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HomeMy WebLinkAbout95-01337 ;1 o Z g)NOV 1 0 1997 AILEEN KERRY VOHS HOUSER, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . vs. NO. 95-1337 CIVIL TERM : WILLIAM CHARLES VOHS, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 4th day of November, 1997, the Conciliator, being advised by Plaintiff's counsel that the custody issues have been resolved by agreement of the parties and the Conciliation Conference scheduled for November 4, 1997 is no longer necessary, hereby relinquishes jurisdiction in this case. j l) .1/ /(,~",-a..-4---Jl.4-. "'c;..~'L Dawn S. Sunday, Esqu re CUstody Conciliator I j. ,~ .' i ., \ I '. Q ..0 () '.. -t '" ;':'" - "J .,lHi c:;! :1!"1' [.111": 0- " 'r~ :;;' " " " ..-r.- :.'.1CJ .... ~ I, I" (J).' c'Jh _".1 ...loll ~~\,",' -- ,~ 1._. i~Ci :;,.. , (,=1i') /r.(! ;~)rrl .:i"C": .. ~;l " r:- ~; ~J -, (;"'I -~ , I r I I I i I. r "'~"'''''~'..' ~., JUN ~ 5 /995 /:. n..., AILEEN KERRY VOHS, Plaintiff I I I I I i i I ! ! vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTi', PENNSYLVANIA CIVIL A<:'l'ION - LAW . . WILLIAM CHARLES VOHS, Defendant NO, 95-1337 CIVIL TERM IN CUSTODY OODER OF CXXlR'l' AND NOW, this 30th day of May, 1995, the eonciliator being advised that all CUstody issues have been resolved by Court proceedings, the Conciliator relinquishes jurisdiction in this case. I J tiL~ Dawn S. Sunday, ~ CUstody Conciliator "'.1 ,"\.-I \ -"" '. ,. " . I 'I... , , 1- ~,.",. nO c:.., .o:c...., nllfl:r... :ir.n,"l-' ~ F! ~~l ::; ..; 1.. /~l "~I .-:r.-~o ..;:l':t: ..., ~~OO." Z.~2: '- ~~'-.,c:, ~....1~ ..... ...'" -< ~-- ~ '" (.Q CD ... CD ~ =-:: cD CJ'I MAY 2G 1~)95d)~ AILEEN KERRY VOHS, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COllNTY, PENNSYLVANIA . . vs. : CIVIL ACTION - LAW : NO. 95-1337 CIVIL TERM WILLIAM CHP~LES VOHS, Defendant . . : IN CUSTODY COORT OOOER " AND tool, this 23rd day of May, 1995, the Conciliator being advised that all outstanding custody matters between the parties have been resolved, the COnciliator relinquishes jurisdiction in this case. 5 /.J3/9() Date (~~- Dawn S. sunday, Esqu r .'~ 1;';-- - Ll c;.~ 0-' '" 'W -":J ~ ,\.0(-' Vii q ~, \ ~ A LJ'> =-: ~ ri, CT> - \~ I") - , \)0 CI, :::i '" ~ I" " ,~ ~ ". \~ ~ cO ~~ ~ i\) "" "-i , Co: ,. -, ':.1 = Ul o ;t, ~ -: w a:l ~ ~ ~ ciJ ~ E $ ~ ;" < ~ - ~ ... 11: " ~ III G ~ ~ " 1': p ;f, _ cl ~ of, Ii! ~ c: 110 ;;- g ~ lJ riJ ~ ~ ~ ~ " 6 Q ~ ): ;" ~ -< ~ .. . , . , ~ . . r f J .. .. AILEEN KERRY VOIIS PlaintH f IN THE COUR1' OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95- /3.17 CIVIL TERM vs. WILLIAM CHARLES VOIlS Defendant ORDBR OF COUllT AND NOW, M~I{C I. 17, 1995, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before ~~"t<;'M!r'*Y. Bsquire, the conciliator, at 31' II) 'r1d'~1 0/, ~~~~If' v Carlisle, Pennsylvania, on ':1"",,,\r'l the ~ day of Apr; I ' 1995, at --1 o'clock ~.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. Either party may bring the child who is the subject of this custody action to the conference, but the child I s attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR TilE COURT, By w t, Custody Conciliator YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT IlAVE A LAWYBR OR CANNOT AFFORD ONE, GO TO OR TELEI'Il0NE THE OFFICE SET FORTIl BELOW TO FIND OUT WIlERB YOU CAN GET LEGAL IlBLP. " OFFICE 01' TilE COURT ADHINISTRA1'OR COURTIlOUSE, 4TIl FLOOR CARLISLB, PA 11013 ('111) 240-6200 H~R 208 10 ;jt/'95 " I'JI:f IIi : '" , : ("VI.,) l~h~ r:1!~ltr i(1 'I'') r./.I,' ry li-"',' ,: do" ,....J" l 'I 'I .J 1 i I ,\11 ',~ " .3 ',,)/.f/}' 6.J Wfi IHa.!)/7.c, a:(f b''r J .,)/ ''1( (1rl 11'(l:fW -z;, 0 <:>5/"....<<,. 3 J {''lC. Yk{C( l/la:J..,; -to c tl--k ;. I 11 ') , -, I ,; i >; , ,r, , '-::. ~ ' ' , , i , .;1. ' I"', 'II I , , f: ~ I'" , AILBBN KBRRY VOIIS Plaintiff IN TIIB COURT OF COMMON PLBAS OF CUMBBRLAND COUNTY, PBNNSYLVANIA CIVIL ACTION - LAW vs. WILLIAM CIIARLBS VOIIS Defendant NO. 95- CIVIL TBRM COMPLAINT FOR CUSTODY AND NOW comes the plaintiff, AILBBN KBRRY VOIIS, by her attorneys, Andes, Vaughn & Bangs and makes the following Complaint for Custody: 1. The Plaintiff is AILBBN KBRRY VOIIS, an adult individual who resides at 1874 Douglas Drive, Carlisle, Cumberland county, Pennsylvania. 2. The Defendant is WILLIAM CIIARLES VOIIS, an adult individual who the plaintiff believes resides someplace in Carlisle, but who can be served at his office at 11 West Pomfret Street, Suite 2, in Carlisle, Pennsylvania, 17013. 3. The Plaintiff and Defendant are husband and wife, having been married on 16 August 1991. 4. The Plaintiff and Defendant are the natural parents of one child, Catherine Bayley Vohs, born 28 August 1993. The said minor child resides with Plaintiff herein. 5. Plaintiff seeks custody of the minor child, Catherine Bayley Vohs. 6. The child was not born out of wedlock and is presently in the custody of the Plaintiff. 7. During the past five years, the minor child, Catherine Bayley Vohs, has resided with the following persons at the following addresses: August, 1993, to December, 1994 Plaintiff and Defendant 1074 Douglas Drive carlisle, Penna. December, 1994, to the present Plaintiff 1074 Douglas Drive Carlisle, Penna. 1 . 8. The mother of the child is the Plaintiff who reGides at the address Got out above. Sho is married to the Defendant. 9. The father of the child is the Defendant who resides in CarliGle, Pennsylvania, and who is married to the Plaintiff. The Defendant spends nights at the Plaintiff's residence, of which ho is a co-owner, but he does not reside in the house in the sense that he docs not spend time there during his waking hours. 