. PaW 7. Esposito, Esquire Supreme Covet ID #25454 370 Mnket Sueey P.O. Box 1268 HwnsW%PA 17108-1268 Auomeys for Pl=tfff JAMIE JO ROSE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER DWAYNE STINE, Defendant NO. 02-3650 CIVIL ACTION - LAW CUSTODYNISITATION 1REE N OF ?E VI F COMMONWEATH OF PENNSYVANIA : COUNTY OF Dauphin • S.S.. On the 31st day of Ju 1 y , 2002, I, Robert A. Dash, served Christopher D. Stine with a Complaint for Custody and Emergency Petition for Special Relief by personally handing same to him at his place of employment at the following location: 109 Millers Lane, Harrisburg, PA 17110. I verify that the statements in this return of service 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 authorities. Date: August 8, 2002 Robert A. Dash Goldberg, Katzman & Shi 320 Market Street Shipman, P.C. P O Box 1268 Harrisburg, PA 17108-1268 Re: Jamie Jo Rose v. Christopher D. Stine Cumberland County 02-3650 Dear Mr. Esposito: This is to certify that at 4:20 PM on July 31, 2002, I personally served legal documents that pertained to the Subject action to Christopher D. Stine at is place of employment, 109 Millers Lane, Harrisburg, pA 17110. Sincerely, Robert A. Dash 3861 SARAYO CIRCLE • HARRISBURG, PA 17110 • 717.652.6628 • FAX 717.652.6628 r I r JAMIE JO ROSE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 02-3650 CIVIL ACTION LAW CHRISTOPHER DWAYNE STINE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday August 28, 2002 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, PA 17055 the conciliator, on Thursday, September 19, 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: /s/ Dawn C Ci aav aq m?" Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 by -,;:, /yam! 1-4v Z'O SC $ "I :11 "IN emly 20 A YGh_; ? u? menssa Greevy has a conflict and can't do this conciliation. Plaintiffs Counsel = Paul Esposito a Defendant's Counsel= Greg Hazlett JAMIE JO ROSE, Plaintiff VS. CHRISTOPHER DWAYNE STINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-3650 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this Sot day of S _e__4 L cl 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated July 31, 2002, is vacated and replaced with this Order. 2. The Mother, Jamie Jo Rose, and the Father, Christopher Dwayne Stine, shall have shared legal custody of Sarah Jessica Rose, born January 11, 1997, and Jenna Rayanne Rose, also born January 11, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 3. The Mother shall have primary physical custody of the Children. 4. The Father shall have partial physical custody of the Children on alternating weekends from Friday at 6:00 p.m. through Sunday at 6:00 p.m., beginning Friday, September 20, 2002. In addition, the Father shall have custody of the Children every week from Wednesday at 5:30 p.m. through the following Thursday morning before school. 5. The parties shall share or alternate having custody of the Children on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 1:00 p.m. through Christmas Day at 1:00 p.m., and Segment B, which shall run from Christmas Day at 1:00 p.m. through December 26 at 6:00 p.m. In even numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. In odd numbered jaN6 orvNVINWWd ) 't' l,f H - V no 83S ZP "]rl 1 years, the Mother shall have custody of the Children during Segment A and the Father shall have custody during Segment B. B. NEW YEARS: The New Years holiday shall be divided into Segment A, which shall run from New Years Eve at 1:00 p.m. through New Years Day at 1:00 p.m., and Segment B, which shall run from 1:00 p.m. until 6:00 p.m. on New Years Day. For purposes of this provision, the entire New Years holiday shall be deemed to fall in the same year as New Years Eve. In even numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. In odd numbered years, the Mother shall have custody of the Children during Segment A and the Father shall have custody during Segment B. C. THANKSGIVING: The Thanksgiving holiday shall run from the Wednesday before Thanksgiving at 6:00 p.m. through the Sunday following Thanksgiving at 6:00 p.m. The Mother shall have custody of the Children for the Thanksgiving holiday in even numbered years and the Father shall have custody in odd numbered years. D. EASTER: The Easter holiday shall be divided into Segment A, which shall run from the Saturday before Easter at 1:00 p.m. through Easter Sunday at 1:00 p.m., and Segment B, which shall run from 1:00 p.m. until 6:00 p.m. on Easter Sunday. In even numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. In odd numbered years, the Mother shall have custody of the Children during Segment A and the Father shall have custody during Segment B. E. MEMORIAL DAULABOR DAY: The Memorial Day and Labor Day periods of holiday custody shall run from the Friday before the holiday at 6:00 p.m. through the day of the holiday at 6:00 p.m. In even numbered years, the Mother shall have custody of the Children over Memorial Day and the Father shall have custody over Labor Day. In odd numbered years, the Father shall have custody of the Children over Memorial Day and the Mother shall have custody over Labor Day. F. INDEPENDENCE DAY: The Independence Day holiday shall run from July 3rd at 6:00 p.m. through July 4 at 6:00 p.m. The Mother shall have custody of the Children in even numbered years and the Father shall have custody in odd numbered years. G. MOTHER'S DAUFATHER'S DAY: The Mother shall have custody of the Children every year on Mother's Day from 9:00 a.m. until 6:00 p.m. and the Father shall have custody of the Children every year on Father's Day from 9:00 a.m. until 6:00 p.m. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 6. Each party shall be entitled to have custody of the Children for 2 non-consecutive weeks each summer for vacation upon providing at least 30 days advance notice to the other party. The party providing notice first under this provision shall be entitled to preference of his or her selection of vacation dates. The parties shall schedule their periods of custody under this provision to include their regular weekend periods of custody. 7. In the event either party takes the Children out of town for an overnight period or longer, that party shall provide advance notice to the other party of the address and telephone number where the Children can be contacted. 8. The non-custodial parent shall be entitled to have reasonable telephone contact with the Children not to exceed 1 time per day unless an additional contact is necessary due to an emergency. 9. The party receiving custody shall be responsible to provide transportation for the exchange of custody unless otherwise agreed between the parties. 10. Neither party shall smoke around the Children during his or her periods of custody. Both parties shall ensure that third parties having contact with the Children comply with this provision. 11. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 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 COURT, J. esley Oler, r„ J. cc: Paul J. Esposito, Esquire - Counsel for Mother ,? • 30 • a -L Gregory Hazlett, Esquire - Counsel for Father A10-L" JAMIE JO ROSE, Plaintiff VS. CHRISTOPHER DWAYNE STINE, Defendant PRIOR JUDGE: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-3650 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Sarah Jessica Rose January 11, 1997 Mother Jenna Rayanne Rose January 11, 1997 Mother 2. A Conciliation Conference was held on September 19, 2002, with the following individuals in attendance: The Mother, Jamie Jo Rose, with her counsel, Paul J. Esposito, Esquire, and the Father, Christopher Dwayne Stine, with his counsel, Gregory Hazlett, Esquire. 