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HomeMy WebLinkAbout95-00483 1" ,. ,,' ',-1 :,') , ' " \. . ~: (i.'< , " , .; .;,' I,' , ';1 ~ i .,:' J , '. , . ,...~ z0 oJ '. " ,~~1. " ,;.~ ,CY) Do :J: , , . . I . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD R. BARRICK, Plaintiff CIVIL ACTION -LAW IN CUSTODY v. SUSAN J. FLORENTINE, Defendant NO. 95- "'I'ff3 (!~t,J ~f.''1 AND NOW, this ORDER OF COURT 1St- day of ~l,,,,""c'r\./ , , 1995, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel shall appear before O',u''''l C;,u.Ao.'/ . the Conciliator, at . l...J. M...ir\ 5 ~. 1VJ(.:>("JC<l'li."l,v.....) - \'V\w-th , 1995 at 10: 3tJ17 .m., for a Pre- s<1. ~t\~ on the day of 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. FOR THE COURT, By: '~1~~e~. cu ody conc 1 ator '.PJ 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 ADMINISTRATOR COURTHOUSE, 4TH FLOOR Carlisle, PA 17013 (717) 240-6200 fEU I J dJ ;';I'~5 .. i)' /1S' Copa <.:} , /. ?!/ COP'I ,,~., Q.5' Copy IW~OCC( t6 c..~11 fJa..p t\,o.Jt.l to c/J 1Y\;.Jul -{b " <QI.v1,.J'(t . It . c.\wcv.n..lDITI"aAIIJ.X"UC1l1Tnt1'l't'tlW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD R, BARRICK, CIVIL ACTION -LAW Plaintiff IN CUSTODY v, SUSAN J. BARRICK, NO, 95- Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland county Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y arCh!""!:' en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualguier queja 0 alivio que es , . . (:\wcw.1.tnnT'&UJJlU'Ct'lTunY ('uN pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiendades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. 51 NO T1ENE ABOGADO 0 SI NO TIENE EL DINERO 5UF1CIENTE DE PAGAN TAL SERVICO, VAYA EN PERSONAL 0 LLAME POR TELEFONO A LA OFIC1NA CUYA DIRECC10N SE ENCUENTRA ESCR1TA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGU1R A515TENC1A LEGAL. Court Administrator Cumberland county Courthouse 1 Courthouse square Carlisle, PA 17013 (717) 240- 200 r la C. Vohs, Esqu re Attorney 10 No. 65208 11 West Pomfret street, suite 2 Carlisle, PA 17013 (717)249-5373 Attorney for plaintiff ... r elwt'W:lllHTr.AlJJCDlC\'ITODy.a.... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD R. BARRICK, Plaintiff CIVIL ACTION -LAW IN CUSTODY v. SUSAN J. FLORENTINE, Defendant NO, 95- COMPLAINT FOR PARTIAL CUSTODY () It AND NOW, this ~ day of :r-~n~~ Plaintiff, Richard R. Barrick, by and t~Ugh , 1995, comes his attorneys, The Law Offices of Michael J. Hanft, and files the following complaint for Partial custody and in support thereof avers as follows: 1. The Plaintiff is Richard R, Barrick, an adult individual residing at HHC 53d ASG. CMR 438, Box 1454, APO AE 09111 (West Germany) . 2. The Defendant is Susan J. Florentine, an adult individual residing at 47 West Keller Street, Mechanicsburg, Cumberland county, Pennsylvania. 3. Plaintiff seeks partial custody of the following children: ~ Shawn A. Barrick Present Address Aqe Joshua B. Barrick 47 W. Keller st., Mechanicsburg 8 47 W. Keller st., Mechanicsburg 6 .. I t'.\wcw.1JOnW'AAkJlCUn'lTUbY.l"llW The children were not born out of wedlock. The children are presently in the custody of Defendant, Susan J. Florentine, who resides at 47 West Keller street, Mechanicsburg, Pennsylvania, The past five (5) years, the children as resided with the following persona and at the following addresses: Persons Address Dates Susan Barrick, Thomas 47 W. Keller st" Mechanicsburg Murry, and 2 minor children 6/94 to Present Susan Barrick New Bloomfield, PA Susan Barrick New Buffalo, PA Richard R. Barrick Anniston, Alabama and Susan Barrick 2/92 to 6/94 4/91 to 2/92 4/89 to 4/91 The mother of the children is Susan J. Florentine, currently residing at 47 W, Keller street, Mechanicsburg, Pennsylvania, She is single. The father of the children is Richard R. Barrick, currently residing at HHe 53d ASG, CMR 438, Box 1454, APO AE 09111 (West Germany) . He is married. 