10. The Plaintiff is the natural mother of the child. Plaintiff currently resides with the following person: the minor child, Catherine Bayley Vohs. 11. The Defendant is the natural father of the child. Defendant currently resides alone. 12. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the child in this or any other court. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights with the said child. 13. The best interest and permanent welfare of the child will be served by granting the relief requested by Plaintiff because the child has resided with Plaintiff since birth, because Plaintiff is available to care lor the child on a regular basls, because removing the child from her mother would be detrimental to her. and because the child's best interests are served by having them reside together because Plaintiff can provide more stability and a more suitable home environment for the child. 14. Each parent whone parental rights to the child have not been terminated and tho person who has physical cllntody of tho child have been named an parties to this action. 2 " _ t I ,.., .-,,_. . " . ...-- . ---. , " 1. " I' .' , , ", I/HBIUlFORB, AILEEN KERRY VOIIS requcsts this Court to grant her custody of the child, catherine BaYley Vohs. ANDES, VAUGHN & BANGS By ~ 7/:1 Michael L. Bangs Attorney for P ntiff COMMONWEALTH OF PENNSYLVANIA ) ( SS.: COUNTY OF CUMBERLAND ) AILEEN KERRY VOHS, being duly sworn according to law, dcposes and says that the facts set forth in the foregoing Complaint for Custody are true and correct to the best of her knowledge, information, and belief. '. ~AJ Sworn to and subscribed before me this 13" day of M,,^c.h , 1995. 1'1....., f4.IJe., Notary Public ~SC"I'\Jtl..: \,\"",VJr<lC~.,rdG<J.'7 ~~..) ~wus~. ' 3 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~,.- . ,~) ; NO, 95:} CML TERM : CML AC"I'ION . LAW : IN CUSTODY AILEEN KERRY VOHS HOUSER, WILLIAM CHARLES VOHS, ORDER OF COURT 0.........1 S AND NOW, this q'h day oC S",?It'mJ- r ,1996, uponconsiderntlon oCthe attached Complaint, It Is hereby directed that the parties WId their respective counsel appear beCore S':!jj~/", ~- 'I (".: \,.,./{>/, ,theconcUlator,at '1tt=f,''-'I.'' (~'7?T"Jr..(" (..(:",..~I)' '" ~cl e..." i"1";"SI,f'J.,(J.,,,,;.,~,)> onthelldaYoC V c1-obO ,1996,at~/1M, Cor a Pre-Hearing Custody Conference. At such Conference, WI 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, WId to enter into a temporary order. All children age live or older ~o be present at the Conference. Failure to appear at the Conference may provide grounds Cor entry oC a temporary or permanent order. Custody Conc' The Court oC Common PleBS oC Cumberland County Is required by law to comply with the AmerlCBllll with DlssbUltles Act oC 1090, For lnCol'llllltlon about IIccesslble CncUlUes WId reBSonsble By: accommodations nvnllnble to disabled individunls having business beCore the Court, pleBSe contact our, office. All arrangements must be made lit lenst 72 hours prior to WlY hearing or business beCore the Court. You must attend the scheduled conference or hearing, YOU SHOULD TAKE THIS PAPER TO YOUR ~WYER 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 oC the Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, PA 17013 (717) 240.6200 . . r::L~O'OFACr: IT l' ". "'in "',f)i^,W % r.Fr I 0 f It ;~: 1.0 CU", i\'I~.L j Ii J ,I..' ;, ,,;,.:1'; f'f f'r.~'\'1"1'\".r '(- ~ 11.'-1 L."lll\~ \ tJ.ltJ,?~ d~-I /~ ./.'~..b ~V? d7f~l?'J 7./tJ ,?.? 7(t1'tf,,'t. In4:4,./ '$ ~ ' tJ ' ff -# 'j.;t>.tJt .&~ INIAr!/ 11 a~, ~I#" ~ - AILEEN KERRY VOHS HOUSER, PlnlntlfT v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 95.1162 CML TERM WILLIAM CHARLES VOHS, Defendant PETITION TO MODIFY CUSTODY ORDER AND NOW comes the PlnlntllT, AIleen Kerry Vohs Houser, by and through her attorney, Ron Turo, Esquire, and mes the following Petltlon: 1. On Apr1128, 1995, the Honorable William H, Kaye, visiting Judge, entered an Order setting forth the custody arrangement between the partles in the above captloned PIl\tter. A copy of snId Order is attached. 2, Pursuant to the Order, the partles share joint legal custody ohhe minor child, Catherine Bayley Vohs and provided the mother, PlnlntllT, with prlmnry physlcnJ custody subject to periods of custody with the father. 3. Since the date of the Order, the Defendant, William Charles Vohs, hns failed to exercise his right ofvlsltation 118 outlined in the order, has refused mother's rell80nnble requests for a change In dnyeare arrangements, has previously failed to provide mother with his address and phone nwnber, hns repeatedly failed to provide payments to mother for unrelmbursed rnedlcnJ expenses, hns repeatedly allowed the child to remaIn In dnyClll'e even during his periods of visitatlon, and hns genernJly failed to cooperate in an amicable fll8h1on with the mother in terms ohhe child's needs both physicnJly, emotlonnlly and mentnlly. 4. The father's failure to provide adequate support and I18slstance to mother In rearing the child hns now necessitated the mother's request to amend the Order of Court of Aprl128, 1995 08 follows: A. Provide prlmnry legal and physicnJ custody to the mother; B. Gl1lllt the father liberal visitation at such tlmes and places 08 the parties agreei C. Provide such other relief 08 mny be just and re08onnble, " .' WHEREFORE, for aU the obove rensans, the PlnIntlff, Aileen Kerry Vahs HaUBer, hereby requests this Court to schedule 8 hearing and therenller amend Its Order of Court of Aprl128, 1995 for the rensons ns set forth obove. Respectfully submitted, LAW OFFICES OF RON TURO r~h~ Dote Ron Turo, Esquire 32 South Bedford Street Carlisle, PA 17013 (717) 245.9688 Attorney for PlnIntilf ~ 1.' ~ , .' VERIFICATION I verify that the statements mode In the foregoing Petition ore true and correct, I undel'8land that false statements herein ore mode subject to the penalties of 18 Pa. C.B. Section 4904 relntlng to unsworn falsl/lcatlon to authorities, 9' djpp a.