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TIMOTHY M, LAVIN, ) IN THE COURT OF COMHON
Plaintift ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
vs, )
) NO. 94-5076 CIVIL 'rERH
KRISTINA GOODLANDER, )
Detendant ) CUSTODY
Q!!!I!l
AND NOlI, this 1"{ \t. day ot 0 c..{ 0 to cr ' 1994, upon receipt ot the
.conciliator'd report, it appearing that the parties have agreed to the terms and
provisions ot this order which was dictated in their presence and approved by them and
their counsel. we hereby order as tollows:
1. Legal custody ot the minor child, Kaytlynne L. Goodlander, born March 9, 1991,
is hereby temporarily awarded to her mother, the Detendant, Kristina Goodlander, on the
condition. however. that the mother will consult with the tather. Timothy M. Lavin,
whenever possible betore making any critical or major decisions regarding the child,
It is not our intention to make this award permanent and we will review it upon the
request ot either party as the circumstances change,
2, Physical custody ot the said minor child shall continue with the mother.
3. The tather shall have the tOllowing periods ot temporary or partial custody ot
the child:
A, On October 22. 1994, from 10:00 a,m, until 7:00 p,m, and on October
23, 1994, trom 11:00 a.m, until 7:00 p,m,
B, On November 25, 1994, and November 26, 1994. trom 10:00 a,m, until
7:00 p.m, each day and on November 27, 1994. from 11:00 a,m. to 7:00 p,m,
1
c, On December 22, 1994, Pecember 23, 1994, December 29, 1994, and
DeceMber 30, 1994, from 10100 a.m, until 7100 p,m, each day,
The father ahall be responsible to pick up the child at the mother's residence and
shall be accompanied by one of his parents for purposes of the custodial exchange,
4, This order is intended to be temporary only and is further intended to give
the father a period of time for the child to be re-introduced to him and for bill to
,
!start forming a good father-child relationship with the child, We expect tbat the
i,father's time will expand in 1995 or thereafter, to include overnight time,
Accordingly, ve direct the parties to appear before the conciliator in this matter for
. further proceedings at a conference to be held in the office of the conciliator at 525
North 12th Street in Lemoyne, Pennsylvania, on Tuesday, the 17th day of January,
"
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'1995, commencing at 1100 p,m,
5, This order is entered at a time when the father is a full-time student at
,Temple University in Philadelphia. It is expected that the fatber will be personally
',present for tbe times be is scbeduled to have the cbild, altbough he is encouraged to
cooperate with his parents so that they see the child on these occasions as veIl.
By the Court,
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. . ~~rug, Esquire _ e...\t;r ,""';'.('J..IU~.,)r;'t J.
~o;~ey for Plaintiff' .s, ~
Prances H, Del Duca, Esquire _ (',<t"".l _,u(,'''-,J......~ i....lL
Attorney for Defendant l 'JJ
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I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
t
t CIVIL ACTION - LAW
t NO, q4-- 5"O'l{P CtVd T.LA~
t
CUSTODY
TUIOTIIY M. LAVIN,
Petitioner
KRISTINA GOODLANDER
Respondent
ORDER OF COURT
AND NOW, this ~ day of ~t?fcn\bt' ,1994, upon
consideration of the attached Petition, it is hereby directed that
the parties and their respective counsel appear before, s,..mW'( LIl.Js
..y"
, the Conciliator, at 5J~' IV, lat., 'J/:
Li'I'n~"lflt' , on the '1 fill--.. day of Of'l<'brr
.