3. The parties agreed to entry of an Order in the form as attached, with the exception of the mid-week periods of custody for the Father, which is the recommendation of the Conciliator. The Mother proposed that the Father have custody on Wednesdays from 5:30 p.m. until 8:00 p.m. but objected to the overnight period. The Conciliator's recommendation is based upon representations made by the parties at the Conference, including the Father's desire for more time with the Children, the developing relationship between the Children and the Father, the necessity of developing trust between the parties and the fact that the Mother is able to spend every afternoon with the Children after morning kindergarten. Date Dawn S. Sunday, Esquire Custody Conciliator JAIME JO ? OSE, vs. Plaintiff CHRISTOPI?ER DWAYNE STINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3650 CIVIL TERM IN CUSTODY PETITION TO MODIFY_ AND OW come the above-named Defendant, by his attorney, Samuel L. Andes, and petitions the court to modify the custody order of 30 September 2002, based upon the following 1. The Petitioner herein is the Defendant, Christopher Dwayne Stine, who resides at 912 Nixon Drive in Mechanicsburg, Cumberland County, Pennsylvania. 2. Th Respondent herein is the Plaintiff, Jaime Jo Rose, who resides at 6 Whiteoak Bo levard in Mechanicsburg, Cumberland County, Pennsylvania 3. The parties are the parents of two twin daughters, Sarah J. Rose and Jenna R. Rose, both born 11 January 1997. 4. Th? last order in this case was entered on 30 September 2002 and a copy of it is attached horeto and marked as Exhibit A. 5. Def'ndant seeks to modify the above order for the following reasons: The said order was not intended to be a permanent order, but as a bridge to expanding his time with the children and moving toward some type of shard physical custody of the children; and . Although he enjoys a good relationship with his daughters, he would I ke to expand upon that and be more active as their father and parent; and . He is able to provide for the emotional and personal needs of the girls an wants to do so on a regular and frequent basis; and He is able, and prepared, to be more involved with the children than is he Plaintiff and wishes to be granted more time so he can do so. 6. Defendant believes it is in the best interest of the minor children for the last order to be odified to increase his periods of custody with him. WHE EFORE, Defendant prays this court to modify its order of 30 September 2002 to grant him !shared physical custody of the children and equal time with the Plaintiff. Samue L. Andes Attorney for Defendant Supreme Court I.D. #17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 VERIFICATION veriO that the statements made in this Petition are true and correct. I understand that any false statements in this Petition are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: 03 CHRISTOPHER D. STINE iFP 2 5 2n JAMIE JO ROS, P aintiff v?. CHRISTOPHE DWAYNE STINE, DOfendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-3650 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT D NOW, this 3v `- day of upon consideratio of the attached Custody Conciliation RepoPit' 2002, , is ordered and directed as follows: 1. The prig Order of this Court dated July 31, 2002, is vacated and replaced with this Order. 2. The Mother, Jamie Jo Rose, and the Father, Christopher Dwayne Stine, shall have shared legal custody of Sarah Jessica Rose, born January 11, 1997, and Jenna Rayanne Rose, also born January 11, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major on-emergency decisions affecting the Children's general well-being including, but not limited to, all ecisions regarding their health, education and religion. Pursuant to the terms of this paragraph each p ent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 3. The Mo?her shall have primary physical custody of the Children. 4. The Father shall have partial physical custody of the Children on alternating weekends from Friday at 6:00 p.m through Sunday at 6:00 p.m., beginning Friday', September 20, 2002. In addition, the Father shall have custody of the Children every week from Wednesday at 5:30 p.m. through the following Thursday morning before school. 5. The parties shall share or alternate having custody of the Children on holidays as follows: A. HRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 1:00 p.m. through Christmas Day at 1:00 p.m., and Se ent B, which shall run from Christmas Day at 1:00 p.m. through December 26 at 6:00 .m. In even numbered years, the Father shall have custody of the Children during Segrr ent A and the Mother shall have custody during Segment B. In odd numbered , the Mother shall have custody of the Children during Segment A and the Father have custody during Segment B. B? NEW YEARS: The New Years holiday shall be divided into Segment A, which shall run from New Years Eve at 1:00 P.M. through New Years Day at 1:00 p.m., and Segment B, which shall run from 1:00 p.m. until 6:00 p.m. on New Years Day. For p rposes of this provision, the entire New Years holiday shall be deemed to fall in the same year as New Years Eve. In even numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. In ?nd dd numbered years, the Mother shall have custody of the Children during Segment A the Father shall have custody during Segment B. C. THANKSGIVING: The Thanksgiving holiday shall run from the Wednesday be ore Thanksgiving at 6:00 p.m. through the Sunday following Thanksgiving at 6:00 p.m. The Mother shall have custody of the Children for the Thanksgiving holiday in ev n numbered years and the Father shall have custody in odd numbered years. D. EASTER: The Easter holiday shall be divided into Segment A, which shall run fro the Saturday before Easter at 1:00 p.m. through Easter Sunday at 1:00 p.m., and Segment B. which shall run from 1:00 p.m. until 6:00 p.m. on Easter Sunday. In even numbered years, the Father shall have custody of the Children during Segment A and the other shall have custody during Segment B. In odd numbered years, the Mother shall have custody of the Children during Segment A and the Father shall have custody during Segment B. E. EMORIAL DAY/L LBOR DAY: The Memorial Day and Labor Day periods of holiday custody shall run from the Friday before the holiday at 6:00 p.m. through the day f the holiday at 6:00 p.m. In even numbered years, the Mother shall have custody oft the Children over Memorial Day and the Father shall have custody over Labor Day. In o d numbered years, the Father shall have custody of the Children over Memorial Day land the Mother shall have custody over Labor Day. R I EPENDENCE DAY: The Independence Davy holiday shall run from July 3rd at 6:00 p.m. through July 4`' at 6:00.p.m. The Mother shall have custody of the Children in even numbered years and the Father shall have custody in odd numbered years. G. OTHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Children every year on Mother's Day from 9:00 a.m. until 6:00 p.m. and the Father shall have custody of the Children every year on Father's Day from 9:00 a.m. until 6:00 p.m. H. T e holiday custody schedule shall supersede and take precedence over the regular custo y schedule. 6. Each partshall be entitled to have custody of the Children for 2 non-consecutive weeks each summer for vac tion upon providing at least 30 days advance notice to the other party. The party providing notice first under this provision shall be entitled to preference of his or her selection of vacation dates. The parties shall schedule their periods of custody under this provision to include their regular weekendperiods of custody. 