HomeMy WebLinkAbout94-05334
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JODI L. YOHN, I IN THE COURT OF COMMON PLEAS
I CUMBF.RLAND COUNTY, PENNSYLVANIA
plaintiff I
I riLl - S ~,J'I {', ,;( _1.c ""''J
v. t NO,
I
DENNIS F. YOHN, I
I
t
Defendant t CIVIL ACTION - CUSTODY
ORDIR or COURT
AND NOW, this
upon consideration of the
directed that the parties
" I {
before '", "L'"
at ,<'1 ~ {\/ If)~ ')j L".,y"r
,
on the ') I,ll. day of I) { \" b, , , 1994, at Jt-.m., for a
Pre-Hearing Custody Conference. At such conference, an effort
will be made to resolve the issues in dispute; or if this cannot
be accomplished, to define and narrow the issues to be heard by
the court, and to enter into a temporary order. All children age
five or older s~l (may) also be present at the conference.
Failure to appear at the conference may provide grounds for entry
of a temporary or permanent order.
(' It..
;)/',1 day of ",JI"fI.fY(ll, 1994,
attached complaint, it is hereby
and their respective counsel appear
IIIl,lt.., 1"1/ , the conciliator,
FOR THE COURT,
By:
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT AMNINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
TELEPHONE: (717) 240-6200
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During the past ten years the children have resided with
following persons and at the following addresses:
(1) from April, 1983, to January, 1991, at 2701 Mill Road,
Grantham, Pennsylvania with both Plaintiff and Defendant.
(2) from January, 1991, to June 15, 1994, at 115 Willow View
Drive, Carlisle, Pennsylvania with both Plaintiff and Defendant
(3) from June 15, 1994, to present at 115 Willow View Drive,
Carlisle, Pennsylvania with Defendant.
The mother of the children is the Plaintiff, JODI L. YOHN,
whose permanent address is 115 willow View Drive, Carlisle,
Cumberland County, Pennsylvania. she is presently married to
Defendant.
The father of the children is the Defendant, DENNIS F. YOHN,
currently residing at 115 Willow View Drive, Carlisle, Cumberland
County, Pennsylvania. He is presently married to Plaintiff.
4. The relationship of Plaintiff to the children is
that of biological mother. The Plaintiff currently resides with
her sister at 1110 Apple Drive, Mechanicsburg, Cumberland County,
Pennsylvania.
5. The relationship of Defendant to the children is
that of biological father. The Defendant currently resides with
the children at 115 Willow View Drive, Carlisle, Cumberland
county, Pennsylvania.
6. Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the children in this or another court.
. .'
JODY L. YOHN, I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
PlainUtr I
t
v. t NO. 94-5334 Civil Term
t
DENNIS F. YOHN I
t
Defendant t IN DIVORCE
CIRTI.ICATI O. 81RVICI
I, Thomas M. Kutz, Esquire, do hereby certify that I
served a true and correct copy of the Complaint for Custody and
Order ot Court setting a concilation conference for the above
captioned matter on the Defendant, DENNIS F. YOHN, by depositing
a copy of the same in the united states mail, certified,
restricted delivery, return receipt requested and postage
prepaid. The return receipt bearing the Defendant's signature
and showing a delivery date of September 27, 1994, is attached.
----------.j, / /
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Thomas M. Kutz~ Esquire,
Attorney for Defendant
219 East Main street
Mechanicsburg, PA-.17055
Attorney I.D. NO. 38887
date:. ,-<';; 6, /,>-",.y
. ,
NOV 0 1 199,~c...
,! ) IN THB COURT OF COHHON
.JODI L. YOHN,
Plaintiff ) PLEAS OF CUHBERLAND
) COUNTY, PENNSYLVANIA
VI. )
I NO. 94-5334 CIVIL TERM
DENNIS F. YOHN, )
Defendant ) CUSTODY
AND NOW, this
~ OlDY
11 day of Nrv:
, 1994. upon receipt of the
conciliator'a report, it appearing that the parties have agreed to the terlls and
provisions of thlS order which was dictated in their presence and approved by them and
their counsel, we herebY order as follows:
1, Legal custody of the ~inor chlldren, Taryn Yohn. born .June 7, 1982, and Joden
Yohn, born .June 23, 1984. shall be shared by their parents, the Plaintiff, .Jodi L.