~ Vok~ Date , AILEEN KERRYC ~ ~~intiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I NO. 95-1162 CIVIL TERM I I I IN DIVORCE v. WILLIAM CHARLES VOHS, Defendant - . - - - - - - . - - - - - - - - AILEEN KERRY VOHS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - SUPPORT DOMESTIC RELATIONS SECTION WILLIAM CHARLES VOHS, Defendant NO, 28 SUPPORT 1995 IN RE I AGREEMENT ORDER OF COURT AND NOW, this 28th day of April, 1995, upon the agreement of the parties as expressed in open court, we hereby order as follows I I. The Plaintiff, Eileen Kerry Vohs, is awarded exclusive possession of the residence at 1874 Douglas Drive, Carlisle, Pennsylvania, effective Saturday, May 6, 1995. Mr. Vohs will vacate the premises no later than 5100 p.m. on Saturday, May 6, 1995. The wife will have exclusive possession thereafter, provided, however, that she execute and file an affidavit of consent with the Court in this divorce action prior to June 30, 1995. Both parties have agreed to execute and file those consents. If Mrs. Vohs does not do so, the order for exclusive possession will dissolve automatically at midnight on June 30, 1995. II. This Court will enter contemporaneouDly herewith !! r an order for support on the terms to which the parties have agreed. Those terms are that Mr. Vohs will pay $360.00 and no cents per month as child support for the parties' minor child, Catherine Bayley Vohs, born August 28, 1993. The order will be effective on the 1st of May, 1995, and payments shall be made on or before the 5th of each month. The order will be administered by the Domestic Relations Office, to which all payments will be made'. This order is a temporary order only, and we make no findings as to the incomes or income potentials or expenses of the parties. This order is entered without prejudice to either party to seek a modification of the support order which is to be entered contemporaneously herewith, and the Domestic Relations Office of Cumberland County will schedule a conference to review that order upon the request of either party prior to June 30, 1995. The monthly payment provided for by this order includes the father's contribution to the child-care expenses of the child. Further, in addition to the payment to be made for the month of May, Mr. Vohs shall pay one installment which is due on the home equity loan which encumbers the residence within ten days of the date of this order. III. The parties have agreed upon an order and schedule for custody of their minor child who is named above. Accordingly, we hereby enter the following order for custody of the child I A. The parties shall share legal custody of the " child. B. The parties shall share legal custcdy of their minor child with the mother having all periods of custody except the following, which shall be the father's periods of custody of the child: " 1. Alternating weekends, from Friday at 4:00 p.m. until Sunday at 6:00 p.m., commencing on Friday, April 28, 1995. 2, One overnight each week. If the parties are unable to mutually agree on another night, the overnight shall be from Tuesday at 6:00 p.m. until Wednesday at 4:00 p.m. Mr. Vohs may, at his election, deliver the child to child care on Wednesday morning. 3. Alternating holidays, with the holidays being New Year'q Day, Presidents' Day, Easter, Memorial Day, JUly 4th, Labor Day, Columbus Day, Veterans' Day and Thanksgiving Day, commencing with the father having the July 4th holiday in 1995. If the father's holiday falls on his weekend or is celebrated on Monday, father shall return the child at 6:00 p.m. on that Monday. 4. Over the Christmas holiday each year, alternating December 23rd at noon until December 25th at noon and from December 25th at noon until December 27th at noon, commencing with the mother having the first period, being December 23rd to December 25th in the year 1995. .;. ........ 5. Either the day before or the day after, at the father'S election, the ohild's birthday, which is August 28th. 6, Two nonconsecutive weeks during the summer, with reascnable notice to the mother, The mother shall also be entitled to two nonconsecutive weeks during the summer, ,with reasonable notice to the father, of time with the child uninterrupted by the father'S periodS of telllporary custody. It is specificallY agreed that a week may begin immediately following a party's weekend and therefore result in more than a full seven-day period. This will enable each party to travel and enjoy vacation for a longer period of time. 7. Each pather'S Day, with the understanding that the child shall be with the mother every Mother'S Day. This order is entered without prejudice to either party to seek a modification of this order at any time in the future. IV. This order resolves all matters called or scheduled for a hearing at this time. By the court, samuel L. Andes, Esquire counsel for Plaintiff l- .'o___l-\. \~" William H. Kaye J., visiting Judge ~Hubert X. Gilroy, ESquire counsel for Defendant . \ .1- _ __.__ - " " . ' 1 I >- .::- L~ ,- "~ C'; "n " U:itl .. ~,,-,: r:J J..,- [ (, '" I. .)_) :::i,' i.' .J;~ c.)':" 1 ~! );:J 8'" .,. ;01 ; l ~ I fi!L' C'_. '. " '1] t--; 1.1, II, '-': '::1. I..