7. In thel event either party takes the Children out of town for an overnight period or longer, that party shall p?ovide advance notice to the other party of the address and telephone number where the Children can a contacted. 8. The on-custodial parent shall be entitled to have reasonable telephone contact with the Children not to a ceed 1 time per day unless an additional contact is necessary due to an emergency. 9. The p rty receiving custody shall be responsible to provide transportation for the exchange of custody unless otherwise agreed between the parties. 10. Neith?r party shall smoke around the Children during his or her periods of custody. Both parties shall ensu Ie that third parties having contact with the Children comply with this provision. 11. Neith r party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development oft the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 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, th terms of this Order shall control. BY THE COURT, esXey Oler, fir., J cc: Paul J. Esposit ' , Esquire - Counsel for Mother Gregory Hazlet, Esquire - Counsel for Father In T&VIYt041y wlrFz t C ORD I .f .?"? `k `?. E c l Yw :g€jF viand at c . Isis 'go pp ?...?s.YV1Y.iMY ,U?9q 0 Prctthonotar ? _r JAIME JO ROSE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER DWAYNE STINE DEFENDANT • 02-3650 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, February 06, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, March 12, 2003 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 permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sundury, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH. BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 1701.3 Telephone (717) 249-3166 JAMIE JO ROSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 02-3650 CIVIL ACTION LAW CHRISTOPHER DWAYNE STINE, Defendant IN CUSTODY ORDER OF COURT AND NOW, this _ZS& day of 4 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall submit themselves, the Children, and any other individuals deemed necessary by the evaluator, to a custody evaluation to be performed by Arnold Shienvold, Ph D. or other professional selected by agreement of the parties. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best serve the needs and interests of the Children. The parties shall sign all authorizations deemed necessary by the evaluator in order to obtain additional information pertaining to the parties or the Children. The Father shall be responsible to pay 70% and the Mother shall be responsible to pay 30 % of all costs of the evaluation. 2. Pending further Order of Court, or agreement of the parties, the prior Order of this court, dated September 30, 2002 shall continue in effect. 3. Pending further Order of Court or agreement of the parties, the Children shall continue to attend kindergarten in the elementary school in which they are currently enrolled. 4. In the event the parties are not able to resolve all custody issues following completion of the custody evaluation, counsel for either party make contact the conciliator within sixty days of receipt of the evaluator's written recommendations to schedule an additional custody conciliation conference. cc: Paul J. Esposito, Esquire - Counsel for Mother Samuel L. Andes, Esquire - Counsel for Father y- 0-3 BY THE COURT, „-s r n r JAMIE JO ROSE, Plaintiff VS. CHRISTOPHER DWAYNE STINE, Defendant PRIOR JUDGE: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-3650 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Sarah Jessica Rose January 11, 1997 Mother Jenna Rayanne Rose January 11, 1997 Mother 2. A Conciliation Conference was held on March 12, 2003, with the following individuals in attendance: The Mother, Jamie Jo Rose, with her counsel, Paul J. Esposito, Esquire, and the Father, Christopher Dwayne Stine, with his counsel, Samuel L. Andes, Esquire. 3. The parties agreed to entry of an Order in the form as attached providing for a custody evaluation. However, it should be noted that the parties were not able to resolve an issue concerning school enrollment for the Children. The Children currently attend kindergarten at the Silver Spring Elementary School in the Cumberland Valley School District, and have done so since the beginning of the school year. The Mother has remarried and moved with the Children to Newberrytown. The Father continues to reside in the Cumberland Valley School District, although not in the section in which the elementary school is located. The parties disagree as to whether the Children should be moved to an elementary school in Newberrytown or finish the school year at Silver Spring. As there is not sufficient time for the custody evaluator to address the issue, it was agreed at the conference that counsel for the parties would contact the Court to request the scheduling of a brief argument or telephone conference to obtain guidance from Court on this one discrete issue. N----c l_ ) 9, 3-00 3 Date Dawn S. Sunday, EsqeL, uir Custody Conciliator JAIME JO ROSE, vs. Plaintiff CHRISTOPHER DWAYNE STINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3650 CIVIL IN CUSTODY MOTION FOR HEARING AND NOW comes the above-named Defendant, by his attorney, Samuel L. and moves the court to schedule a hearing in the above matter, based upon the f 1. The Petitioner herein is the Defendant, Christopher Dwayne Stine, who res at 912 Nixon Drive in Mechanicsburg, Cumberland County, Pennsylvania. 2. The Respondent herein is the Plaintiff, Jaime Jo Rose, who resides at 6 Whiteoak Boulevard in Mechanicsburg, Cumberland County, Pennsylvania 3. Presently before this Court is the Defendant's Petition to Modify a prior order. 4. By an order of this court dated 25 March 2003, entered pursuant to an agreement reached by the parties at a conciliation conference, this court directed the parties to obtain a custody evaluation to be performed by Arnold Shienvold, Ph.D. 5. The parties have completed the evaluation process. Although they have not received a written report from Dr. Shienvold as yet, he has made his report and recommendation orally to both parties through their attorneys. 6. The parties have not been able to resolve the differences which exist betwee them with regard to the custody order, specifically the Defendant's request for additior time with the children. 7. The matter must be resolved and, unfortunately, the parties will not be able resolve it without the intervention of the court. WHEREFORE, Defendant moves this court to schedule a hearing to resolve his Petition for Modification of the custody order and to take such other action as the co deems appropriate following such hearing. Sa el L. Andes Attorney for Defendant Supreme Court II.D. #17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 VERIFICATION I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of Pa. C.S. 4904 (unsworn falsification to authorities). Date: 0:36ADa 8 L. CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon counsel the Defendants herein by regular mail, postage prepaid, addressed as follows: Paul J. Esposito, Esquire P.O. Box 1268 Harrisburg, PA 17108-1268 Date: 20 October 2003 _ Amy M. r4 ' s Secretary for Samuel L. Andes JAIME JO ROSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CHRISTOPHER DWAYNE STINE, : 02-3650 CIVIL TERM Defendant IN CUSTODY ORDER OF COURT AND NOW, this 5th day of February, 2004, upon consideration of Defendant's Petition for Modification of Custody with respect to the children of the parties, Sara Jessica Rose (date of birth January 11, 1997), and Jenna Rayanne Rose (date of birth January 11, 1997), and pursuant to an agreement reached in open court among the parties and their respective counsel, Paul J. Esposito, Esquire, on behalf of the Plaintiff, and Samuel L. Andes, Esquire, on behalf of the Defendant, it is ordered and directed as follows: 1. All prior orders of this Court in this action are vacated and replaced with this Order. 