Yohn, and the Defendant, Ilennis F, Yohn.
2, The parents shall share physical custody of the children on the following
schedule, pending further order of this court:
A, The children shall be with the mother from 5:00 p.m, on Sunday,
October 30, 1994. through 5:00 p,m. on Sunday, Nove~ber 6. 1994.
B. The father shall then have the children from 5:00 p.m. on Sunday,
Novellber 6, 1994. through 5:00 p.m, on Sunday, November 13, 1994.
C, The parties will alternate physical custody of the children on a
week-to-week basis thereafter with the exchange to be at 5:00 p.lI. on Sunday.
D. For the Christllan holiday of 1994, the Mother, who will have
physical custody on Sunday. Dec:eRlber 25, 1994, wi 11 return the children to
the father at 3:00 p.m. that day to co"",,ence his week with the children.
1
.JODI L. YOHN, ) IN THB COURT OF COKMON
Plaintiff ) PLBAS OF CUMBBRLAND
) COUNTY, PBNNSYLVANIA
vs. )
) NO. 94-~334 CIVIL TBRM
DBNNIS F. YOIIN, )
Deflmdant ) CUSTODY
.JUDGE PRBVIOUSLY ASSIGNBD: None
CONCILM1!m_QlNPIlRJlN~!!n!.\!HHM!!. IBfQlT
IN ACCORDANCB WITH CUMBBRLAND COUNTY RULE OF CIVIL PROCBDURE 1915.3-8Ib), the
undersigned Custody Conciliator submits the following report:
1. The pertinent inforlllation concernin'l the children who are the subject of this' ,
, litigation is as follows:
NAME
BIRTHDA1'E
CURRENTLY IN
CUSTODY OF
Taryn Yohn
.Joden Yobn
'/ June 1982
23 June 1984
Defendant/Father
Defendant/Father
2. A Conciliation Conference was held on 26 October 1994 and the following
"individuals were present: the Plaintiff and her attorney. Thomas M, Kutz, Esquire; the
Defendant and his attorney. Cara Boyanowski. Esquire.
3, Items resolved by il'lreement: Shared legal custody and a telllporary order.
4. Issues yet to be resolved: Primary physical custody, which is requested by
both parties, and a custody schedule,
5. 'fhe Plaintiff's position on custody is as follows: 'fhe mother wants prilllary
physical custody and believes the children will be better with her.
6. The Defendant's position on custody is as follows~ The father wants priMary
physical custody and believes the children are better off with hiM,
7. Need for separate counsel to represent children: the conciliator sees no need
for independent counsel tor the children and neither party made such a request to the
conciliator.
8. Need for independent psychological evaluation or counseling: the conciliator
sees no specific need for independent counseling and neither party requested it,
9, Other matters and COMments:
The parties separated in June of 1994 when the mother left the hOlle. The children
have been with the tather since then but apparentiy have had liberal time with both
parents.
'file parties acknowledged, at the very beginniny ot our conference, that each party
was fit to care for the children and that neither of thelll had any reason to Challenge
the fitness of the other. Although lhey had some dllticulty communicating at our
conference, they did both say they were able to communicate effectively about the
children and I believe that trom whitt ( saw.
'fhe parties agreed to a telllporary order in which they share physical custody of
the children on a week-to-week basis. I persuaded them to try lhat until a hearing
could be held with the hope that tlley could work out a permanent custody plan from tile
start.
The teMPorary order gets lhe parties throuqll the end of the year. Hopefully, by
January. the parties will see if tllis shared custody arrangement works and will either
agree to extend it or negotiate a lIoditication of it whicll will satisfy tllell.
vs.
)
)
)
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)
)
)
IN THB COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO, 94-5334 CIVIL TERM
CUSTODY
JODI L. YOHN,
Plaintiff
I'
:DBNNIS F. YOHN,
Defendant
I
I'
I
"
ORDU
il
AND NOW, this
day of
, 1994, upon receipt of the
conciliator's report, it appearing that the parties have agreed to the terms and
provisions of this order which was dictated in their presence and approved by them and
their counsel, we hereby order as follows:
l. Legal custody of the minor children. Taryn Yohn, born June 7, 1982, and Jaden
'iYohn, born June 23, 1984, sball be shared by their parents, the Plaintiff, Jodi L.
Yohn, and the Defendant, Dennis F. Yohn.
