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HomeMy WebLinkAbout95-02438 ~ ,oj i I , ~()o 'rf) ,.". ~ -" ., ins W I 'to CT JENNIFER (lJMBEIHiER) WALTERS, l'laintilf IN TilE COlJln OF COMMON PLEAS OF ('lJMBHtLAND('lllJNT\', PENNSYLVANIA v, CIVIl. ACTION-I.A W CIIRISTOI'IIElt M, UMIIEIWER, Dcfcndant NO, lJ5-243H CIVIL IN CUSTODY QlWER 01' couarr AND NOW, this _ ~_ day of ___ \:'r\. c \~\:::(;.L______ll)l}_j, upon considcraliun of Ihc allachedl'omplaint, it is hcreby dircctcdthut thc parties and theil' rcspcctive counselappcar ,I~eforc~~ \L_,~~'::-\-' Esquire, Ihe conciliatur, at t 1 \,) .\ ~[Ii\ )b~~' Cumberland County, Pennsylvania, un the \ ~ dllY of ...JQ\.."\ , I~~~~t .lS!i p-,m" for a Pre-lIcaring Custody Confcrcnec, At such conference an efl'urt will be madc tlll'eSlllvc the issues in disputc. or if Ihis cannot be accomplishcd, to dcfinc allllnarrllw the issucs to bc heard hy the l'llln1 and to cnter into a tcmporary Ordcr, Eithcr party may hring the child who is the suhject uf this custody aclion to the confercnce. but the child/childrcn's allcndance is not mundatory, Fuilure to appcl'" at the confercncc ll1uy provldc grounds for entry of a Icmporary or penllancnt Ordcr. FOR TIlE COURT: By: (-tfiw,\\..f\"J\\,\i'\(~\ },\~, Custody Conciliator C) I \;}>) YOU SIIOULU TAKE TIllS PAPER TO YIlUlt LAWYER AT ONCE, IF YOU DO NOT IlAVE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEI'IlONE TilE OFFICE SET FORTH BELIlW TO FIND OUT WIlEltE YOU CAN GET LEGAL lIEU', OFFICE Ill' TilE COURT ADMINISTltATOR ClllJlnllllUSF, FOlJlUH FI,()()lt l'AIU,ISU',PA 170lJ (7171 240-fl200 : il J, , " ( , I, , 1 P/I'!'! iAl.(~.'-;.tf,,/ 4 'd'~# (;;J,/J ~'t/ '7'b~" 1Ho1$t/ ;1 ,,7/ ~.x;:;"...t'....> /..;?IJ~~.' (.".. ~1~ttW ;~ '11,xrl'~",> JENNIFElt (lJMBEIHiElt) W ALlUlS, I'lllintill' : IN TIlE COlJRTOF COMMON PLEAS 01' : ClJMBEIH.AND COUNTY, PENNSYLVANIA \" : CIVIL ACTION.LA W ('llIlISTOI'IIER M, UMBI'IUil'll, Dcfendant : NO, 95-24311 CIVIl. : I N CUSTODY AND NOW, Clll11es Pctitioncr, Jcnnlfer (Umbcl'gerl Waltcrs, by und through her counsel, Kristcn Goddard Donscn, Esquirc, Ilnd thc law linn of Griffic & Assoclules, und pelitlons thc Court as liJllolI's: I. Your PClitioner is Jennifcr (Umbergcr) Wulters. lhe above-numcd Plaintiff and an adult individual residing at )1)55 Sullivan Street, Mechaniesburg, Cumberland County, Pcnnsylvunia, 2, Your Rcspondent Is Christophcr M, UlIlbcrger. the uhove-named Defendant and an adult individual currently rcslding lit 411 lIullonll'ood Lanc, Carlisle, Cumberland County, Pennsylvania, ), The parties ure thc natural parcnts of two childrcn, namely, Dustin Jamcs Covert Umberger, born March Ill, Il}l}), und Alexandra Marie Umberger, bom Dccembcr 25. 11)1)4, 4, The Parlics arc currently operating under an Ordcr of COUl'l duted May II), 191)1), providing lur Ihe physicalllnd Icgal custody urrangements fiJr the parties' children, said Order BUached hcreto and Incorporated herein by reference us Exhihit "A," 5, ,ince thc cntry of that Order, cireumstnnces haw chungcd such thai it is in the hest interest of the parties' children 10 reside in the primary physical cllslody of Petitioner, tl, Pelitinner hclicl'Cs, and therl'lilre uvers, thai Itespondcnt hilS sepuruled Irom his secolul Wile a 11I1 no longcr has hcr tOllid inl'aring fill'the children, 7, Pctitioncr helicl'Cs, lInd thcrclilrc Ul'crs, that the childrcn spenllllearly cl'cry wcekduy ovcmightat thcir putclllal grulldmolhcr's rcsidencc, Ij, Sincc thc cntry of thc Muy II), 