2. The parties, mother, Jamie Jo Rose-Clark, and the father, Christopher Dwayne Stine, shall share legal custody of the two children who are the subject of this order. 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. Each parent shall be entitled to all records and information pertaining to the children, including, but not limited to, school and medical records and information. 3. During the school year mother shall have primary O 1 ? G D ., i 6S o i 033 hUZ physical custody of the children, and father shall have temporary custody on alternating weekends from 6:00 p.m. on Friday until 6:00 p.m. on Sunday. The father's alternating weekends shall commence on Friday, February 6, 2004. 5. During the children's summer vacation from school, the parents shall share shall start with father commencing at 8:00 p.m. last day of school and Thereafter, the parties before the first day of school schedule set out custody on an alternating week basis, which having the children for the first week on the first Sunday after the children's =_nding at 8:00 p.m. one week later. shall alternate weeks until the Sunday school in the fall, at which time the in paragraph 3 shall resume. 6. The parties shall share or alternate custody of the children on holidays as follows: A. CHRISTMAS: The Christmas holidays shall be divided into Segment A, which shall run from Christmas Eve at 1:00 p.m. through Christmas Day at 1:00 p.m.; and Segment B, which shall run from Christmas Day at 1:00 p.m. through December 26 at 6:00 p.m. In even numbered years, the father shall have custody of the children during Segment A and mother shall have custody during Segment B. In odd numbered years, mother shall have custody during Segment A and father shall have custody during Segment B. B. NEW YEARS: The New Years holiday shall be divided into Segment A, which shall run from New Years Eve at 1:00 p.m. through New Years Day at 1:00 p.m., and Segment B, which shall run from 1:00 p.m. until 6:00 p.m. on New Years Day. For purposes of this subparagraph, the entire New Years holiday shall be deemed to fall in the same year as New Years Eve. In even numbered years, the father shall have custody of the children for Segment A and mother shall have custody for Segment B. In odd numbered years, mother shall have custody for Segment A, and father shall have custody for Segment B. C. THANKSGIVING: The Thanksgiving holiday shall run from the Wednesday before Thanksgiving at 6:00 p.m. through the Sunday following Thanksgiving at 6:00 p.m. The mother shall have custody of the children for the Thanksgiving holiday in even numbered years and father shall have custody in odd numbered years. D. EASTER: The Easter holiday shall be divided into Segment A, which shall run from the Saturday before Easter at 1:00 p.m. through Easter Sunday at 1:00 p.m.; and Segment B, which shall run from 1:00 p.m. until 6 p.m. on Easter Sunday. In even numbered years, father shall have custody during Segment A, and mother shall have custody during Segment B; and in odd numbered years, mother shall have custody during Segment A, and father shall have custody for Segment B. E. MEMORIAL DAY AND 7,ABOR DAY: The Memorial Day and Labor Day periods of custody shall run from the Friday before the holiday at 6:00 p.m. through the day of the holiday at 6:00 p.m. In even numbered years, the mother shall have custody of the children over Memorial Day and the father shall have custody over Labor Day. In odd numbered years, father shall have custody of the children over Memorial Day, and the mother shall have custody over Labor Day. F. INDEPENDENCE DAY: The Independence Day holiday shall run from July 3 at 6:00 p.m. until July 4 at 6:00 p.m. The mother shall have custody of the children in even numbered years and the father shall have custody of the children in odd numbered years. G. MOTHER'S DAY AND FATHER'S DAY: Mother shall have custody of the children every year on Mother's Day from 9:00 a.m. until 6:00 p.m. and father shall have custody of the children every year on Father's Day from 9:00 a.m. until 6:00 p.m. H. The holiday custody schedule shall supercede and take precedence over the regular custody schedule. 7. In the event that either party takes the children out of town for an overnight period or longer, that party shall provide advance notice to the other party of the address and telephone number where the children can be contacted. 8. The non-custodial parent shall be entitled to have reasonable telephone contact with the children not to exceed 1 time per day unless an additional contact is necessary due to an emergency. During the time that the mother has custody of the children, father shall exercise his right to telephone contact at 7:00 p.m. on Tuesday, Wednesday and Thursday evenings. If mother knows in advance that the children will not be available at her phone at that time, she will contact father to make other arrangements as to a time for him to speak to the children; and if she does not have such advanced notice and they are not available to speak to father on the telephone at 7:00 p.m., she will have them call father as promptly thereafter as she can. 9. The party receiving custody shall be responsible to provide transportation for the exchange of custody unless otherwise agreed between the parties. 10. Neither party shall smoke around the children during his or her periods of custody, and both parties shall ensure that third parties having contact with the children comply with this provision. 11. Neither party shall do or say anything which may estrange the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. Both parties shall also ensure that third parties having contact with the children comply with this provision. 12. The parties acknowledge that the children are currently engaged in a program of counseling with Stephanie Devine of Kenneth Small and Associates. The parties will continue the counseling program for the girls with that counselor. Further, the parties will both engage in a minimum of 6 sessions of co-parenting and communication counseling with a counselor to be recommended or, if the parties cannot agree, selected by Ms. Devine or by Kenneth Small Associates. The purpose of the co-parenting counseling is to enhance the parties' ability to communicate about their children and work together to resolve problems relating to custody of the children. Paul J. Esposito, Esquire 320 Market Street P.O. BOX 1268 Harrisburg, PA 17108-1268 For the Plaintiff Samuel L. Andes, Esquire 525 North 12th Street Lemoyne, PA 17043 For the Defendant By the Court, /'G?? 1 . Jl./ Wesley , Jr. ,/,j pcb JAIME JO ROSE, ? IN THE COURT OF COMMON Plaintiff 1 PLEAS OF CUMBERLAND ? COUNTY, PENNSYLVANIA VS. CHRISTOPHER DWAYNE STINE, Defendant CIVIL ACTION - LAW NO. 02-3650 CIVIL TERM IN CUSTODY PETITION TO CLARIFY, MODIFY OR ENFORCE PRIOR ORDER AND NOW comes the above-named Defendant, by his attorney, Samuel L. Andes, and petitions the court to modify, clarify, or enforce its prior order, based upon the following: 1. The Petitioner herein is the Defendant, Christopher Dwayne Stine. 