} " U ,_1 l." U I ,I it 'j " I . , ,.' 'l'~_., ,.>' . ' '" . .' ,,~...~ -~ ..~ .~..,--~. , , , . .' ' , . ;~~ \j.j i ~ ih~i .\j.j !li:r.l ::1. I" ~~ ~i Jl~Jw:g . t1 ~ . lV ~J " ~~ ~8 ~ ~P< . . 'il 'W , ~~ E ~ (oii'1Ji j :'i !f i ~i~ gj il g \ ....c ~ .o.g I I ' ' C S ~ . mRJ "ill ~ ~I~ i] ~ ~ ~ ~ ~ . " , .. i , {/, .; , AILEEN KERRY VOHS HOUSER, Plaintiff IN THE COURT OF c:.'OOMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 95-1337 CIVIL TERM WILLIAM CHARLES VOIlS, CIVIL ACl'ION - LAW Defendant IN CUSTODY h OODBR OP~;1 AND tol, thiLday of consideration of the attached Custody onc at on Report, and directed as follows: , 1996, upon it is ordered 1. The prior Order of this Court dated April 28, 1995, as it relates to Child CUstody, shall continue in effect with the following modifications and additions. 2. The parties agree that the Child may attend the Magic Years Daycare on a full-time basis when the daycare has a full-time opening. Until that time, the parties agree that the Child shall attend the Magic Years Daycare on Mondays, Thursdays and Fridays and the Child shall remain in the care of Betty Tolley on Tuesdays and Wednesdays. 3. If the childcare provider is not available on a Wednesday, the parties shall share responsibility for the Child's care on an alternating basis. On the first occasion on which childcare is not available on a Wednesday, the Mother shall assume responsibility for making alternative arrangements and on the second occasion, the Father shall be responsible to provide alternative childcare arrangements. The responsibility for providing alternative childcare shall alternate between the parties thereafter. 4. In place of the two nonconsecutive weeks of summer vacation with the Child, provided in paragraph 6 of the prior Order, the Father shall have custody of the Child for one full week at any time during the year and the Father shall be entitled to exercise an additional optional week of custody at any time during the year. The Father shall schedule these extended periods of custody with the Child so as not to interfere with the Mother's periods of holiday custody. The Father shall provide reasonable notice to the Mother of the scheduling of his periods of cllstody under this provision. 5. When the Father is unable to exercise his right to custody on the holidays falling on Mondays as listed under paragraph 3 of the prior Order, custody of the Child on the remaining holidays shall continue to alternate as if the Father had exercised his right to custody on all specified holidays. 6. If either party requires childcare for the Child during his or her periods of weekend custody, that party shall offer custody of the Child to the other party prior to contacting a babysitter or other third party. 7. Sunday evening exchanges of custody under this Order shall occur . at Betty Tolley's residence. Regular exchanges of custody on weekdays shall take place at either Betty Tolley's residence or Magic Years oaycare as appropriate. For exchanges of custody on holidays, the party receiving custody shall be responsible to provide transportation from the other party's residence, unless agreed otherwise by the parties. 8. 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. cc: Ron Turo, Esquire - Counsel for Plaintiff _ ~~,L. lo/e/%, Michael A. Scherer, Esquire - Counsel for Defendant ..J .f'. '.":'.',';l',"'"";"1.! ~ 'I -~:.I " '. 1 ,.. ,,' ," 1'1 'I.J" ,.. i,- "JJ ::, " ' ,'.- ,;" :J ", :.-...;.....1 '.~_ ~ J . AILEEN KERRY VOHS HOUSER, . IN THE COURT OF CCX>IMOO PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . VS. . NO. 95-1337 CIVIL TERM . . . WILLIAM CHARLES VOHS, . CIVIL ACTION - LAW . Defendant . IN CUSroDY . PRIOO JUIJGB: (Visiting: William H. Kaye) CUS'.lOOY CXN::ILIATIOO Sl.tII1ARY REPOOT IN ACXXIUlANCE wrm CDlBERLAND CXXNlY RULE OF CIVIL PROCEDI.JRE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: ~ Catherine Bayley Vohs BIRTfIDATE ClJRREm'Ly IN aJS'lOOY OF August 28, 1993 Plaintiff/Mother 2. A Conciliation Conference was held on October 1, 1996 with the following individuals in attendance: The Mother, Aileen Kerry Vohs Houser, with her counsel, Ron Turo, Esquire and the Father, William C. Vohs, with his counsel, Michael L. Scherer, Esquire. 3. The parties agreed to entry of an Order in the form as attached. t<~ Dawn :;. :;unday, Esqu r Custody Conciliator Oc../-abtA ~, J if'll! Date '" '. .. ...... ~ . .~.. . f'-- " > /", "~I' ~,._"l-.," ': ,..,,~ ." .'_~~_'.n~7:;'- --')J , ' AILEEN KERRY VOHS HOUSER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . v. : NO. 95-1337 CML TERM . . WILLIAM CHARLES VOHS, : CML ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this '8 day oC October, 1997, upon consideration of the attached Complaint, It Is hereby directed that the parties and their respective counsel appear beCore rn\~ f'I ," S'-"c'o1&Q. the concl1lator, at 39 \J, \"\oirl ~\- '1 \-\rrVfl'\1 (,5:.\0...("5 ,PA on the ..!::L day oC , ' ~n\.JC:N"'\'cE"\, 1997, at 3:aO .eM, Cor a Pre-Hearing Custody Conference. At such Conference, an effort will be IlI8de to resolve the Issues In dispute; or If this cannot be accomplished, to deCme and narrow the Issues to be heard by the Court, and to enter Into a temporary order. All children age live or older shall also be present at the Conference. Failure to appear at the Conference may provide grounds Cor entry of a temporary or permanent order. FOR THE COURT, By: <:J.Jn I \..\)\ <:.A, J\ II rf\ rtfLl,.