4. The relationship of Plaintiff to the children is that of father. The Plaintiff currently resides with his wife and her children, Nicholas, Laura Beth, and Leigh Ann. 5, The relationship of the Defendant to the children is that of mother. The Defendant currently resides with the children, her boyfriend Thomas Murry, and his two children. 2 .. I C1W't"W'UlNn'..,.aJ;k....It'\ll1\JIIYnlW 6. Plaintiff has participated as a party in other litigation concerning the custody of the children in the Court of Common Pleas of perry county at 91-1376, which was a divorce proceeding, the final decree of which incorporated an Agreement, a copy of said decree and Agreement is attached hereto and made a part hereof, and marked as Exhibit "A". Other than the aforementioned divorce decree, the Plaintiff has no information of a custody proceeding concerning the custody of the children in this or any other court. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interests and permanent welfare of the children will be served best by granting the relief requested because: a) The Plaintiff is the natural father of the children; b) The Plaintiff is currently enlisted in the United states Army, stationed in West Germany; c) The plaintiff can provide a home with adequate moral, emotional and physical surroundings as required to meet the children's needs; c) The Plaintiff is, and has always been, willing to accept partial custody of the children; and d) The Plaintiff, as the children's father, provides the 3 , . .. '. C\Wl"W;1JI!)(T1lJlAlJK"U'.c\-'noor en., children with love, affection, and care. S, Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. There are no other persons who are known to have or claim a right to custody or visitation of the child. WHEREFORE, Plaintiff respectfully requests Your Honorable Court grant Plaintiff partial custody of the children. Respectfully submitted, HANFT W 1 am C. Vohs, Esqu re Attorney ID No. 6520S 11 W. Pomfret street, suite 2' Carlisle, PA 17013 (717) 249-5373 Attorney for Plaintiff 4 .. *. verification I verify that the statements made in the foregoing complaint for Partial custody are true and correct to the best of my knowledge, information and belief. This Verification is made only as to the factual averments contained herein, and not to legal conclusions and averments authored by counsel in his capacity as attorney for the party or parties hereto. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. section 4904, relating to unsworn falsification to authorities. v -~\\ ~, Richard R. Barrick . . .... '. IN TIlE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF ',,"'ii':, :;",',,',,':; PENNSYLVANIA, PBRRY COUNTY BRANCH ..., SUSAN.'J ~','BARRICK; . CIVIL ACTION - DIVORCB . Plaintiff : . . v. . No. 91-1376 . . . RICHARD R. BARRICK, . . Defendant . . DECREB AND NOW, July 2 , 1992, it is ordered and decreed that SUSAN J. BARRICK, Plaintiff, and RICHARD R. BARRICK, Defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of for those issues specifi- cally reserved as set forth in the Agreement dated May 28, 1992, executed by the said Susan J, Barrick, and Richard R. Barrick, a copy of which is attached hereto, and which said Agreement is incorpo~ated herein by reference. BY THE COURT: 1s/ KEI~:......9.UIGLEY P. J. I, William M. Templeton, Prothonotary, do hereby certify that the foregoing is correct, and a true copy of the Decree entered in the above entitled case, Clerk , ~;~~ty pr tho notary . . , ' " '" , , AGREEMENT This agreemont datod tho 28th day of May, 1992, by and between SUSAN J. BARRICK. party of tho first part. and hereinaf- ter referred to os "Wifo" or "Mother", and RICHARD R. BARRICK. party of