2. The Respondent herein is the Plaintiff, Jaime Jo Rose. 3. In its prior order, a copy of which is attached) hereto, this court awarded shared legal custody of both of the parties' children to both of the parties. 4. The parties have agreed to involve the children, and themselves, in a program of voluntary counseling and therapy for the children to help the children adjust to their situation and the problems between the parties and their households. 5. Plaintiff has consistently frustrated the intentions of the parties' agreement, and this court's order, by refusing to cooperate in the scheduling of the children's counseling sessions. She has consistently arranged to schedule those sessions at a time when Defendant is not available to attend because of his work schedule. 6. As a result of the conduct of Plaintiff, Defendant has not been able to meaningfully participate in the counseling sessions with the children. 7. Despite repeated requests by Defendant and his attorney, Plaintiff has refused to cooperate in scheduling the counseling and has continued to obstruct Defendant's participation in the counseling program. WHEREFORE, Defendant prays this court to clarify, modify, or enforce the terms of its prior order by requiring Plaintiff to cooperate with Defendant in scheduling the counseling sessions for the children at a time when Defendant can attend and participate on a regular basis. uel L. And Attorney for Defendant Supreme Court I.D. #17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 VERIFI_ CA ION I verify that the statements made in this Petition are true and correct. I understand that any false statements in this Petition are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: CHRIS I ER D. STINE c7 ^> r ? O r r T Q I < Ul K 1 JAIME JO ROSE IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER DWAYNE STINE DEFENDANT 02-3650 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, May 12, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before ]Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg PA 17055 on Thursday, June 10, 2004 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 permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By. /s/ Dawn Sunday. Esq, mhc Custody Conciliator The Court of Common Pleas of Cumberland Comity is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 V NVA,TISNN--ld ?dNlr ?:?i rig •.?,i'... _ Ij I S Q NY E I AVW hOoz li,baui IG LICSd 3Ni 30 3W14.40-031 IJ JAIME JO ROSE VS. Plaintiff CHRISTOPHER DWAYNE STINE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-3650 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 7.3r day of ?' s: upon consideration of the attached Custody Conciliation Report, it is ord ed and directed as fo11ow2004, 1. The prior Order of this Court dated February 5, 2004 shall continue in effect as modified by this Order. 2. During the school year, the Father's periods of partial custody on alternating weekends shall run from Friday at 5:00 p.m. until Sunday at 7:00 p.m. 3. The Mother shall take the Children to their counseling appointments in August and September and the Father shall transport the Children to their appointment in October 2004. Thereafter, the Mother shall be responsible to schedule and provide transportation for the Children's counseling session in odd numbered months and the Father shall be responsible to schedule and provide transportation for the Children's session in even numbered months. When the Father is working on the day of the counseling session, the parties agree that the Mother will transport the Children to counseling appointments during the Father's months and the Father will come to the session as soon as possible after work to transport the Children home and to talk with the counselor, if appropriate. 4. Paragraph 8 of the prior Order is replaced with the following provision: The custodial parent shall ensure that the Children contact the non-custodial parent by telephone at 7:00 p.m. on Tuesdays, Wednesdays and Thursdays. The parties shall be entitled to contact the Children by telephone at reasonable times. 5. 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. cc Joanne Harrison Clough, Esquire - Counsel forl Samuel L. Andes, Esquire - Counsel for Father AU K2O 2004 BY THE COURT, Cl) c-i `J JAIME JO ROSE IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CHRISTOPHER DWAYNE STINE Defendant Prior Judge: J. Wesley Oler, Jr. 02-3650 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT emeunderACCO PROCEDURE 915 3-8, thsgned Custody Conciliator subms the f?ollllowing poOF CIVIL 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Sarah Jessica Rose January 11, 1997 Jenna Rayanne Rose January 11, 1997 Mother Mother 2. A conciliation conference was held on August 9, 2004, with the following individuals in attendance: The Mother, Jaime Jo Rose, with her counsel, Joanne Harrison Clough, Esquire, and the Father, Christopher Dwayne Stine, with his counsel, Samuel L. Andes, Esquire. 3. The parties agreed to entry of an Order in the form as attached. !4V4 ,AL /7, , y f?L Date Dawn S. Sunday, Esquire Custody Conciliator I F ED-M0E JAIME JO ROSE, PLAINTIFF VS. 2010 MAR 25 PM 2 33 CUMBEhU'11 ? ?Ar_y PE%1,,S' *P4!A CHRISTOPHER DWAYNE STINE, ) DEFENDANT ) THE COURT OF COMMON EAS OF CUMBERLAND ?UNTY, PENNSYLVANIA ACTION - LAW 0. 02-3650 CIVIL TERM CUSTODY AND NOW comes the above-named Defendant, by s attorney Samuel L. Andes, and petitions the court to modify the terms of its order of custod dated 5 February 2004, based upon the following: 1. The Petitioner herein is the original Defendant, Cl address is 3977 Brookridge Drive in Mechanicsburg, Pennsy 2. The Respondent herein is the original Plaintiff, Ja: whose address is 105 Park Place Avenue in Camp Hill, Penn 3. The parties are the parents of two minor children, 1997 and now age 13, named Sara Jessica Rose and Jenna X subject of an order entered by this court on 5 February 2004, and marked as EXHIBIT A. 4. Since the entry of that order, circumstances have Petitioner believes justify a change in the custody schedule. A. The daughters are several years older and involvement, guidance, and supervision than the Res] B. Respondent does not properly supervise tl with other persons substantial portion of time when F for the children. C. Respondent has a tumultuous relationship husband which has resulted in several instances of vi ristopher Dwayne Stine, and his vania 17050. me Jo Rose, now Jaime Jo Clark, cylvania 17011. win daughters, born I 1 January .yanne Rose. Those children are the a copy of which is attached hereto fanged significantly which ,hose circumstances include: e in need of more parental ndent can provide. children and places them itioner is available to care ith a boyfriend and with her -nce directed to Respondent U f? a1 ?loll kl1- '3y`1?'1 and in the presence of the children, all of which are children. 5. Petitioner is in a better position to provide a stal children. 6. Based upon the above, Petitioner requests that t order to award him primary physical custody of both daug] custody for the Respondent's time with them. 7. Prior orders in this matter have been entered by of this Court. 