\- I [JVL.. Custody Concl1lator U (n;)U- The Court of Common Plens of Cumberland County Is required by law to comply with the Americans with Disabilities Act of 1990. For Information about accessible CacUlties and rensol18ble accommodations available to disabled individuals having business before the Court, plense contact our office. All arrangements must be IlI8de at lenst 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 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 Cumberland County Courthouse Fourth Floor Carlisle, PA 17013 (717) 240.6200 \ \ ., fltFD'Of/::C'= Or." 1"-. t. r Ii.' . .. '.i!t'.I!"l'lr.y . . h..'LLo..1 0- Or> ,d "T - r, I'" ',.... 7 .... ., ./.. ~ e[!\,'.; ",,~^.,,'!', ,",': ,. j""'v /)....."., .. .' . ...,,,';', t, '., 11\" . ,'J'.',\ .~ : ~ /(),(,t() &d. (~ /)!,;c.6-1 '$ dtf~ It) r 1) 'lfb,"t;;, ,p,tz,6J.t ~ a-li' ,$<4e-t II} ,,,,tl> {I' .-iff . (,~ IM../Jti ~ .i1~ ~""~~ r- , \ AILEEN KERRY HOUSER, PlainlilT, v. : IN THE COURT OF COMMON PLEAS : CUMBERI.AND COUNTY, PENNSYLVANIA : NO. 95.1337 CML TERM : CML ACl'ION . LAW : IN CUSTODY WILLIAM CHARLES VOHS, Defendant PETITION FOR MODIFICATION OF CUSTODY 1, The PlaintllT, Aileen Kerry Houser, Is an adult individual currently residing in Perry County, Pennsylvnnln, and is the natural mother of the chlld, Catherine Bayley Vohs, born August 28, 1993. 2. The Defendant, Willinm Charles Vohs, is an adult individual currently resIding In Cumberland County, Pennsylvnnla, and is the naturnl father of the snId chlld. 3, On October 7, 1996, the Honorable George E. HolTer entered a Caurt Order setting forth the amendments to a prior Court Order of Aprl128, 1995 outlining the custody arrangement between the parties. A copy of the Aprl128, 1995 Order and the October 7,1996 Order are attached hereto and made a part hereof. 4, The PlaintllT requests a modllicnlion of the Order of October 7, 1996 as foUows: A. Paragraph number 6 of the Court's Order requires that when chlldcnre Is necessary during a vlsitslion weekend, the party'in custody must fU'St request the out of custody parent to provide chiJdcnre, The Defendant has falled to foUow this order and has allowed other parlies to provide chlldcnre with the chlld during his weekend visltnlions. B. The Order should be amended to require that neither party spenk detrimentn1ly about the other party in the presence of the chlld, C, PlaintllT requests that paragraph number 7 be amended to set the drop-olT tbne at 5:00p,m. as opposed to 6:00p,m, D. The Court Order should be amended to delete the overnight for father during the week and it appears the pnrlies have agreed to this in the meantbne. E. Paragraph number 2 of the Court Order should be amended allowing the child to be enrolled In daycare In the Newport area which is closer to her home and which wI1J allow her to acclimate herself to her clnssmates with whom she will be attending school during the next school year. WHEREFORE, for all the above reasons, the Pla1ntlff, AIleen Kerry Vohs Houser, requests the Court to schedule a hearing and, aller hearing, provide the modifications to the Court Order as set forth above. Respectfully submitted, /O/J)f'? TURO LAW OFFICES !. --- -- Ul/L 0 Date Ron Turo, Esquire 32 South Bedford Street Cnrllsle, PA 17013 (717) 245.9688 Attorney for Pla1ntlff .... r do AILEEN KERRY VOHS, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 95-1162 CIVIL TERM WILLIAM CHARLES VOHS, Defendant IN DIVORCE AILEEN KERRY VOHS, Plaintiff - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - SUPPORT DOMESTIC RELATIONS SECTION WILLIAM CHARLES VOHS, Defendant NO. 28 SUPPORT 1995 IN RE: AGREEMENT ORDER OF COURT AND NOW, this 28th day of April, 1995, upon the agreement of the parties as expressed in open court, we hereby order as follows: I. The Plaintiff, Eileen Kerry Vohs, is awarded exclusive possession of the residence at 1874 Douglas Drive, Carlisle, Pennsylvania, effective Saturday, May 6, 1995. Mr. Vohs will vacate the premises no later than 5:00 p.m. on Saturday, May 6, 1995. The wife will have exclusive possession thereafter, provided, however, that she execute and file an affidavit of consent with the Court in this divorce action prior to June 30, 1995. Both parties have agreed to execute and file those consente. If Mre. Vohe doee not do eo, the order for exclusive posseesion will dissolve automatically at midnight on June 30, 1995. II. This Court will enter contemporaneouely herewith , I (" an order for eupport on the terms to which the partiee have agreed. Thoee terms are that Mr. Vohe will pay $360.00 and no cents per month ae child support for the parties' minor child, Catherine Bayley Vohe, born August 28, 1993. The order will be effective on the 19t of May, 1995, and paymente shall be made on or before the 5th of each month. The order will be administered by the Domestic Relations Office, to which all payments will be made. This order is a temporary order only, and we make no findings as to the incomes or income potentials or expenses of the parties. This order is entered without prejudice to either party to seek a modification of the support order which is to be entered contemporaneously herewith, and the Domestic Relations Office of Cumberland County will schedule a conference to review that order upon the request of either party prior to June 30, 1995~ The monthly payment provided for by this order includes the father's contribution to the child-care expenses of the child. Further, in addition to the payment to be made for the month of May, Mr. Vohs shall pay one installment which is due on the home equity loan which encumbers the residence within ten days of the date of this order. III. The parties have agreed upon an order and schedule for custody of their minor child who is named above. Accordingly, ,we hereby enter the following order for custody of the child: A. The parties shall share legal custody of the . ~. " ... ( ... , child. B. The parties shall share legal custody of their minor child with the mother having all periode of custody except the following, which shall be the father's periods of custody of the childl " , 1. ing weekends, from Friday at 4:00 p.m. until Sunday 1995. ., commencing on Friday, April 28, 2. One overnight each week. If the parties are unable to mutually agree on another night, the overnight shall be from Tuesday at 6:00 p.m. until Wednesday at 4100 p.m. Mr. Vohs may, at his elsction, deliver the child to child care on Wednesday morning. 