191)1), Order. Pctilioncr hus lIIurried und moved Into a ncw, Ii vc hedroolll hOllie, I), Since the cutry of thc May II), 11)1)1), Ordcr. I'clilionel' hus Icll hcr joh and is null' working for Unitcd Postal Scrl'lccs, which prol'idcs a 111 ore uecunlll10duting work schcdulc, 10, Pctltioncr's ncw uddrcss is Inthc sUllie school district as Respondcnl's addrcss, II, Overall. sincc cntry of thc MlIY II), 11)1)1) Order, Pctitioncr's situation has stabillzcd and nespondcnt's sitoation has dctcriontlcd, 12, It is in thc bcst intcrcst und pcrmancnt wclfarc of hoth childrcn to cntcr an Ordcr providing Ihat thcy bc transfcrrcd into Pctitioncr's primary physical custody. 13, Thc childrcn havc continucd to rcsidc in Cumbcrlllnd County, Pcnnsylvania slncc thc entry of Ihc lasl Ordcr, WHEREFORE, Pctltioner requcsts your Ilonurablc Court to sehcdulc u Conciliation Confcrcncc ullcr which primary physical custody oflhc chlldrcn should bc transfcrrcd to hcr or u hcaring should bc schcdulcd on this mattcr, Rcspcctl\i1ly suhmlttcd. mUFFlE & ASSOCIATES '-~"'-~9~~ \:~J-'h:~~ Kristcn Goddllr.li lIlsen, ESljuirc Attorncy lor PlainlifT 200 North lIunol'cr Strect Curlislc, PA 17013 (717) 243.5551 (1100) 347-5552 VEItIl'ICA'1'ION I VERIFY THAT TIlE STATEMENTS MADE IN TilE FOREGOING DOCUMENT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS IIEREIN MADE AilE SUBJECT TO TIlE PENALTIES OF 1M I'A,C,S, SECTION 4l)()4 RELATING TO UNSWOI(i'l FALSIFICATION TO AUTIIORITIES, DATE: fJ:. C, II~~ , 1\.:I\t ;}:. l,l'h!tb.J\......f) J Ilnifcr ( lnbe 'cr) Waltcrs Plaintiff IN THE OJURT OF CXlMMON PLEAS OF CUMBERLAND COON'I'Y, PENNSYLVANIA JENNIFER UMBERGER, vs. NO. 95-2438 CIVIL TERM CHRISTOPHER M. UMBERGER, Defendant CIVIL ACTION - LAW CUSTODY OODER OF CXXlRT AND~, this 1'1 ~ day of I~ consideration of the attached CUstody concil at 0 and directed as follows: , 1999, upon Report, it is ordered 1. The Mother, Jennifer Umberger, and the Fathel.'", Christopher M. Umberger, shall have shared legal custody of Dustin Jamea Covert Umberger, born March 18, 1993, and Alexandra Marie Unt>erber, born Decellber 25, 1994. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being inclUding, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. To the extent one parent has possession of any such records or information that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Each party shall keep the other advised of any medical emergencies or illnesses pertaining to the Children while they are in his or her custody. The Father shall notify the Mother of any upcoming school events to give the Mother an opportunity to participate or attend. . 2. The Father shall have primary physical custody of the Children. 3. The Mother shall have partial physical custody of the Childrem in accordance with the following schedule: A. scxxx. YEAR: During the school year, the Mother shall have custody of the Children on alternating weekends from Friday at 6100 p.m. through Sunday at 6100 p.m. and every Thursday (beginning May 13, 1999) from after school until 6130 p.m. In addition, the Mother shall be entitled to have custody of the Child for 5 additional days (to be taken consecutively or non-consecutively) when the Children are not in school upon providing 30 days advance notice to the Father. The 5 additional days under this provision shall not be scheduled to interfere with the Father's periods of holiday custody which are specified in this order unless othenlise agreed by the parties. I':XIII 1lI'I' ^ B. SlJ9U'J{ SCIDJL BREAK: During the sunrner school break, the Mother shall continue to have custody of the Children on alternating weekends from Friday at 6:00 p.m. through Sunday at 6:00 p.m. In addition, the Mother shall have custody of the Children for 4 non-consecutive weEks (to be scheduled to include the Mother's regular weekend period of custody) upon providing 60 days advance notice to the Father. 