2. The parents shall sbare physical custody of the children on the following
schedule, pending further order of this court:
A. The children shall be with the mother from 5:00 p.m. on Sunday,
October 30, 1994, through 5:00 p.m. on Sunday, November 6, 1994.
B. The father shall then have the children from 5:00 p.m. on Sunday,
November 6, 1994, through 5:00 p.m, on Sunday, November 13, 1994.
C. The parties will alternate physical custody of the children on a
week-to-week basis thereafter with the exchange to be at 5:00 p.m. on Sunday.
D. For the Christmas holiday of 1994, the mother, who will have
physical custody on Sunday. December 25. 1994, will return the children to
the father at 3:00 p,m. that day to commence his week with the children.
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JODI L. YOHN, t IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff I
t CIVIL ACTION - LAW
v. t
t NO. 94-5334 civil Term
DENNIS F. YOHN, I
t
Defendant I CUSTODY
CU8TOf; ORDIR
AND NOW, this l '> day of , 1994,
upon consideration of stipulation of JODI L. YOHN, hereafter
refered to as the Mother, and DENNIS F. YOHN, hereafter refered
to as the Father, concerning the custody of their minor children,
Taryn Yohn, born June 7, 1982, and Joden Yohn, born June 23,
1984, the following Custody Order is entered:
1. Legal custody of the both children shall be shared
equally by the Mother and Father.
2. The Father shall have primary physical custody of
both children.
3. The Mother shall have visitation and/or partial
physical custody rights to the children as follows:
a. on alternating weekends from Fridays at 5:00
p.m. to Sundays at 5:00 p.m. beginning with the weeKend of
December 16th through December 18th, 1994,
b. during the weeks following the Father's wee.kend
custody the Mother shall be entitled to a mid-week visit from
5:00 p.m. to 8:30 p.m.; the day of the week for such mid-week
visits shall be determined by the Mother and Father no later than
7:00 p.m. on the Sunday preceeding said visits.
4. Physical custody of the children for Christmas
1994, shall be shared as the parties agree; the Mother,
neverless, shall have physical custody of the children for no
..
.
le.. than four consecutive hours during the hOliday.
5. The Mother and Father shall permit reasonable
telephone oontact between the children and the non-custodial
parent.
6. The Mother and Father shall notify the other of all
medical care either child receives while in that parent's
custody. Each parent will notify the other immediately of
medical emergencies which may arise while the children are in
that parent's care.
7. The Mother and Father shall, at the end of their
children's 1994-1995 school year, determine an appropriate
oustody arrangement for their children's summer vacation from
school.
8. The Mother and Father, by mutual agreement, may
vary from this agreement at any time but this Order shall remain
in effect until either parent petitions to have it modified or
changed.
By the Court:
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JODI L. YOHN, I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff I
I CIVIL ACTION - LAW
v. I
I NO. 94-5334 civil Term
DENNIS F. 'lOHN, I
t
Defendant t CUSTODY
8TIPULATIOH or PARTII8 RIGARDIHG CU8TODY
THIS STIPULATION, is made this I',?-\h day of December, 1994,
between JODI L. YOHN currently of Mechanicsburg, Cumberland
County, pennsylvania, hereafter referred to as Mother and DENNIS
F. YOHN of Carlisle, Cumberland County, Pennsylvania, hereafter
referred to as Father. The Mother represented by Thomas M. Rutz,
Esquire, the Father represented by Cara Boyanowski, Esquire.
WHEREAS, the above-named Mother and Father had born to them
the following children on the following dates:
TARYN YOHN
born: 7 June 1982
JODEN YOHN
born: 23 June 1984
WHEREAS, the Mother and Father having attended a concilation
conference on October 26, 1994, before Samuel L. Andes now desire
to enter into an Agreement as to the custody of their children
and to the visitation or partial custody rights of the non-
custodian parent.
NOW THEREFORE, to effectuate this desire, the Mother and
Father hereby agree to the entry of an Order providing the
following:
~
1. Legal custody of the both children shall be shared
equally by the Mother and Father.
2. The Father shall have primary physical custody of
both children.