3. Alternating holidays, with the holidays ~ being New Year'q Day, Presidents' Day, Easter, Memorial Day, ~ July 4th, Labor Day, Columbus Day, Veterans' Day and Thanksgiving Day, commencing with the father having the July 4th holiday in 1995. If the father's holiday falls on his weekend or is celebrated on Monday, father shall return the child at 6100 p.m. on that Monday. 4. Over the Christmae holiday each year, alternating December 23rd at noon until December 25th at noon and from December 25th at noon until December 27th at noon, commencing with the mother having the first period, being December 23rd to December 25th in the year 1995. rl rl 5. Either the day before or the day after, at the father's election, the child'e birthday, which is August 28th. 6. Tw~ nonconeecutive weeks during the summer, with reaeonable notice to the mother. The mother shall also be entitled to two nonconsecutive weeks during the summer, with reasonable notice to the father, of time with the child uninterrupted by the father's periods of temporary custody. It ~ is specifically agreed that a week may begin immediately following a party's weekend and therefore result in more than a full seven-day period. This will enable each party to travel and enjoy vacation for a longer period of time. 7. Each Father's Day, with the understanding that'the child shall be with the mother every Mother's Day. This order is entered without prejudice to either party to seek a modification of this order at any time in the future. IV. This order resolves all matters called or scheduled for a hearing at this time. By the Court, L.....:.'- (~(. 1(" William H. Kaye9 J., Visiting Judge ~amuel L. Andes, Esquire Counsel for Plaintiff Hubert x. Gilroy, Esquire Counsel for Defendant 1 sl1-RUE COpy FROM RECOHO DRO In Tostlmony wheroof. I hore unto set my hand and tho 5631 of said Ct'urt al Carlisle, Pa, This. /1'11. ~ay of ~ ;i1 ~5"' ~r/"'" ;::', protho. J"i '. AILEEN KERRY VOIIS IlOUSER, Plaintiff IN TilE COUR'l' OF COMMON PLEAS OF : CUMDERLANO COUNTY, PENNSYLVANIA : vs. NO. 95-1337 CIVIL 'l'EllM WILLIAM CHARLES VOltS, Defendant : CIVIL ACTION - LAW IN CUSTODY . . ORDER OF OXJRT AND to'I, this 'l;tL day of ((J...:t: ' consideration of the attached Custody conciU~Hon and directed as follows: , 1996, upon Report, it is ordered 1. The prior Order of this Court dated April 28, 1995, as it relates to Child Custody, shall continue in effect with the following modifications and additions. 2. The parties agree that the Child may attend the Magic Years Daycare on a full-time basis when the daycare has a full-time opening. Until that time, the parties agree that the Child shall attend the Magic Years Daycare on Mcndays, Thursdays and Fridays and the Child shall remain in the care of Betty Tolley on Tuesdays and WedneSdays. 3. If the childcare provider is not available on a Wednesday, the parties shall share responsibility for the Child's care on an alternating basis. On the first occasion on which childcare is not available on a Wednesday, the Mother shall assume responsibility for making alternative arrangements and on the second occasion, the Father shall be responsible to provide alternative childcare arrangements. The responsibility for providing alternative childcare shall alternate between the parties thereafter. 4. In place of the two nonconsecutive weeks of S1.ll1ll1er vacation with the Child, provided in paragraph 6 of the prior Order, the Father shall have custody of the Child for one full week at any time during the year and the Father shall be entitled to exercise an additional optional week of custody at any time during the year. The Father shall schedule these extended periods of custody with the Child so as not to interfere with the Mother's periods of holiday custody. The Father shall provide reasonable notice to the Mother of the scheduling of his periods of custody under this provision. 5. When the Father is unable to exercise his right to custody on the holidays falling on Mondays as listed under paragraph 3 of the prior Order, custody of the Child on the remaining holidays shall continue to alternate as if the Father had exercised his right to custody on all specified holidays. 6. If either party requires childcare for the Child during his or her periods of weekend custody, that party shall offer custody of the Child to the other party prior to contacting a babysitter or other third party. 7. Sunday evening exchanges of custody under this Order shall occur , . . ' i ,. , , " I at Betty Tolley's residence. Regular exchanges of custody on weekdays shall take place at either Betty Tolley's residence or Magic Years Daycare as appropriate. For exchanges of custody on holidays, the party receiving custody shall be responsible to provide transportation from the other party's residence, unless agreed otherwise by the parties. 