4. In 1999, the parties agree that the Father may have custody of the Children for a scheduled vacation over What would have been the Mother's regular weekend period of custody. The parties agree to cooperate in rescheduling the Mother's missed weekend custody period over another weekend during the summer. 5. 'Itle parties shall share or alternate having custody of the Children over holidays as follows: A. CHRIS'I1Wl: The Christmas holiday shall be divided into Segment 11, which shall run from Decenber 24 at 2:00 p.m. through Christmas Day at 2:00 p.m., and Segment B, which shall run from Christmas Day at 2:00 p.m. through Decenber 26 at 2:00 p.m. The Mother shall have c;ustody of the Children during Segment 11 in odd numbered years and during Segment B in even numbered years and the Father shall have custody of the Children during segment A in even numbered years and during Segment B in odd numbered years. The party who has custody of the Children during Segment B shall also have custody of the Children for the first half of the remaining vacation days before school resumes after the Christmas holiday. The party who has custody of the Children during segment 11 shall also have custody of the Children during the second half of the remaining vacation days before school resumes after the Christmas holiday. For purposes of this paragraph the remaining vacation period shall run from Decenber 26 at 2:00 p.m. through the day before school resumes at 6:00'p.m. 'mANItSGIVING/E"S'l'I~U The Mother shall have custody of the Children on Th&nksgiving Day and Easter Sunday frem 9:00 a.m. until 2:00 p.m. in odd numbered years and frem 2:00 p.m. until 8:00 p.m. in even numbered years. The Father shall have custody of the Children on Thanksgiving Day and Easter Sunday from 9:00 a.m. until 2:00 p.m. in even numbered years and from 2:00 p.m. until 8:00 p.m. in odd numbered years. lU!l1t:H'S Oo\Y/P'ATHm'S DAY: The Mother shall have custody of the Children every year on Mother's Day from 9:00 a.m. until 6:00 p.m. and the Father shall have custody of the Children every year on Father's Day from 9:00 a.m. until 6:00 p.m. B. C. D. MI'l'DUAL DAY/JULY 4'1'1l/I.AllOO DAY: The parties shall share or alternate having custody of the Children on Memorial Day, July 4th and Labor Day each year as arranged by agreement between the parties. E. The holiday custody echedule shall supernde and take precedence over the regular custody schedule. 6. The Mother ahall have custody of the Children from after school on Friday. 5eptenber 10, 1999 through Saturday. September 11, 1999 at 6100 p.m. for the Mother'e witdding. 7. The party receiving custody of the Children shall be responsible to provide transportation for the exchange of custody, except that the Mother shall provide all transportat ion for exchange.s of custody for her 1'hunday periods of custody during t.he /School year. B. 1'he partiee shall be on time for all exchan\les of custody under thie Order. In the event of an emergency which would prevent a party fran being on time, that party shall notify the other of the GITlet"lj!ency as Boon as p:l811ible. 9. Both pertie. ahall ensure that the Children have no contact with Brian Barger, the former hu.band of the Children' a metemal aunt. 10. 