8. Respondent does not concur in the relief reques WHEREFORE, Petitioner prays this court to mod grant him primary physical custody of the parties' two chi] upsetting to the and appropriate home for the i Court modify the current custody t rs and set a schedule of temporary Honorable J. Wesley Oler, Judge in this Petition. its order of 5 February 2004 to S'amdel L. Andes Attorney for Defen ant Supreme Court ID 17225 525 North 12' Stre t P.O. Box 168 Lemoyne, Pa 1704 (717) 761-5361 I verify that the statements made in this document any false statements in this document are subject to the falsification to authorities). Date: 12 ou W 20 io true and correct. I understand that ties of 18 Pa. C.S. 4904 (unsworn DWIkYNE STINE I x?t?'T p JAIME JO ROSE, IN THE COURT OF (COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - CHRISTOPHER DWAYNE S`.PINE, : 02-3650 CIVIL TE Defendant IN CUSTODY ORDER OF COURT AND NOW, this 5th day of Februar 2004, upon consideration of Defendant's. Petition for Modification of Custody with respect to the children of the parties, ara Jessica Rose (date of birth January 11, 1997), and Jenna R yanne Rose (date of birth January 11, 1997), and pursuant to an a reement reached in open court among the parties and their respec ive counsel, Paul J. Esposito, Esquire, on behalf of the P1a;.,i ; -Ff, and Samuel L. Andes, Esquire, on behalf of the Defendant, it is or ered and directed as follows: 1. All prior orders of this Court in this action are vacated and replaced with this Order. 2. The parties, mother, Jamie Jo Rose-Clark, and the father, Christopher Dwayne Stine, shall share egal custody of the two children who are the subject of this order Each parent shall have an equal right, to be exercised jointly w to make all major non--emergency decisions affe general well-being including, but not limited regarding their health, education and religion be entitled to all records and information per children, including, but not limited to, schoo and information. th the other parent, ting the children's o, all decisions Each parent shall aining to the and medical records 3. During the school year motherlshall have primary physical custody of the children, and father shall have temporary custody on alternating weekends from 6:00 p.m. on Friday until 6:00 p.m. on Sunday. The father's alternating wee ends shall commence on Friday, February 6, 2004. 5. During the children's summer vacation from school, the parents shall share shall start with father commencing at 8:00 p.m. last day of school and Thereafter, the parties before the first day of school schedule set out custody on an alterna having the children f on the first Sunday a =_nding at 8:00 p.m. on shall alternate weeks school in the fall, a in paragraph 3 shall ing week basis, which r the first week ter the children's week later. until the Sunday which time the esume. 6. The parties shall share or alternate custody of the children on holidays as follows: A. CHRISTMAS: The Christm divided into Segment A, which shall run from C p.m. through Christmas Day at 1:00 p.m.; and S run from Christmas Day at 1:00 p.m. through De p.m. In even numbered years, the father shall) children during Segment A and mother shall have Segment B. In odd numbered years, mother shat. Segment A and father shall have custody during s holidays shall be zristmas Eve at 1:00 ?!gment B, which shall Member 26 at 6:00 have custody of the custody during have custody during Segment B. B. NEW YEARS: The New Years holiday shall be divided into Segment A, which shall run from Now Years Eve at 1:00 p.m. through New Years Day at 1:00 p.m., and S gment B, which shall run from 1:00 p.m. until 6:00 p.m. on New Year Day. For purposes of this subparagraph, the entire New Years holiday shall be deemed to fall in the same year as New Years Eve. In?even numbered years, the father shall have custody of the children gor Segment A and mother shall have custody for Segment B. In oqd numbered years, mother shall have custody for Segment A, and father shall have custody for Segment B. C. THANKSGIVING: The Thanksgiving holiday shall run from the Wednesday before Thanksgiving at 6:00 p.m. through the Sunday following Thanksgiving at 6:00 p.m. T e mother shall have custody of the children for the Thanksgiving oliday in even numbered years and father shall have custody ?n odd numbered years. D. EASTER: The Easter hol?day shall be divided into Segment A, which shall run from the Saturday before Easter at 1:00 p.m. through Easter Sunday at 1:00 p.m.; and Segment B, which shall run from 1:00 p.m. until 6 p.m. on Easter Sunday. In even numbered years, father shall have custody during Segment A, and mother shall have custody during Segment B; a rd in odd numbered years, mother shall have custody during Segment A, and father shall have custody for Segment B. E. MEMORIAL DAY AND LABOR AY: The Memorial Day and Labor Day periods of custody shall run fr m the Friday before the holiday at 6:00 p.m. through the day of tle holiday at 6:00 p.m. In even numbered years, the mother shall have custody of the children over Memorial Day and the father sha Labor Day. In odd numbered years, father sha children over Memorial Day, and the mother s Labor Day. F. INDEPENDENCE DAY: The holiday shall run from July 3 at 6:00 p.m. un p.m. The mother shall have custody of the ch numbered years and the father shall have cust odd numbered years. have custody over have custody of the 1 have custody over dependence Day 1 July 4 at 6:00 dren in even y of the children in G. MOTHER'S DAY AND FATHER'S DAY: Mother shall have custody of the children every year on Mot?er's Day from 9:00 a.m. until 6:00 p.m. and father shall have cujstody of the children every year on Father's Day from 9:00 a.m. until 6:00 p.m. H. The holiday custody sc edule shall supercede and take precedence over the regular custody schedule. 7. In the event that either party takes the children out of town for an overnight period or longer, that party shall provide advance notice to the other party of he address and telephone number where the children can be contacted. 8. The non-custodial parent sha 1 be entitled to have reasonable telephone contact with the childre not to exceed 1 time per day unless an additional contact is neces ary due to an emergency. During the time that the mother h s custody of the children, father shall exercise his right to elephone contact at 7:00 p.m. on Tuesday, Wednesday and Thursday venings. If mother knows in advance that the children will not b available at her phone at that time, she will contact father t make other arrangements as to a time for him to speak to the children; and if she does not have such advanced notice and th y are not available to speak to father on the telephone at 7:00 p m., she will have them call father as promptly thereafter as sh can. 9. The party receiving custody hall be responsible to provide transportation for the exchange of custody unless otherwise agreed between the parties. 10. Neither party shall smoke a ound the children during his or her periods of custody, and bot parties shall ensure that third parties having contact with the children comply with this provision. 11. Neither party shall do or s y anything which may estrange the children. from the other parent, njure the opinion of the children as to the other parent, or hampe the free and natural development of the children's love and respect for the other parent. Both parties shall also ensure that third parties having contact with the children comply with this provision. 