8. 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, 1.5/ ~J.( r!'. ~"-' J. cc: Ron Turo, Esquire - Counsel for Plaintiff Michael A. Scherer, Esquire - counsel for Defendant TRUE COpy FROM RECORD In Testimony v,h'r:\'If. II"ro unlo set my hand end the seel of said Court at Carlisle, Pa, Thl. .....7.!!:..... day of....(J).d,...." 19..2.~ _..~~~t~,;;~=L . ' .~... / ' ." AILEEN KERRY VCHS HOUSER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLANO CO\lNT'i, PENNSYLVANIA NO. 95-1337 CIVIL TERM vs. CIVIL ACTION - LAW : IN CUSTOOY WILLIAM CHARLES VOHS, oefendant PRIOR JU1)GE: (Visiting: william H. Kaye) ~ ~ILIATlOO ~ ~ m 1IC(XlU)l\NCE Wl'l'H a.I'IBERLI\ND cxnmc RULE OF CML PRQCEOORE 1915.3-8, the undersigned Custody conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: Nl\ME - BJRTIlO1\TE ~y Dl ClJ5'l'OOY OF Catherine Bayley Vohs August 28, 1993 plaintiff/Mother 2. II conciliation Conference was held on october 1, 1996 with the following individuals in attendance: The Mother, Aileen Kerry Vohs Houser, with her counsel, Ron TUro, Esquire and the Father, William C. Vohs, with his counsel, Michael L. Scherer, ESquire. 3. The parties agreed to entry of an order in the form as attached. O~ pawn s. suncay, "~'i~"'~~ custody conciliator Qc,,19hM ~ I ) CZq c., pate CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Petition for Modification of Custody, upon Michael A. Scherer, Esquire, by depositing same In the Unlted States Mall, rl/'8t clnss, postage pre- paid on the .l. day of October, 1997, from CarUsle, Pennsylvania, addre88ed as follows: Michael A. Scherer, Esquire o 'Brien, Baric & Scherer 17 West South Street CnrUsle, P A 17013 TURO LAW OFFICES kl Ron 'Nfo, Esquire 32 South Bedford Street CnrUsle, PA 17013 (717) 245.9888 Attorney for Pla1ntlfT ,- 0 ,/'l 0 C. ,-I "I " ,":'I ...-;, ~ .") ".1 , " ...\ jl~tig I -CJ'~ ( 1,..1 .'JI ,) ~:: ~ ~'J\ ...j l.'''. .;C) ,- ','-.rn .. "d " :', -. " ~":l >4; II' -< AILEEN KERRY HOUSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. . . : NO. 95-1337 CIVIL TERM WILLIAM CHARLES VOHS, Defendant . . : CIVIL ACTION. LAW : IN CUSTODY ORDER OF COURT AND NOW, this 1/ day of June, 1998, upon consideration of the attached Complaint, It Is hereby directed that the parties and their respective counsel appear before t"'ruS'\\ ....). f\'~,he conciliator, at 31 \J II'-b\!\~ \-, I ME'd"m\L~Q ,11 on the l..\ day Of~~8, at \ \ " 00 AIM, for a Pre-Hearing Custody .J 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 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: ~UJ\\~.~\\ri\cln~~ Custody Conciliator l~ ') The Court of Common Pleas of Cumberland County Is required by law to comply with the Americans with Disabilities 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 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, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Film-orne\: Cr 11 -: ;' r,'I:t~I;I_)!1 JW .'''' 1\'" \ \; F," '1: r;r., 7hJ ,. ;11 'oJ \ !. .'... C"l '.: ' ' , ., "'.'i"{ ..........., \. ...". I.~::! i" ri \;', 'if. .....1. \,,1\.,1 , . ~ ./S-.~ &V(. I'o/P.;'~ -i 4~d c:. '/.5 ~~ ~ /ha.-& z. ell ~~" (p 'IS- ~ 6/,;- I/.JV 7$ 4 ~~ AilEEN KERRY HOUSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. . . : NO. 95.1337 CIVIL TERM WilLIAM CHARLES VOHS, Defendant . . : CIVIL ACTION. LAW : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY 1. The Plaintiff, Aileen Kerry Houser, Is an adult Individual currently residing In Perry County, Pennsylvania, and Is the natural mother of the child, Catherine Bayley Vohs, bom August 28, 1993, 2. The Defendant, William Charles Vohs, Is an adult Individual currently residing In Cumberland County, Pennsylvania, and Is the natural father of the said child. 3, On October 7, 1996, the Honorable George E, Hoffer entered a Court I Order setting forth the amendments to a prior Court Order of April 28, 1995 outlining the custody arrangement between the parties. A copy of the April 28, 1995 Order and the October 7, 1996 Order are attached hereto and made a part hereof. 4. The Plaintiff requests a modification of the Order of October 7, 1996 as follows: A, Paragraph number 6 of the Court's Order requires that when child care Is necessary during a visitation weekend, the party In custody must first request the out of custody parent to provide chlldcare. The Defendant has failed to follow this order and has allowed other parties to provide chlldcare with the child during his weekend visitations, , . . I ' ~... -' , . . . . - , B. The Order should be amended to require that neither party speak detrimentally about the other party In the presence of the child. C. Plaintiff requests that paragraph number 7 be amended to set the drop-off time at 5:00p.m, as opposed to 6:00p.m. D. The Court Order should be amel1ded to delete the ovemlght for father during the week and It appears the parties have agreed to this In the meantime. E. Paragraph number 2 of the Court Order should be amended allowing the child to be enrolled In daycare In the Newport area which Is closer to her home and which will allow her to acclimate herself to her classmates with whom she will be attending school during the next school year. F. The child will be ready for school In the Newport area In September and therefore the Court Order must be amended to reflect this change of circumstances and the fathe~s visitation changed accordingly, WHEREFORE, for all the above reasons, the Plaintiff, Aileen Kerry Vohs Houser, requests the Court to schedule a hearing and, after