the second part. and hereinafter referred to as "Hus- band" or "Fathor". W ITNESSE'l'1I WHEREAS. tho pC\I.ties hereto al'e Husband and Wife. having boon mardod on O.:lobol' In. 1905. and al'e the parents on two (2) childron. OEllnl.ll;'. f'ihawn A. BUI.J'ick, bOl'n on Mfu'ch 4, 1966, and Joshua B. Barrick. born on Junu 3D. 1988: and WHEREAS. tho parties hove resolved that it is impossible to continue the marital relationship between them for reasons known to them: and WHEREAS. Wife has filed suit for divorce from the matrimony in the Court of Common Pleas of the 41st District of Pennsylvania. Perry County Branch. at No. and bonds of Judicial 91-13;6: WHEREAS, the partiou desire to make arrangements in connec- tion with tholr anticipated divorce. including tho settlement of theil' propert~. rishts,' tho custod~' and support of their child:'en and other rishts and obliGations urisins out of their marital relationship; end WHEREAS. both Huobend and Wife hove been full:r. seperately find indapolldQllt ly advisllu of his ClI' hOI' logal rights and oblisa- tions. flnd each ht's fully and completely disclosed to the othel' his or her property holdings end illcomc; and WHEREAS. both Husband and Wife fully understand all the terms. conditions, end provisions of this asreement and believe it to be fair. Just. adequate. and reasonable as to each of them and. voluntarily accept such terms, conditions and provisions. NOW THEREFORE. in consideration of the mutual heroin containod. the parties horeto. intend ins to bound horeby. aAroo as follow~: covenants be I oga 11 y '.' .. '. . . I, The parties may and shall continue at all times to live aepal'ate and apal.t fl'om eech othel'. free from interfel-ence or control by the other..as fully aa if he or she were sihgle and unmarried. Each may hereaftAr realde at such place anywhere in the world nnd engage in any employment. dcdup~tion. business or trude. which either mu~' deam fit, free from any interfel'ence or contr~l, direct or indirect. by the other in all respects as if , he or ahe were aingle and unmarried. Both agree that he or ahe shall not alienate the affections or attempt to alienate the 'affoctions of their children from the other. 2. Husband and Wi fe a~I'ep. that each will pay the outatanding debta incurred on or before the date of the sepF.ll'ntion: following parties' a. Husband: (1) The balance due Service Fenaral Credit Union in the approximate amount of 56.000.00 on the 1988 Nissan automo- bile. Husband shall hold wife safe and harmless from any liabil- Ity thereon. The aforesaid automobile is titled in Huaband'a name. and sholl be his sole and separate property. tha safl.! (2) The balance due on the Montgomery Ward approximate amount of 52.000.00. Husband shall and harmloss from any liability thereon. chal'ge in hold Wife (3) The balonce due o~ the Soars/Discover account(s} in tho approximate om9unt of 51.500,00. Huaband shall hold Wife safo and harmless from any liability thereon. (4) The balance of approximately Bo:;cov'a account in Joint names. Husband shall nnd hRrmluGs from unr liability thereon. 5875.00 on hold Wifa the safe Jowelol.s' from nn:; (5) The balancc of aCCOLln t. Huabrnd liability thereon. approximately $500.00 shall hold wife safe on the Go~don anc! harmless (6) The balancc of approximately 570.00 on tho J. C. Pennoy accoLlnt. Husband shall hold Wife aafe and harmless from any liability thoroon. .2- . \ . . . , . , . .' " ill Wifo (7) The balance due Wife' 5 mothol', Al ico tho amount of 53,002.46 plu!l illtnl'out. Husband safo and hormloss.from any liability thoroon. Flol'ontino. 