12. The parties acknowledge the the children are currently engaged in a program of counseling with Stephanie Devine of Kenneth Small and Associates. The parties will continue the counseling program for the girls with that counselor. Further, the parties will both engage in a minimum of 6 sessions of co-parenting and communication counseling with a counselor to be recommended or, if the parties cannot agree, selected by Ms.. Levine or by Kenneth Small Associates. The purpose of the co-pare ting counseling is to enhance the parties' ability to communicate about their children and work together to resolve problems relating to custody of the children. By the Court, G? !esley Paul J. Esposito, Esquire 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 For the Plaintiff Samuel L. Andes, Esquire 525 North 12th Street Lemoyne, PA 17043 For the Defendant pcb J?., J. TRUE COPY ROM m 1'eshm nywhere , i here unttsW rty hand and Ow seei of saki at .",:?U3409 Pa. rhic /n ,-, &V JAMIE JO ROSE PLAINTIFF V. CHRISTOPHER DWAYNE STINE DEFENDANT IN THE C( URT OF COMMON PLEAS OF CUMBERL ND COUNTY, PENNSYLVANIA 2002-36501 CIVIL ACTION LAW IN CUSTODY AND NOW, Thursday, April 01, 2010 it is hereby directed that parties and their respective counsel appea at 39 West Main Street, Mechanicsburg, PA 17055 on for a Pre-Hearing Custody Conference. At such conference, an efl if this cannot be accomplished, to define and narrow the issues to I order. Failure to appear at the conference may provide grounds to consideration of the attached Complaint, before Dawn S. Sunday, Esq. the conciliator, Thursday, May 06, 2010 at 10:30 AM rt will be made to resolve the issues in dispute; or heard by the court, and to enter into a temporary entry of a temporary or permanent order. The court hereby directs the parties to furnish any and 11 existing Protection from Abuse orders, Special Relief orders, and Custodv orders to the conciliator 48 tours prior to scheduled hearinLy. FOR THE COURT, By: /s/ iunday, B 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 accessibl facilities and reasonable accommodations available to disabled individuals having business before the co rt, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or busines before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO O OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET I EGAL HELP. n tW Cumberland County Bar Association ?r 7- + 5- o co'?k- MCtA key ,- T, ??-- 32 South Bed Ord Street -Q ?SpQ$i^?O Carlisle, Pennsvl ania 17013 1 _ r c -:- Telephone (71 ) 249-3166 Dawn 14 -S-Io cop,? rna;leA +0 MAY 10 2010 JAMIE JO ROSE IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2002-3650 CIVIL ACTION LAW CHRISTOPHER DWAYNE STINE Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2010, upon consideration of the attached Cus~~~~tody C----onciliation Report, it is o dered and directed as follows: 1. A hearing is scheduled in Court Room No. ~ of the Cumberland County Court House on the v7(o.~tday of (~~ , 2010, at % o'clock ~m., at which time testimony will be taken. F • purposes of the hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least seven days prior to the hearing date. 2. Pending the hearing and further Order of Court or agreement of the parties, the prior Order of this Court dated February 5, 2004 shall continue in effect. cc: ~sica Holst, Esquire -Counsel for Mother /Samuel L. Andes, Esquire -Counsel for Father ~// ~/iGl ,/c'-tom tES m~.l~ s/~3/~v C'7 G o r:J o n ' ~..._.. ..~' --C T7 ~.-'_ f r .P... c c~~ ~.'- ..... w 'T7 CTt ;.i c~ ~~~= t,,~ ~;; C .J -~ c . rv - i`fl ~._-~ .~- ~a BY THE COURT. JAMIE JO ROSE IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2002-3650 CIVIL ACTION LAW CHRISTOPHER DWAYNE STINE Defendant IN CUSTODY Prior Judge: J. Wesley Oler, Jr. 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Sara Jessica Rose January 11, 1997 Mother/ Father Jenna Rayanne Rose January 11, 1997 Mother/Father 2. A custody conciliation conference was held on May 6, 2010, with the following individuals in attendance: the Mother, Jamie Jo Rose, with her counsel, Jessica Holst, Esquire, and the Father, Christopher Dwayne Stine, with his counsel, Samuel L. Andes, Esquire. 3. This Court previously entered an Order in this matter on February 5, 2004, under which the Mother has primary physical custody of the Children during the school year and the parties share having custody during the Summer school break on an alternating weekly basis. The Father filed this Petition to Modify seeking primary physical custody of the Children during the school year. The parties were not able to reach an agreement at the conference and it will be necessary to schedule a hearing. 4. The Father's position on custody is as follows: The Father believes that it would be in the Children's best interest to reside primarily with him at least during the school year as the Father reports it is the preference of the Children. According to the Father, the Children have indicated to him that there is an atmosphere of tension at the Mother's residence due to the process of divorce with her current husband and at least one violent incident between the Mother and her boyfriend when the Children were in the home. The Father does not believe that the Children are receiving adequate supervision and he believes that they are frequently left home alone in the evening, when he would otherwise be available to provide care for them. The Father also believes that the relationship between the Children and the Mother is difficult at this time due to the developments with the Mother's divorce and boyfriend, the Children's age, and other factors. The Father stated that he is pursuing primary custody essentially at the insistence of the Children. 5. The Mother's position on custody is as follows: The Mother believes it would be in the Children's best interest to maintain the existing custody schedule under which the parties share custody during the Summer and the Mother has primary physical custody during the school year. While the Mother acknowledges that there have been tensions in her household over the past few months due to the pending divorce, financial difficulties and a single anomalous incident of domestic violence involving her boyfriend, the Mother believes that those factors are or have been resolved and do not merit a change in the basic custody schedule. While willing to make arrangements for additional time for the Father as requested by the Children, the Mother believes that another drastic change in their lives would be detrimental at this time. The Mother made an attempt to consider the possibility of an alternative arrangement on a trial basis but concluded that, at heart, it did not feel right and would not be the best decision for the Children. 6. The conciliator recommends an Order in the form as attached scheduling a hearing in this matter. It is anticipated that the hearing will require at least one half day. Date Dawn S. Sunday, Esquire Custody Conciliator ~'yy 1,~. ll..L~`d~ l 1~ r,~ r='~ P~ F r . ... ~,' ~~i,^ #~ 201? ~.~L -7 ~' ~: ~?~ JAMIE JO ROSE, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER DWAYNE STINE, Defendant NO. 02-3650 CIVIL TERM CIVIL ACTION -LAW DEFENDANT'S PETITION FOR EMERGENCY RELIEF AND NOW comes the above-named Defendant, by his attorney, Samuel L. Andes, and petitions the court for emergency relief in the form of an order awarding him primary physical custody of the minor children in this action, based upon the following: 1. The Petitioner is the Defendant. The Respondent is the Plaintiff. 2. The parties are the parents of two minor twin daughters, Sara Jessica Rose, and Jenna Rayanne Rose, both born 11 January 1997. 3. The children are currently the subject of an order entered by this Court on 5 February 2004 and the parties are scheduled for a hearing before the Honorable J. Wesley Oler, Jr., Judge of this Court, on 26 August 2010 on Defendant's petition to modify that order. 4. Within the past thirty (30) days, Defendant/Fatherbas become aware of serious problems in the home of Plaintiff/Mother which have a serious negative impact upon the girls. Specifically: A. Mother and her live-in boyfriend, Harry Winters, have been engaged in a series of assaults against each other, including an assault by Mr. Winters on Mother on 13 June 2010 and an assault by Mother on Mr. Winters on 20 June 2010. 