hearing, provide the modifications to the Court Order as set forth above. Respectfully submitted, TURO LAW OFFICES 0/74 3 Date on Turo, Esquire 32 South Bedford Street Carilsle, PA 17013 (717) 245-9688 Attorney for Plaintiff ';" CERTIfICATE OF SERVICE; I hereby certify that I served a true and correct copy of the Petition for Modification of Custody, upon Michael A. Scherer, Esquire, by depositing same In the United States Mall, first cla~s, postage pre-paid on the 9 day of June, 1998, from Carlisle, Pennsylvania, addressed as follows: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 17 West South Street Carlisle, PA 17013 TURO i .OFFICES _ I/~q Ron Turo, Esquire 32 South Bedford Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff - n If) ~ f; Cl'l '- :;J ~Jirj g C} ir. ,;,:D ~..Ii ,.,Hi 1,:';. ~ ~ <:") 'D :\s r::~ i:,j ::1 .l!:;.j '(; ...-, '1- ",.l. ...~., :,.:~P~ ~ Cin -i :.) ::"l ,. ~q -. '0 "'" I I I I i b " ,. ~....,. i, ~ . -...". -..- .. AILEEN KERRY HOUSER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . vs, : NO. 95-1337 CIVIL TERM : CIVIL ACTION-LAW : IN CUSTODY WILLIAM CHARLES VOHS, Defendant ~ ORDER OF COURT AND NOW, this r day of , 1998, the parties having agreed to the following, It Is ordered and direct as follows: 1. The prior Order of Court dated April 28, 1995 at 95-1162 Civil Term, as It relates to custody of the minor child, Catherine Bayley Vohs is vacated. 2. The prior Order of Court In the above captioned matter dated October 7, 1996 Is vacated, 3. The parties shall share legal custody of the parties' minor child, Catherine Bayley Vohs. The Mother, Aileen Kerry Houser, shall have primary physical custody of the child, The Father, Williams C. Vohs, shall have periods of partial physical custody as follows: a, Alternating weekends from Friday at 4:00p,m, until Sunday at 6:00p,m, b, Alternating holidays, with the holidays being New Year's Day, President's Day, Easter, Memorial Day, July 4th, Labor Day, Columbus Day, Veteran's Day and Thanksgiving Day, c, Over the Christmas holiday each year, alternating December 23 at noon until December 25 at noon and from December 25 at noon .. l.,...j ) ", ., " I I ! I I I \ , \ Ie , , , 1" j' ,,'I 'h, . '.'1\:' ~ '. '.' I i!~'\'\ ". ". '" I~ f _ .', .._,""I ,......;' '.1' "nO Z " "r. ~IJ'''" .J IV 06' rJ~,', 0' .' v :::..:';':1, " . -.1.) ,1..;.-, ' '. '" 'J-O:lijj''' ~'O , l. " : II I ill , "'~' -', "'~ -.,' , until December 27 at noon, with Mother having the first period during all odd years and the Father having the first period In all even years. d, Either the day before or the day after, at the Father's election, on the child's birthday which Is August 28. e, Two weeks, non-contlnuously. The parties shall provide reasonable notice to one another of the scheduling of the period of custody under this provision. This two week period may not Interfere with school nor the holiday schedule set forth above. f. Every Father's Day, with the understanding that the child shall be wllh the Mother every Mother's Day. 4. When the Father is unable to exercise his rights to custody on the holidays failing on Mondays as listed above, custody of the child on the remaining holidays shall continue to alternate as If the Father had exercised his right to custody on all specified holidays. 5, Regular exchange of custody on weekends shall occur with Father picking up the child on Friday at 4:00p.m, and Mother picking up the child on Sunday at 6:00p.m, In all other cases, the party exercising custody shall be responsible for transportation at the commencement of such period custody, 6, Each party shall notify the other at any time the child spends an overnight with any other party other than her father or mother or their families, I i i , I i' I , i ! '., '- ~ . . I , 7, This Order Is entered pursuant to an agreement of the parties. 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 , AilEEN KERRY HOUSER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. . . : NO, 95.1337 CIVil TERM WilliAM CHARLES VOHS, Defendant . . : CIVil ACTION.LAW : IN CUSTODY ~T!!,ULATION OF COUNSEL AND NOW, comes Aileen Kerry Houser, Plaintiff, by and through her attorney, Ron Turo, Esquire, and William C, Vohs, Defendant, by and through his attorney, Michael Scherer, Esquire and stipulate to the entry of the enclosed Order of Court reSOlving all custody Issues in the above captioned matter. '>!{3)9V Date ' Ron Turo, Esquire 32 South Bedford Street Carlisle, PA 17013 Attorney for Plaintiff I,'L'Vi~ 1f4;vj~ Michael Scherer, Esquire 17 West South Street Carlisle, PA 17013 Attorney for Defendant Date i' I' i! ;i, ~.~ :1 i- It '1 ., I ~ ;i ; i i ~ , I ! i n \,("1 () c- e.o :~ "I -oi',; ,;. 'c) ,.. pI' ~n ' -.\ ~~'-- 11,.... .... , I -'''1 I. : I,) 'II.::: I;: ,- , <IlL) I:' :\1 ' "I' " " , 'i~_1 ,- .1 . " I- t:- ;~ I " , , :::. .. .:-; :::1 't'. --) :~1 -, <1' . @; i i ti I, I i ! . I i t i i f I ~. r ~ i I' I ~ ..;) - A,.-I:\ .~ ;i> AUG 7 19~# AILEEN KERRY HOUSER, Plaintiff IN THE COURT OF COMMOO PLEAS OF CUMBERLAND COUN'l'Y, PENNSYLVANIA vs. NO. 95-1337 CIVIL TERM WILLIAM CHARLES VOHS, Defendant CIVIL ACTION - LAW IN CUSTODY OODER OP CXXlR'l' " AND NCJoI, this 4th day of August, 1998, the conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The CUstody Conciliation Conference scheduled for August 4, 1998 is ., canceled. FOR THE COURT, LO~~L..,d.t?r; Dawn S. Sunday, Esquire CUstody Conciliator 0 .0 ~ c: OJ ;.- ::- '1J "t1r :1 1':: (I)LT' :;-) I11:g ... ,,; Ie I ~,IT1 l/1.' , 'I? -,~ IdeJ r~>: :::~ \Jo-T d:!l .'. ~:.("') :; ~o-~~ \:irn ...t ::1 r:- ~l -< ,.' -..