3. The Mother shall have visitation and/or partial
physical custody rights to the children as followsl
a. on alternating weekends from Fridays at 5tOO
p.m. to sundays at 5:00 p.m. beginning with the weekend of
December 16th through December 18th, 1994,
b. during the weeks following the Father's weekend
custody the Mother shall be entitled to a mid-week visit from
5100 p.m. to 8:30 p.m.; the day of the week for such mid-week
visits shall be determined by the Mother and Father no later than
7100 p.m. on the sunday preceeding said visits.
4. Physical custody of the children for Christmas
1994, shall be shared as the parties agree; the Mother,
neverless, shall have physical custody of the children for no
less than four consecutive hours during the holiday.
5. The Mother and Father agree that reasonable
telephone contact between the children and the non-custodial
parent will be permitted.
6. The Mother and Father agree that each will
notify the other of all medical care either child receives while
in that parent's custody. Each parent will notify the other
immediately of medical emergencies which may arise while the
children are in that parent's care.
7. The Mother and Father agree that at the end of
JODI L. YOHN,
Plaintiff
IN 'I'HI': COURT OF COMMON PLEAS OF
CUMBI':RLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94-53]4 civil Term
v.
DENNIS Y, \lOHN,
Defendant
CUSTOD\I
CUSTODY ORDIlR
AND NOW, this I l (I, day of ;.. ...., ".............. , 1994,
upon consideration of stipulation of JODI L. YOHN, hereafter
retered to as the Mother, and DI':NNIS F. 'iOHN, hereafter refered
to as the Father, concerning the custody of their minor children,
Taryn'iohn, born June 7, 1982. and Joden \lohn, born June 23,
1984, the following custody Order is entered:
1. Legal custody of the both children shall be shared
equally by the Mother and Father.
2. The Father shall have primary physical custody of
both children.
3. The Mother shall have visitation and/or partial
physical custody rights to the children as follows:
a. on alternating weekends from Fridays at 5:00
p.m. to Sundays at 5:00 p.m. beginning with the weekend of
December 16th through December 18th, 1994,
b. during the weeks following the Father's weekend
custody the Mother shall be entitled to a mid-week visit from
5:00 p.m. to 8:30 p.m.; the day of the week for such mid-week
visits shall be determined by the Mother and Father no later than
7:00 p.m. on the Sunday preceeding said visits.
4. Physical custody of the children for Christmas
1994, shall be shared as the parties agree; the Mother,
neverless, shall have physical custody of the children for no
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JODI L. YOHN, ) IN THE COURT OF COMMON
Plaint! ff ) PI,BAIl OF CUMBERLANIl
) COUNTY, PENNS Yl,v AN I A
VB. )
) NO. 94-5334 CIVIL 'rERM
DENNIS F. YOHN, )
Delend,lnt ) CUWrODY
'"" N<N "I'};(~ 0'
p ~.Q.UIlT
, 1995, a hearing is hereby scheduled in
I the above matter to be held in Court Room No. 2_ o( the cumberland cO~lty Court House
in CarliBle, Pennsylvania, commendnq at __'1._,2.1/__.. o'clock !J;m., on !f~;',1/(~0~(j-',~,
2. 'IV
!. the _ ' 'I _day ot__1.E7'_': !!_4!_L-:'__, 1 <J95.
!I Counsel tor e,lch ot the parties in directed to till! with the Court and 5.~rve llpon
i'
opposing eoullsel, at leolBt twenty (20) days l,rior to the datI> ot the hearing, a list of
witnesses they intend to call at tlll! hearinlJ, which list uhall indlldf> the name,
address. daytime and home phone numbl~r ot the wi tnes5, and a <}(!ner,ll 51l1nmary o( the
nature of the witnes5'5 te5timony.
If either party intend5 to eall a p5ychololJist or other expert witness. they
shall provldn to the other party, through their counsel, the (ollowing information at
least twenty (20) days prior to the hearing:
(a) The name, address, and daytime telephone number of the expert
w itnesB;
(b) A list of the expert's qualifications; and
11
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(Q) ~ written report of the oxpert's findingB in the case, specificallY
including any reCOmllll!l\l\ationll he or Illle will make to tho court and any
conclusions drawn (rom tho expllrt'B work.
T~o~as Kutz, Esquire
Attorney for Plaintiff
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Robert MUlderig, Esquire
I,~ttorney for Dafen~ant
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JODI L. YOHN, ) IN THB COURT OF COMMON
Plainti ff ) PI,EAIl OF CUMBERLANIl
) COUNT'i, PENNSYLVANIA
VI;. )
) NO. 94-5334 CIVIl, 'rERM
I DENNIS F. YOHN, )
Defendant ) CUSTODY
,
i, JUDGE PREVIOUSLY
I.