'unul! hold Excopt auhorcin providod in this paragraph 2, oach of tho partios horoto covonants nnd ugroos thnt ho or sho has not in the paut and will not ut. any timo in the futuro incur or contract'hny dobt. chargo or liubility whatsoevor for which tho othor party. his or her legal represontatives. or his or her proporty or os tate may be como liable: and each of thom further covonants at all times to keop tho other free. harmless and indomnified of and from all debts. charges and liabilities heroaftor contractod by them. 3, The parties horeto agreo that thoy mad tnl pOl'sonal pl'opel'ty to their, mutual personal property in possussion of oach shall and sepurate property upon execution heroof. have divided satisfaction. bo his aI' her the The sole 4 . CUt; tod~' cU!;; tocl~'. timco Q~ Tho purtie~ hereto agroe thnt they shall shore logol of thrd \' children. ~Iother shull na\'o priman" physical ond Futhar shall have partial physical custody at such mutually agreed upon by the partios hereto. , , 5. Mothor agroes that she shall consult with Father with roapect to the education and religious training of the children. any i11n09s 0/' operation. except in an omerg'ency, of the children and other matters of similar importanco affocting the children. Fathel' shall likewiso so consult w'ith tho Mother with rospect to any illness, except in an emorgency. while the children are in his r.ustody. The oducation. dovelopmont, health and well-being of tho children shall at .all times ho tho paramount consideration of Mother and Father. Each parent iurther agrees to keop tho othor paront informed of the child's genoral activities whon in his or her custody. I; . Hund rl,d chi Idl'OIl Father ugrees thut he will pay to Mother the sum of Elm] 110/100 DollEll's (5(;00.00) support oach month fOl' to be paid as Collows: Six the 11. Tho sum of Four Hundred (5400,00) shull be paid in the middlo of from the date horoof foi that purpose. and 00/100 each and evor)' 001101'5 month -3- . . . . , , . . ohall hel'eef b. The OUJl\ ef Twe Hundred and 00/100 Oellaro ($200.00) be pnid at the end ef each and every menth frem the date fer that pUI'peoe'. Father agrees that the aferesaid sums shall be deducted frem his puy, and ferwarded te MDther. Tho parties herete may. by mutual agreement, increase er decrease the ameunt ef menthly suppert payable te Mether. rathel' ngroes thut he will previde Mether with the necessal'Y decuments fer madical, sur~ical. ~ental, and prescriptien cever- age for the children. 7. The parties herete agree that sheuld Father leave the military oervice. Yelher may cemmence an actien fer child suppert befero Lhe upprepriate demeslic rolatiens efficer. Tho mad tnl parti~s herete agree lhat persenal preperly in his er thut he Dr she ha~ ne richt. proporty ef the other. each has his er hel' possession, title er interest her and in pre- each ::aid t&grQe~ persentl1 O. All liabilities en Jeint federal. state er 11.11.101 inceme tax roturns heretofere filed by the parties shall be the respen- sibility ef Husband. 9. The parties herete agree. that Father shall claim A. Dllrricl\ I.Hl a dlJpel~dent fer Federal inceme tax purpeses, that Mether shall claim Jeshua B. Barrick 1.15 a dependent Federnl inceme tax purpeses. Shawn and fer 10. A mudl ficatien er waiv'!I' nf tiny of the previsiens ef thi~ Agreement shall be effective enly if made in writing and executed with the same fermality as this Agreement. The failure ef either party ta insist upen strict perfermance ef any ef ~he previsions ef this Acreement shall not be censtrued as a waiver ef anY subsequent default ef tho same er similar nature. 11. If eithor party defnults in tho due perfermance ef ef the terms, cenditions and cevenants ef this Agreement en er her part ta be perfermed, tho nendefaulting party shall the riKht te suo fer specific perfermance er damages fer eny his heve the -4 - . , , . , . . , . . breach of this Agreement. and defaulting crhall pay the roasonable legal feecr for ony services rendered by the nondefoulting party's attorney in any actidn or pro~eeding to compel the defaulting purty's duo performanc~ hereunder. 