199~, at '7, p.m., for a Pre-Hearing Custody
Conference. At such Conference. an effort wiil be made to resolve
the issues in dispate; 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
"",Wt1also be present at the Conference, Failure to appear at the
Conference may provide grounds for entry of a temporary or,
permanent order,
BY THE COURT:
\<~ ,..,,,JA, - illa.:). Eir)((,
Custody Conciliator
L_ '
BY:
YOU SHOULD TAlE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Office of the Court Administrator
Cumberiand County Courthouse
Four th Floor
Carlisle. PA 17013
(717) 240-6200
"
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TIMOTHY M, LAVIN, ) IN THB COURT OF COMMON
PlaintlU ) PLBAS Of CUMBERLAND
) COUNTY, PENNSYLVANIA
vs, )
) NO. 94-5076 CIVIL TERM
KRISTINA GOODLANDER, )
Defendant ) CUSTODY
!JUDGE PREVIOUSLY ASSIGNED: The Honorable J, Wesley Oler, Jr,
!;.ONe I L!ATO-L~9.N1BRJjHCB _lIIOO1ARY RB!'QRT
IN ACCORDANCE WI'l'H CUMBERLAND COUN'l'Y RULE OF CIVIL PROCEDURE 1915,3-8(bl, 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
!!tR'l'HDATE
9 March 1991
CURRENTLY IN
CUSTODY OF
Kaytlynne L, Goodlander
l>efendant/Hother
2, A Conciliation Conference was held on 1 February 1995 and the following
individuals were present: the Plaintiff and his attorney, Rob A, Krug, Esquire; the
. Defendant and her attorney, Frances H, Del Duca. Esquire,
3, 1'he parties were before me in October at which time the mother did not want
the father to have overnight contact with the child because the father and the child
had not established any meaningful relationship, At that time we negotiated a
temporary order which gradually reintroduced the father to the child with the express
understanding that the father would, within a few months, expand that into overnight
time with the child. That time is not up and the mother is not willing to relent and
agree to allow the father to have overni~ht visitation,
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4, Her reasons are that the father does not have proper facilities lshe claims
that the father and his family consist ol about five adults who live in a 2-bedroolll
I
I house) and that the child cries when the lather comes to pick her up tor periods of
,temporary custody, The fath~r (!ontends that five adults live in a )-bedroolll house and
,
I that, when his daughter stays with him, he has arranged (or her to have a bedroom by
herself, Although he acknowledges that, sometimes, the child is upset when he first
':picks her up, he reports that the child soon brightens and always has a good tiMe with
bim,
~, I see absolutely no reason whatsoever why this man should not have the same
type o( access to his child as every other (ather enjoys in similar circumstances, The
child is almost (our years o( age, there is no accusation by anyone that the (ather has
I mistreated the child or is otherwise not a proper parent, and the father has
demonstrated by bis conduct and patience a sincere desire to have a meaningful
relationship with his daughter. 'fhe sooner he can start his overnight contact. with the
child the sooner she will get over her alleged reluctance and the sooner sbe will
'develop a Meaningful and proper relationship with him,
6, Try as I might, I could not get the mother to relent and it will be necessary
for the court to order overnight visitation for the (ather. The parties were able to
reach agreement for a temporary order to continue the present arrangements pending that
i hearing, After the hearing, I strongly suggest that the court. extend the father's
weekend time (rolll Saturday morning at 10:00 a,m, until Sunday evening at 1:00 p,m, at
least every third weekend,
1. I do not expect the hearing will take long. The only witnesses identified by
the parties were members of their families, The issuer. are simple and the court should
,TIMOTHY M, LAVIN, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
vs, )
" ) NO, 94-5076 CIVIL TERM
iKRISTINA GOODLANDER, )
Defendant ) CUS'fOllY
ORDBR
II AND NOW, this day of , 1995, upon receipt of the
I
~:conciliator'~ report, it appearing that the parties have agreed to the terms and
I provisions of this order which was dictated in their presence and approved by them and
I
their counsel, we hereby order as tollows:
1, The provisiQns regarding legal custody and primary physical custody of the
Minor child, Kaytlynne L, Goodlander, born March 9, 1991, set out in our prior order
shall continue until further order of this court.
2. The father of the child, the Plaintiff, Timothy M, Lavin, shall have the
following periods of temporary or partial custody of the child pending further order of
this court:
A. Every third weekend on Saturdays from 10:00 a.m, until 7:00 p,m. and
on sundays from 11:00 a,m, until 7:00 p,m" commencing on Saturday, February
18, 1995,
B, Such other times as the parties may agree,
The father shall be responsible to pick up the child at the mother I s residence for
purposes of the custodial exchange and he shall return the child to the mother's
residence at the end of his periods of custody,
1
MAIN OffiCE
412 Erford Road
Camp Hili, PA 17011
Sian ley E. Schneider, Ed.O,
Dlreclor
(;GUIDANCE
ASSOCIA TES
OF
PENNSYLVANIA
Call111 UIIII <<717) 7:I~.~'l17
UmheYI (717) ll:t:I.4JI~
Carll,lrl (717) ~4Il,~~""
CharnhmhurRI (717) ~I.:I,":I"~
fA_I 1717) 7:l:1.!l:I71l
March 2, 1995
Re: Kaytlynne Goodlander
DOB: March 9, 1991
TO WHOM IT MA Y CONCERN:
Kaytlynne Goodlander and her mother were assessed In the offices 0'
Guidance Associates of Pennsylvania February 16, 1995, Ms, Goodlander
expressed concerns regarding possible overnight visitations by Kaytlynne with her
father and asked for guidance In preparing her 'or this.
Based on a review 0' symptoms, Kaytlynno ','JlIIIlS to ho exhibiting 0
Separation Anxiety Disorder, Briefly, this condition Is choracterllod by feelings 0'
apprehension, worry, and anxiety when separation from a parental figure 15
contemplated. Kaytlynne exhibits reluctance to fall osloep when not In her
mother's presence, and 15 apprehensive about ~taylno ovurnl{Jtll sornewhuro other
than her home, Recently, her maternal aunt allemptud to keep Kaytlynne
overnight, but was unsuccessful, Kaytlynne cried And cOflllnuously pleaded to
return home,
During her Initial office vlslth Kaytlynne was also unahla to separate from her
mother and became quite appre enslve when this was suggested, Based on her
mother's reports, the severity 0' Kaytlynne's condition would be judged as mild to
moderate.