,I
"
ASSIGNED: T~e Honorable George E. Hoffer
l;Q.Iir.IlJJ~TOR CONl'B!lt~r.!U.U~~RY !l~QJ~'l'
IN ACCORDANCE WITH CUM8ERLAND COUN'ry RULE Of' CIVIl, PROCEDURE 1915.3-8(b), the
! undersigned CUlIlody Conciliator lIubmltll the following report:
1. The pertinent information coneernlng the children who are the subject of thiB
litigation is as followlI:
NAME
m'l'_~lll\.'!'ll
CURRENTI,Y IN
CUSTODY. OF
Delendant/Father
Defendant/Father
. Taryn Yohn
Joden Yohn
7 June 1982
23 June 1984
2. A Conciliation Conference was held on l2 September 1995 and the following
individuals were present: the Plaintiff and her attorney. Thomas Kutz, Esquire; the
Defendant and hill attorney. Robert Mulderlq, Esquire.
3. Items resolved by agreement: None
4. Issues yet to be resolved: Legal custody. primary physical custody, and a
custody sehedule.
5. 'rhe Plalntlff's pCHlition on custody is as follows: The mother claims that she
allowed the father to have primary physical custody of the children in December of 1994
only because she did not, at that time. hdve d sultabll! place for till,"! to live. She
has corrected that problem and is now livinq with her brother In a 4-bedroom house in
Meehanicsburq where each of the children would have their own bedroom. She also claims
1
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that the older child has a stronlJ prel~rence 10 re81do with her. Finally, nhe contends
I th,lt the father and hpr nHW ljlritrillllll al'l! not Iu'ol)(lr pOlrenls lor the children.
1\. The Delend;IIII's Illlsitlon IlII l'uIIl.ody is ;\s lollows: The lather contends thilt
I
:1 the pr~sent order IIhould re"~in hpl'aullu Ih~ molher cannot propurly control and care (or
i,
thp children. He dilimB Bill: lIo1d 0111 opportunity to do Ih;\1. prior to the December, 1994,
order and simply conld nol do II.
7. Nel:d lor Bellill'illl' l'ounnel 1.0 l'I'prr!/H'nt children! the concili;ltor sees no need
lor indl'pendelll connn,d for tlll' cll i I dr~n ilnd lie i I hur pOlrt y mold(' HIICh ., rp.quest to the
conc1liiltor,
8. Need (or independp.nl. psycholo,!icOII t'v,tluOItlon or coulIlleling: the conciliator
seen no specilic need lor independent counBellnlJ and neither party requested it.
9. Other matters ilnd comments:
One potl!ntlill problem in the COlS" iB the school dintrict lor the children. They
currently attend the Cllmherland Valluy School Dintrict but will have to change school
districtu next year II they continu" to reBide with the lather at his lJirllriend's
home. The mother residen in the CumberlOlnd Valley School DiKtrict but, because of her
location, the children would hilV!: to chanlJe Kchools within the school district by next
'September il they lived with hur.
l' was able to mak" no headway in negotiating a settlement of the case because of
the extreme bitterneHs ilnd hOBti lity of the parties. I am afraid a hearing will be
neces8ary. I have prepar"d an ord"r RchpdllllnlJ a hearing so that the court can do that
2l September 1995
ue J". AndeB
Custody Conciliator
2
JODI L. YOHN, ) IN THB COURT OF COMHON
Plaintiff ) PLEAS OP CUHBBRLAND
) COUNty, PENNSYLVANIA
VB. )
) NO. 94-~334 CIVIL TBRH
DENNIS P. YOHN, )
Defendant ) CUSTODY
OIlDn OF COURT
AND NOlI this
day of
, 1995, a hearing iB hereby scheduled in
the above matter to be held in Court Room No. __ of the Cumberland County Court House
in carliBle, PennBylv8nia, commencing at
o'clock _.m., on
-'
the
day of
-'
1995.
CounBel for each of the partieB is directed to file with the Court and Berve upon
,
opposing counsel, at least twenty (20) daYB prior to the date of the hearing, a list of
witnesBes they intend to call at the hearing, which list shall inclnde the name,
addreBs, daytime and home phone number of the witness, and a general summary of the
nature of the vitnesB'B teBtimony.