12. Each party hus sought separate legal counsel relative to this Agreement:,counsel for the respective parties has ex- plained aaid Agreement to each party; each party fully under- standu all of the terms herein set forth: all of said terms represent and constitute tho entire understanding between the pertles: each party has read this Agreement and finds the same to be in accordance with hicr or her undercrtanding. Each party does hereby voluntarily exacuto lhl~ A~reemont and affixes his or her cri~na tUl'e hel'e to in the pl'esence of the wi tnessecr below. 13. Except as otherwlso provided for herein. each party hereby releaGen nnd dicrchnrgos comp~etely and forever the other from any and ull rights of support, alimony. alimony pondento 11to. counsol f(ltH;, division of pl'opel't).. right of dower and curtsy, richt to uct as administrator or exocutor in the estate of tho othor. rl~ht of distributive share In the other's estate. l'ight of exurnlltlon In thu ~state of tho othel', or any other property rightu, benefits or privileges accruing to either party b)' 'virtue of suid mUl'riago l'elationship, or otherwise. and wheth- er tho samo ere conferred by the statutory law or by the common law of Lho Commonwealth of Penncrylvania, o~ any other state. or lhe common Inw of the United Slales of Ameri~a. It is the under- alandlng bolween the porlies that this Agreement, except as olherwise provided herein. forever and completely adjusts, set- tles and diaposos of, and completely terminates, any and all rights. claims. "l'ivileges Bnd benefits that each now has. or each may have reason to believe each has. against the other. ~rlcrins out or said marrlnge reLationship or oth~rwise, and wheth~r Lhe cornu are conferred by the lews of the Commonwealth of Pennsrlvania. or ony other state. or nf the United States. of America, and which are now or which may hereofter be in force'and effect . 14. Each party chell. at the request of the other party, prompll~ execute any nnd all documents which may require their ciGnaturo for lhu purpoco of effectuating all of the terms and conditions of this Agroemcnt 50 os to sive full force and effect to this Agr~omonL. -5- . . . . . . . " , " 15. It i~ understood and agreod that the hairs, odministro- torn. executors and assigns of the pOl,ties hel'eto sholl be bound b)' all of the terms. conditions and clouses of this Agreement. - 16. All ml.lttol'S offocting the intel'PI'etotion of this AgI'ee- mant and the ri~hts of the porLlos hereto sholl be governed by . , the lows of the Commonwoolth of Pennsylvania. 17. This Aureement sholl be submitted to the Court of Common Pleas of tho 41st Judicial Dintrict, Perry County Bronch. with the rOquAllt that this A.l:I'Oemollt bo incol'paroted into any docre~ in divorue is~ued by tho said Court, it being understood that Lho A~reeml,)nt will survive tha decree in divorce and not be morged into it. IN WITNESS WHEREOF, legally bound hereby, hove thio Agreement tho day and the parties hereto intending to hereunto set their hands and seals dote first above writtan. be to WITNESS,. /.. /:) . ~! /:. Ii ' /:0-/ :.t~~<:t1.'i'~L,-_ 7:;,~<'{:;"':'t"~ />i,'-'~'S"/ . ..f / ~USDn J. Borri{'i (SEAL) ~f~_.\),_~~ -.............. (SEAL) Richord R. Borrick -6- , ~_. .,...,--...... ~ ,'f' i, '.....~~-. -, --- . ~ 1, ' , . . . '" .,._.._..-.~.>>. , " ", --" '... " .,' . ,,', 'f!',," . .' ',' . . . , , . . . .' '. COMMONWEALTH OF PENNSYLVANIA S9. COUNTY OF PERRY On this, the/!.f#- day of May. 1992. before me the under- signed officer, personally appeared Susan J. Barrick known to me. or satisfactorily proved to be, ono of the persons whose name is subscribed to the within instrument. and acknowledged that she executed the sarno for tho purposo thoro in contained. IN WITNESS WHEREOF, I ha\'e set my hand and official seal. ~ , . ~UtJ/". CO~~ONWEALTH OF PENNSYLVANIA COUNTY OF CUPlbe/'bI1J On this. the 'irff day of tJ~. 