70 ~ Pd /~G 9 > B. Mother and her boyfriend drink to intoxication and frequently argue, in addition to the physical fights between them, in the presence of the children. C. Mother has taken the children with her driving in her automobile when she is seriously intoxicated and driving while under the influence, over the protests of the daughters. D. Mother has attempted to prevent the daughters from communicating with Father about these problems and, in furtherance of those attempts, has taken the children's cell phones and ipods from them and refused to allow them to communicate with Father. E. During and immediately following her arguments and fights with her boyfriend, Mother directs verbal abuse, insulting language, and foul language, at the parties' children. F. As a result of the conduct of Mother and her live-in boyfriend, the children are fearful of both Mother and her boyfriend and Father is concerned for their physical safety. G. As a result of the violence in the Mother's household, the local police have been called repeatedly and have filed criminal charges against both Mother and Mr. Winters. 5. Despite the violence and fighting between Mother and her boyfriend, Mother continues to live with her boyfriend and insists that the children stay in his home with her during her weeks of custody. 6. The children have related these problems to Father and he has been able to confirm much of the information provided to him by his daughters. The daughters have expressed considerable fear of their Mother and Mr. Winters, particularly when the Mother and Winters are drinking to excess. 7. Both daughters have expressed a strong desire to reside with Father and have explained that they wish to avoid the trauma, chaos, and fear they experience while at their Mother's home with Mother and her boyfriend. 8. Father believes it is critical to the best interests of the children that they be protected from the verbal and physical abuse directed at them by their Mother and her boyfriend and that they be separated from the physical violence in Mother's household. 9. This matter is currently assigned to the Honorable J. Wesley Oler, Jr., who has entered previous orders in this case. 10. Plaintiff does not concur in the relief requested in this petition. WHEREFORE, Defendant prays this Court to award him primary physical custody of both of the parties' minor children until the hearing scheduled for 24 August 2010 or until such earlier date as the Court schedules any hearing. Samuel L. Andes Attorney for Defendant P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: ~ ~(~ ~ 2V _ ' CHRISTOP ER DWAYNE ST E CERTIFICATE OF SERVICE I hereby certify that on _ ~ ~ try 2010, I served a copy of the foregoing document upon counsel for Plaintiffby U.S. Mail, postage prepaid, addressed as follows: Jessica Holst, Esquire Mid-Penn Legal Services 401 E. Louther Street, Suite 103 Carlisle, PA 17013 Samuel L. Ande Attorney for Defendant Supreme Court ID 17225 P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 ,~ i i JAMIE JO ROSE, ) Plaintiff ) vs. ) CHRISTOPHER DWAYNE STINE, ) Defendant ) ORDER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3650 CIVIL TERM CIVIL ACTION -LAW AND NOW this ~~ day of , 2010, upon consideration of the attached petition, a hearing/conference is hereby schedule ,before the undersigned, to commence at o'clock ~.m., on ,the a~ ~ day of , 2010, in Court Room No. 1 of the Cumberland County Court House, 1 Courthouse Square, Carlisle, PA. Distribution: ~ Jessica Holst, Attorney for Plaintiff, 401 E. Louther Street, Suite 103, Carlisle, PA 17013 '~ Samuel L. Andes, Attorney for Defendant, P.O. Box 168, Lemoyne, PA 17043 ., .-_ --_ ~, ~~ _. - ~.. ; ~~ :~ -`- _._ BY THE COURT, JAIME JO ROSE-CLARK,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION n _ CHRISTOPHER DWAYNE STINE, ' Defendant . NO. 02-3650 CIVIL TERM { c -a C IN RE: DEFENDANT'S PETITION TO MODIFY CUSTODY O ER`0- and DEFENDANT'S PETITION FOR EMERGENCY RELIEFS .rs BEFORE OLER, J. OPINION and ORDER OF COURT AND NOW, this 30`h day of August, 2010, upon consideration of Defendant's Petition To Modify Custody Order and Defendant's Petition for Emergency Relief, with respect to the parties' children, Sara Jessica Rose (d.o.b. January 11, 1997) and Jenna Rayanne Rose (d.o.b. January 11, 1997), and following a hearing held on August 26, 2010, it is ordered and directed as follows: 1. The caption of this case is amended to reflect Plaintiff's present name of Jaime Jo Rose-Clark; 2. Legal custody of the children shall be shared by the parties. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all non-emergency decisions regarding the children including, without limitation, decisions regarding the health, education and religious training of the children. Both parties shall be entitled to full access to all records and information relating to the children and neither party shall withhold any information from the other party regarding such matters; 3. During the school year, primary physical custody of the children shall be in Defendant, the father, and temporary or partial physical custody of the children shall be in Plaintiff, the mother, at the following times: a. On alternating weekends, from 6:00 p.m. on Friday, until 6:00 p.m. on Sunday; b. Every Wednesday evening, from 5:00 p.m. until 8:00 p.m.; c. During Thanksgiving vacation, from 3:00 p.m. on Thanksgiving Day until 3:00 p.m. on the Sunday following Thanksgiving Day; d. During Christmas vacation, from 3:00 p.m. on Christmas Day until 3:00 p.m. on the day preceding the resumption of school; e. During any spring vacation, from 3:00 p.m. on the day following the last day of school preceding the vacation to 3:00 p.m. on the first day preceding the resumption of school; 4. During the summer, physical custody of the children shall be shared by the parties on an alternating weekly basis, with the exchange time being 6:00 p.m. on Friday; 5. The non-custodial parent shall be entitled to have reasonable telephone contact with the children; 6. The party receiving custody shall be responsible to provide transportation for the exchange of custody. 7. Nothing in this order is intended to preclude the parties from deviating from its terms by mutual consent. 8. Either party may secure a review of this custodial arrangement at the conclusion of the present school year, by petition. During the current school year, the children shall attend school in the Cumberland Valley School District, where Defendant, the father, resides. ?fessica Holst, Esq. 401 E. Louther Street Suite 103 Carlisle, PA 17013 Attorney for Plaintiff S •? /Samuel L. Andes, Esq. P.O. Box 168 Lemoyne, PA 17043 Attorney for Defendant , BY THE COURT, J. esley 01 Jr., JAMIE JO ROSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW 02-3650 CIVIL TERM CHRISTOPHER DWAYNE STINE, Defendant CUSTODY/VISITATION IN RE: DEFENDANT'S PETITION TO MODIFY ORDER OF CUSTODY & DEFENDANT'S PETITION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 26th day of August, 2010, upon consideration of Defendant's Petition To Modify Order of Custody, and the Defendant's Petition for Emergency Relief, and following a hearing held on this date, the record is declared closed, and the matter is taken under advisement. Jessica Holst, Esquire 401 East Louther Street Suite 103 Carlisle, PA 17013 For Plaintiff Samuel L. Andes, Esquire 525 N. 12th Street P.O. Box 168 Lemoyne, PA 17043 For Defendant :mae ~f~i' rr~~l4d~ 4 ! ~l0 o Y s ':~ ~:.. -c ~ 3 co w a-. By the Court,