If either party intends to call a psychologist or other expert witness, they
shall provide to the other party, through their counsel, the following information at
leaBt twenty (20) days prior to the hearing:
(a) The name, address, and daytime telephone number of the expert
witnesB;
(b) ^ liBt of the expert's qualifications; and
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JODI L. YOM, I IN THI COURT or COMMON PLIAS
plaintiff I CUMBIRLAND COUNTY, PINNSYLVANIA
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Y. I NO. 94 - 5334 CIVIL TIRM
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DIDIS r. YOHH, I CIVIL ACTION - LAW
Defendant I CUSTODY ACTION
PITITION TO MODIry CUSTODY ORDIR
TO THE HONORABLI JUDOIS or SAID COURT I
1. The Plaintiff is Jodi L. Yohn who lives at 3 Donald
Street, Mechanicsburg, Cumberland County, PA 17055.
2. The Defendant is Dannis F. Yohn who lives at 8 Meadowview
Drive, Carlisle, Cumberland County, PA 17013.
The Plaintiff seeks to Modify the Order dated November 2, 1994
by incorporating the actually current custody arrangement which is
that Plaintiff has primary physical custody of both of her
children, subject to Defendant's periods of temporary physical
custody.
Respectfully submitted
~D,~
Thomas D. Gould, Esquire
ID #36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
Fax 761-1974
NOV 0 1199+ cl~
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IN THE COURT Of COMMON
PLEAS Of CUHBERLAND
COUNTY, PENNSYLVANIA
L, YOHN,
Plaintiff
II ;:: DENNIS f. YOHN,
Defendant
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!:conciliator's report, it appearing that the parties have agreed to the terms and
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NO. 94-5334 CIVIL TERM
CUIlTODY
QMD.BR
AND NOW, this rJ. ~ day of
-n 6V" .
, 1994, upon receipt of the
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::provisions of thiB order which waB dictated in their presence and approved by them and
, their counsel, we hereby order as folloWB:
1. Leqal cUBtody of the Minor children, Taryn Yohn, born June 7, 1982, and Joden
iiYohn, born June 23, 1984, shall be Bhared by their parentB, the Plaintiff, Jodi L.
iiYOhn, and the Defendant, Dennis P. Yoho.
2. The parents shall share physical cUBtody of the children on the following
'schedule, pending further order of this court:
A. The children shall be with the Mother from 5:00 p.m. on Sunday,
October 30, 1994, through 5:00 p.m. on sunday, November 6, 1994.
B. The father shall then have the children from 5:00 p.~. on Sunday,
November 6, 1994, through 5:00 p.m. on Sunday, November 13, 1994.
C. The parties will alternate physical custody of the children on a
week-to-week basis thereafter with the exchanqe to be at ~:OO p.m. on Sunday.
D. por the Christ.as holiday of 1994, the .other, who will have
physical custody on Sunday, December 25, 1994, will return the children to
the father at 3:00 p... that day to commence his week with the children.
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3. This order is intended to be temporary only and will be reviewed and modified
lias appropriate at a hearing to be held before the undersigned in Court Room No. ~ of
lithe Cumberland County Court House in Carlisle, PennBylvania, comMencing at
:1 If
I o'clock e.m., on ~, the IS:tl. day of .f\JN...J~ , 19V.
I The parties, through their counBel, will exchange lists of witneBseB they intend to
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I!call at hearing, at least twenty (30) days prior to the hearing. such witneBs list
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Ilshall identify the witness by name, addreas, and both daytime and evening telephone
i!numbers and shall provide a brief description of the expected testimony of the witness.
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i' By the Court,
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II Thomas H. Kutz, Esquire
II Attorney for Plaintiff
Ii Cara Boyanowski, Esquire
I Attorney for Defendant
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T~U: rr;f)\1 '="'"'M RECORD
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n T,st,n:~n'! ';iJ'r::', I h.'r} Ilcto set my hand
and the $"al Oi ;.;,d Court at Car/isle, Pa.
This ,,,..2.'~", day of ,'J]6Y:.'';'' 19j!t.