1992.. personally appeared Richard R. Barrick. known to me. or satisfactorily proven to be. ona of the persons whose name is subscribed to the within instru- ment. and acknowledged that he executed the same for the purpose theroin contained. ss. NOTARIAL SEAL RUBY F. VillARREAL, NOI~ry Public Bloomfield Boro. Perry County. P.. My Commission Expire, Feb. S. 1993 IN WITNESS WHEREOF. J have so~ my hand and official seal. ~~47~- Nor2rlalSoal ~~F\b&J Mt Corrrnis6lOO E>j:iros Ctt ~~ Mf1lT'bcr,Porns'lr.lrlaA.s.scxiaillncA~ - ;-, ~' ~ ~ ~: ::... ~\~ ' (\ - " . ;.:: . ~.~ :~~J-'_' ~.. ~~ :'i '..' ~ \r: ......-, '(' ") ~ ~ ^ ~ ~ ' " ro ~~' i liM ~.~ . !! ~I i iH1. , I ~ -J~~ , ~5~ . J iii " ~I~ I i~ ~ i!i ~ :> , . .. - ~ , , , .. RICIIARD R. BARRICK, Plaintiff IN TH8 COURT OF COMMON PL&AS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 95-483 CIVIL TERM SUSAN J. FLOR8NTINE, Defendant CUSTODY AND NCM, this consideration of the and directed as follows: 5,,~ ORDER OF COlJR'r day of AJ J, ~JA Custody dn~~~\eport, , 1995, upon it is ordered 1. The Mother, Susan J. Florentine, and the ~'ather, Richard R. Barrick, shall have shared legal custody of Shawn A. Barrick, born March 4, 1986 and Joshua 8. Barrick, born June 3D, 1988. 2. The Mother shall have primary physical custody of the minor Children. 3. The Father shall have partial physical custody of the Children for seven (7) consecutive weeks every summer, beginning at least one week after the end of the school year and terminating at least one week prior to resumption of the new school year in the fall. (a) With regard to the Father's period of summcr partial custody in 1995, the Children shall be accompanied by an adult, with whom they are familiar, on their flight to Germany, where the Father is currently stationed. It is anticipated that the Children also will be accompanied by an adult, with \/hom they are familiar, on the return flight to the United States. However, if these arrangements are not feasible, the Children shall return to the United States on a direct flight with supervisory assistance by the airline having been prearranged by the Parties. (b) The Father shall be responHible for all transportation expenses (including those incurred by the adult(s) accompanying the Children during airline travel) related to his period of partial custody in 1995. Thereafter, transportation expenses shall be allocated by the mutual agre~ment of the Parties. (c) This summer partial custody schedule shall continue for so long as the Father is stationed outside the COllI11Onwealth of Pennsylvania through his service in the United States Army, Upon the Father's relocation in the Commonwealth, the Parties shall review the foregoing partial custody arrangements for the purpose of accomodating the Father's change in residence by mutual agreement. If the parties are unable to agree on revised partial custody arrangements, the Parties may petition the Court to have the case again scheduled with the Custody Conciliator for a Conference. 4. The Mother shall provide to the Fathel' copies of all the Children's , report cards, information as to significant developments Idth respect the Children's health and results/reports of all routine medical examinations. The Mother shall also provide periodic updates on the Children's general physical and social development upon request by the Father. 5. The Mother shall continue to promote and cooperate in arranging liberal contact between the Children and their Paternal Grandparents. BY THE COURT, cc: William C. Vohs, Esquire Murrel R. Walters, III, Esquire J, .3/ /JJ~-I' "J.f? ::c >~ "" n .....,.