Treatment of Separation Anxiety Disorder typic oily Involves a procedure
termed systematic desensitization. Briefly, this refors to 0 stop by step approach
to achieving separation from her mother, Initially, In Koytlynno's case, work
should be done on Kaytlynne failing asleep whon n.:>t In hor mother's presence.
Afterwards, attempts should be made to have Kaytlynno stay for 0 few hours with
a babysitter, preferably her aunt, An overnight stay with 11m aunt might be an
appropriate third step, Finally, a similar gradual procodllrl! should be used to
achieve overnight visitation with her father, Prior to each soporutlon, Kaytlynne
might be prepared via role playing and such toctmlqulls as bibliotherapy.
Instruction In relaxation techniques such as vlsuul 1"'f10ury and systematic
breathin\} would also be helpful. Of course, her parunts should also receive
information about Kaytlynne's condition and assist In doveloplng effective
responses during periods of Increaslld anxiety.
Comprehensive PsycholoKical Se,vices
.
nrUK "'ld Ah'lIhlll Treatment
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/ , ~ ,,!I'SSCIVIL ACTION - LAW
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: ~~5076 CIVIL TBRN
IN THI COURT OP CONNON PLD.S 0'
CUKBIRLAHD COUNTY, PINNSYLVANIA
TIMOTHY M. LAVIN,
Plaintiff
KRISTINA GOODLAHDIR,
Defendant
IN RBI CUSTODY
ORDBR or COURT
AND NOW, this 28th day of April, 1995, upon
consideration of the Petition for Custody in the above-captioned
matter, and following a hearing, with respect to the parties'
minor child. Kaytlynne Goodlander, born March 9, 1991, it is
ORDBRBD and DIRBCTID as follows I
1. Legal and primary physical custody of the
child shall be in the mother, provided, that the mother shall
consult with the father whenever possible before making any
critical or major decision regarding the child.
2. Temporary or partial phy.ical custody shall be
in the father at the following time. I On alternating weekends
from Saturday at 10100 a.m. until Sunday at 7100 p.m., on
alternating federal holidays from 10100 a.m. until 7100 p.m., on
Christmas and New Year's Days from 1100 p.m. until 6100 p.m.,
and during three nonconsecutive week. each .ummer.
'ather or father's mother shall be responsible for
picking up the child and delivering the child during exchanges
of custody.
Nothing in this Order shall prevent the parties
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TIMOTHY M. LAVIN,
9 -5076 CIVIL TERM
va.
Civil Action - Law
KRISTINA GOODLANDER,
IN CUSTODY
AND NOW
PETITION FOR MODIFICATION
this ~\ day of t"'ft,i:( H
, 1997, comes
the Petitioner, TIMOTHY M. LAVIN, and represents the
following:
1. Your Petitioner, TIMOTHY M. LAVIN, is an adult
individual with a mailing address of ~03 Whiskey Springs Road,
Dil1sburg, York County, Pennsylvania, 17019,
2. Your Respondent, KRISTINA GOODLANDER, is an adult
individual with a last known address of 1102 Columbus Avenue,
Apt. 12, Lemoyne, Pennsylvania, 17043,
3. Pursuant to an Order of Court dated April 28, 1995,
this Honorable Court granted legal and primary physical
custody of the parties' minor child, Kaytlynne Goodlander.
born March 9, 1991 to the Respondent/Mother. (A copy of said
Order is attached hereto as Exhibit A,)
AOB II, KIIUG
A"OMII" AT LAW
'01011 lltll
.~. C;A,.AL.'
OOVU. "...n\j'..Nt... 1 u,a
4. Pursuant to that Order of Court the Mother was
required to conRult with the Father whenever possible before
making any critical or major decisions regarding the child.
..
TIMOTHY M, LAVIN,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
VB,
NO, 94-6076 CIVIL TERM
KRISTINA GOODLANDER,
Defendant
CIVIL ACTION - LAW
CUSTODY
JUDGE PREVIOUSLY ASSIGNED: The Honoreble J, Wesley Oler, Jr,
CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1916,3-B(b). the undersigned Custody Conciliator submits the
following report:
1, The pertinent Information concerning the chlld(ren) who Is(ere) the
subject of this litigetion is es follows:
NAME
BIRTHDATE
CURRENTLY IN
CUSTODY OF
Kaytlynne Goodlander March 9, 1991
2, A Conciliation Conference was held on April 17, 1997, and the following
Individuals were present: the Plaintiff and his attorney, Rob A, Krug, Esquire; the
Defendant appeared with her attorney, Lori K, Serratelli, Esquire,
3, Items resolved by agreement: See attached Order,
4, Issues yet to be resolved: See attached Order,