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, "l.)ii- . Prothonotary
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JODI L. lrOllN, I IN THE COURT OF COOMOO PLEAS OF
Plaintiff I CUMaE:RLAND COUNTlr PENNSlrLVANIA
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VB. I CIVIL ACTION - LAW
. NO. 94-5334
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DENNIS F. lrOllN, I
Defendant I IN CUS'roDlr
QUlBR Of' CXlJRT
AND tuf, this .'30th day of July, 1996, the Conciliator beill9
advised by counsel for both parties that the parties have resolved all
custody issues by agreement, hereby relinquishes jurisdiction in this case.
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L, i'L ^ / ,J(, fIe') O~
Dawn S. Sunday, Esqui'r
Custody Conciliator
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or n'~TMY
96 Arm -] Al'" I PiS
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CUMULI~lj>;\D ~vUNTY
o PeNNSYLVANIA
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JODI L. YOHN, I IN THE COURT OF COMMON PLEAS
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
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v. I NO. 94 - 5334 CIVIL TERM
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DIIIlNIS r. YOHN, I CIVIL ACTION - LAW
Defendant I CUSTODY ACTION
CUSTODY AGREEMENT
THIS AGREEMf:NT, made this L day of A~-I-
and between Jodi L. Yohn, hereinafter referre~to as
Denni. r. Yohn, hereinafter referred to as Father.
, 1996, by
Mother, and
WITNESSETH:
WHEREAS, Mother and Father are the parents of Taryn Yohn, born
June 7, 1982, and Joden 'iohn, born June 23, 1984; and
WHf:REAS by order dated November 2, 1994 Mother and Father
share legal and physical custody of the children subject to
alternating weeks of physical custody; and
WHf:REAS, Mother filed a petition To Modify Custody Order on
June 13, 1996 and a custody conference has been scheduled for July
30, 1996; and
WHEREAS, Mother and Father wish to enter into this Custody
Agreement to settle and resolve the outstanding issues regarding
the custody of their children;
NOW THEREFORE, it is agreed by the parties that:
1. Mother and Father shall share legal custody of the
children, which means that each party is to have equal access to
the children's personal, school and medical records and each party
is to inform the other of significant events that occur in the
children's lives. Each parent shall have access to medical, dental
and school records;
2. The parties shall share physical custody of the children.
a. Mother shall have primary physical custody of Taryn
subject to Father's periods of temporary physical custody on
alternating weekends from Friday at 6:00 p.m. until Sunday at 7:00
p.m. throughout the year.
b. Father shall have primary physical custody of Joden
subject to Mother's periods of temporary physical custody on
alternating weekends from Friday at 6:00 p.m. until Sunday at 7:00
p.m. throu1hout the year.
c. It is the intent of the parties that weekend periods
will be coordinated so that the children will spend the weekend
periods at the same parent's home.
d. During the sununer, which shall conunence on the first
Saturday following the close of the school year and shall end one
(1) week prior to the resumption of the school year in the Fall,
each parent shall be entitled to a total of four (4) weeks of
uninterrupted periods of custody, but no more than two (2)
consecutive weeks. f:ach parent shall give the other a minimum of
30 days notice of his/her intention to exercise their respective
weeks of custody. A weekly period must include the regularly
scheduled weekend to have custody of both children and shall run
from Friday at 6:00 p.m. until Friday at 6:00 p.m..
e. Notwithstanding the schedule set forth above, the
parties shall share Thanksgiving and Easter. Mother shall have
the children on Mother's Day and Father shall have the children on
Father's day each year from 9:00 am. until 7:00 p.m..
f. During the children's Christmas vacation, Mother
shall have physical custody of the children in even years from 1:30
p.m. on December 25th until 7:00 p.m. on December 26th, and in odd
years from 10:00 a.m. December 24th until 1:30 p.m. on December
25th. Father shall have physical custody of the children in odd
years from 1:30 p.m. on December 25th until 7:00 p.m. on December
26th, and in even years from 10:00 a.m. December 24th until 1:30
p.m. on December 25th.
g. Mother and Father agree to consider the wishes of
the children regarding their individual desires as to physical
custody, however, the final decision shall be made by mutual
agreement of Mother and Father.
3. Both parents understand the need to provide a loving and
stable environment for their children.
4. The primary physical custodial parent agree>; to encourage
contact between the child and the other parent.
5. Mother and Father agree to place their personal
differences aside and work for the best interests of the children.
6. The parties shall provide for reasonabltl teJ.ephone access
to the children.
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