~ " :: . ~ OIJ '..j..... rdlll r \ . .~ I '1 , ~.'.l';.~: . '.\' i: ,:; ;1 ~~ ...t)lll ,..~; ~ ~ ~ i. "'"" l.D .c.. o ... -", ,::!.: - ~ RICHARD R. BARRICK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLANC COUNTY, PENNSYLVANIA Ii I I I' I v. NO. 95-483 CIVIL TERM SUSAN J. FLORENTINE, Defendant CUSTODY CDlCILIATIW CCNFERENCE SlJolMI\RY. REPORT IN ACCORDIINCE WITH CUMBEIUJ\ND altJNTY 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 Shawn~Barrick Joshua B. Barrick BIRTHDATE March 4, 1986 June 30, 1988 CURRENTLY IN CUSTODY OF Defendant/Mother Defendant/Mother 2. A Concilitation Conference was held on March 2, 1995, with the following individuals in attendance: The Mother, Susan A. Florentine with her attorney, Murrel R. Walters, III, Esquire and the Father's counsel, Hilliam C. Vohs, Esquire. The Father, Richard R. Barrick, resides in Germany and was unable to attend the Conference. However, the Paternal Grandmother was present and able to assist in working out' arrangements for the Children to be accompanied by an adult on their flights to and from Germany as provided in the recollllKlnded Order. It is anticipated that the Paternal Grandmother will travel with the Children to Germany. 3. There was no dispute between the Mother and the Father concerning custody. The issue rained by the Parties at the Conciliation Conference focused on specific arrangements for the Father's periods ot' partial custody while he is residing outside of the country. 4. The Parties agreed to entry of an Order in the form as attached. ~ Ecf::;Je Custody conciliator ,117 /9!J Date ,:1 , r ~ . ,,.., f.. r fH'i i ,~~ ~ ' , ! I' '. ' ~~" (q i~E +J r>.1 ::.to U''l ~ c: .. Eli ~:!l I, ~ III U ';l - ~!:: i c..u:>< .... '0 ; = ~ ~ " +J - c: t!~~ I ~~ I; ~! ~ - c: ~.s tj'irl ~~ ,"'il '_ . i'," . t-i:l . I .:! ~, " ~;;: ~ ~8 ~ I ~ 0 \ ... '8 ~ ~B .~ ~ ~'a ~ ~ El m., ~ .s . r.. i;l lJ.ll ~~g ~ E-' ' ~ ~' . ~ ,.., ~ ! H ~e u li! S . '.. .. ( MAR - 8 1995 . ,k.,' . , .' 15:~~ ~. :t2 "I.J~P:.. ,11.=.t_ T:~; ~:,:J. RICHARD R. BARRICK, pIa inti tt IN THE COURT OF COMMON PLEAS OF CUMBERLAlIO COUNTY, PENNS'/LVANIA \. . SUSAN J, FLORENTINE, Defendant NO. 95-483 CUSTODY CIVIL TERM ORDER OF COUR~ \ p'''.'' 'lilt t. "or(~~-\ J CWh"': > AND NOW, this 3ot~ day of June, 1995, it is ordered and ,.. directed that Hother. Susan J. Florentino, ahall moet Frances Barrick on Saturday, July I, 19~5 at 10:00 a,m, in preparation for an airplane f119ht which leaves Harrisburg Airport at 1:30 p.m. The minor children, Shawn A. Barrick and Joshua B. Barrick, shall be prepared for that flight along with clothing necessary for their international airplane flight to Germany where they will spend time with their father, Richard R. Barrick. July 1 Shall initiate Riohard R. Barrick's seven consecutive weeks of physioal custody of the children, which shall end on August 18, 1995. Susan J. Florentine shall be notitied as soon as arrangements for the return airplane flight are made so that she has an opportunity to meet the children upon their return to the United states. By the Court, , , JUN 30 2 14 PH '95 ,i,"!;! ii ""1 )1.. ;..',' j .' f . \', ~ ;.,. ,1,'(',' "Ir !, t ;.:, ." " ~' I .' ,; , ' t;/30/9{" &17 rl4. 7b C. t/;,t d.,htl/f!;-- 7fo:(~ /-t(~:.tJ.,/ 0 7'1. tJc~ fIJ-1LE~'\JJATAFlLE\UENooc:..r..}tI.rRA l\ldw .. Cualld,01fJ7tt'OU1,"AM Itmud: 01lJ1rnOQ<IOG.tAM RICHARD R, BARRICK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 95.483 CIVIL SUSAN J. FLORENTINE, Defendant CUSTODY PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON, DEARDORFF, WILLIAMS & OTTO in behalf of Plaintiff, Richard R. Banick, in the above matter and withdraw the appearance of William C. V ohs, Esquire. MARTSON, DEARDORFF, WILLIAMS & OTTO By 1"~ ) INJt~ Thomas J. Williams, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attomeys for Plaintiff HANFT & VOHS By Willam C. 0 s. Esquire II W. Pomfret Street, Suite 2 Carlisle, P A 17013 (717) 249-5373 Dated: August 11, 1995 , --:",' . . ." .' . ". " .... . '.' , . .' . .' . ~~ -: ." , ,~'--::. ~.... . . I , .. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: William C. Vohs, Esquire II W. Pomfret Street, Suite 2 Carlisle, P A 17013 Murrel R, Walters, Ill, Esquire 54 East Main Street Mechanicsburg, P A 17055 MARTS ON, DEARDORFF, WILLIAMS & OTTO By 'f~M) 1..v~ &:-t Thomas J. WiI~ms, Esquire Ten East High Street Carlisle. P A 17013 (717) 243-3341 Attorneys for Plaintiffs Dated: August 11. 1995 'n ':r) h 'J "J ." " " " , , ~ f:li ~ ~:> ~J :il ,~ ~ tJ ~ J ~~~~ i " llo~ ~ I [.:J ~ ~~ ~ .i~~ llo ~8~Gg H . . ~ l:t: > ~ ~ 8;ffi o ~ 8 ril , 0"1 OJ P. ~ m ~ '" ~~~ a ~ ej i ~ '! !llel lil m ~ < ~ ' ;~ J < ~ J ... ,,' '", ' . ~.\- :- ~ v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 95-483 CIVIL RICHARD R. BARRICK, Plaintiff SUSAN J. FLORENTINE, Defendant AND NDW. Ihl' I " ~.Y of attached Stipulation of Counsel, the first paragraph 1995, is hereby amended to read as follows: CUSTODY . 1996, upon consideration of the ection 3 of the Court's Order of March 9, The Father shall have partial physical custody of the children for seven consecutive weeks every summer, beginning on the fourth Sunday in June. In all other respects, the Order of March 9, 1995 is ratified and confirmed. c; ":> 0 l (;"\ .. "1 "'j' . ,-J "I' , r;iJ~ ;';i7J f/; t,', "X r'.' 1_) r :-;.-1 J. ~;! '. . =1J '~i,) ~,.J I_jen '.'t -~ C;) :J'J -.; cc: Murrel R. Walters. Ill, Esquire Thomas J. Williams, Esquire - C"'r-.'d,,~._Qul '? /1117".~ .A'~. F,lfILE.!l."IllATAFILE'Il.1ENrx)L"1)o\J..m.:nl.llldw CrcalcdOll11moUI:~AM R -'\cd: OrVJING 0) f1l 10 PM v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-483 CIVIL RICHARD R. BARRICK, Plaintiff SUSAN J. FLORENTINE, Defendant CUSTODY STIPI ILA TION It is hereby stipulated by and between the parties of this action. acting by their attorneys of record, that the first paragraph of Section 3 of the Court's Order of March 9, 1995 should be amended to read as follows: The Father shall have partial physical custody of the children for seven consecutive weeks every summer, beginning on the fourth Sunday in June, Dated: ~. fl. t; v :yURRVli!l1t~ Murrel R. Walters, III, Esquire 54 East Main Street Mechanicsburg, PA 17055 (717) 697-4650 Attorneys for Defendant Susan J. Florentine Dated: 7 /"j /7 (., MARTSON, DEARDORFF, WILLIAMS & OTTO By -rfn--) ~-~ Thomas J. WillIams, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Richard R. Barrick CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Stipulation was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Murre1 R. Walters, lll, Esquire 54 East Main Street Mechanicsburg. PA 17055 MARTSON, DEARDORFF, WILLIAMS & OTTO BY{~W. ) t..~~ Thomas J. Williams, Esquire Ten East High Street Carlisle. PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Richard R. Barrick Date: 7/16/96 (, ; " a ,~ " ~~'!1---:t",---;:, ..,..~: ::-. -' " . .;'.,., . ,'; '-' . _"."..~ l, . J " :,' I' ~. \ ", '.. ~: I" " ' .--..-.-.------".---.. .. -. ."-..' ._-._;::-..::..:;.:"==--':"~:::::-::::;:-':'=':-_~-~"::::-;'':::--''::'::-~::'::''::~;:'.':::;:'::'~~ ::'.=-:;._.~....::.'-~-~'"::..-:-.:::_.._.. - .:7':':: --':'~"::::;:.;::.::::'::'='-'==:::==__ ~o: ~~ iil~ 0 !2l !~~~ i H ~ t3 H . , !;! !jgB 0: > !3 ~ . Po ~ H m fil tJ ~~ Ii! ~~ ~ ~ ~ ~ S 'i:! z... ~ ij 0 < '. ~ ~ ~ ~ :S ~H ~ ~~ ~8~~~ ~ ~ 8 ~2 ~ Q ~ ili ~ ~ ~ ~ ~~ ~ ~ 1;1 oj ~ ~ 5 ~ < ~ -- .~_. .-.-. ....::::-:::::::=:===._-~_..._---_:- ==- I . . ,'. . ~. .., '.. !." ,<, ' " 'l}{t'q I."," ,-' . ," ~. ".,,,. .' 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