1~ia Order ia entered purauant to the agreement of the partie. at a CwItody conciliation Conference. The parti811 mey modify the provieiona of thia order by mutual conaent. In the abeence of mutual conaent, the terms of thia Order ehall control. BY THE CXJllRT, J. CCI Kriatin G. Donaen, Eaquire - Coun.el for Mother Cerol J. Lindaay, taquire - Oounael for rether TRllE COpy FROM RECORD /r l"I"" ,,' I' "F :: . ' '" 'l'fflntr~@f my hand . 'd . 'f l". I" l .' (elft a1 Un ,.( It> f" ;t(. -" 0, lh,. I 9, Joy ~f 7?,1~, 19 9.,y" .. "..:J.Ii.J., ,u. ~~yuu".._ X~. Prothonotary Plaintiff IN TilE COURT OF COMMOO PLEAS OF CUMBERLAND CCONTY, PENNSYLVANIA JENNIFER UMBERGER, vs. NO. 95-2438 CIVIL TERM CHRISroPHER M. UMBERGER, Defendant CIVIL ACTIOO - LAW cusroOY PRIOO J\JDGE: J. Wesley Oler, Jr. CUS100Y a:tl::ILIATlOO &H1ARY REPOOT IN ACXXJU:W<<::E wrm CDIBERLAND CXXm'Y Rtn..E 0Ii' CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent infonnation concerning the Children who are the subjects of thie litigation is as follows: ~ MTE 0Ii' BIRl'IJ DuBtin James Covert March 18, 1993 I.lIlDerger CllRRENl'LY IN aJS'lOOY 0Ii' Father Alexandra Marie Umberger December 25, 1994 Father 2. A Conciliation Conference wae held on May 11, 1999, with the following individuale in llttendanc81 The Mother, Jennifer Umberger, with her couneel, Kristin G. Deneen, Esquire, and the Father, Christopher Umberger, with his couneel, Carol J. Lindsay, Esquire. 3. The parties agreed to entry of an order in the form as attached. Ind I.:J( 1'1'1 9 Date n,.~ Dawn S. Sun ay, Eaqu!e CUstody Conciliator . : IN THB COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAir : , :NO. 'I', ,)'1"\ CIVIl, 19 :CUS7'ODY /VlSn'A7'ION .,- { tJ,.J., ,., Plal'ntill J ("'f' , I( ~ V . ( ~'I,.".....", L,,,l.."/)cfendant ORDER OF COURT ('v I' ''I '.0 I" '1\ AND NOW, tllis (dr!ta)' , upon consideration ol the attaclled complaint, it is hareby directed .tllat t/ll1. partics and tlleir respective counsel appear belore l!:...,'"" )"" ,/.. 'I ( " tIle conciliator, at ~"'I II' '''1,,,,,''/ ~'l"I...".'I'''''J on tile ---'.111, day ol :./ I" t' , 19 <,e" , at ILJ' j(l /I /VI, M., lor a Prehearing 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 tile court, and to enter into a temporary order. Either party may bring the child who is tho Rubjeat of this custody aation to tile conference, but the cllild/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary ar permanent order. FOR THE COURT: By: ~(.,... .~d.u/. J..{ , ustody C nClliatorU " YOU SHOULD TAKE TIlIS PAPER TO YOUR lAWYER AT ONCE. IF YOU DO NOT llAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR ~'ELEPIlONE TilE OFFICE SET FORTIl RELOW TO FIND OUT WIlERE YOU CAN GET LEGAL IlELP. OFFICE Of' TilE COURT ADMINISTRATOR COUIlTIIOUSE, f'OURTIl FLOOR CAJILISl.E I'A 17013 (717)240-6200 , ,JE.NN I HI' I.' '!lliA J NJo: IIMPEI..;J'I" PLIIINTIFf- V, IN 1'111'; 1'[)I'FT 'iI,' ,'[)MMI'N PI.I'M; ,IIHIH:RLIINlJ ",'"NlY nNN::nVIIN I II Nl, 'i\'. .J'/,H C.v,f i~.~_ ':IIR I t;TflPIIEH IIHBEFGEF', DEFENDAln ,'} V I J. A'TII 'Ii A"T1111. i,AW For, ('IISTODY t'!lHPLA1NT )<J!}': c'I)WllJ!JY 1. Plalnlllf IS JENNIFEr' LuRRlIltH' IIHl:!Ef<GH who CUll@l)tly tesld@s at, 311 Suul!J Enol,] fill Vt.;o. F~nol a, Cunilielland Counly, Penn,~y I Vanl a, 170.' ~, , Defendanl 18 ,_'IIF J ',TOPHER I'HBEF';J':T<, whn Clll I "n\ j y I e51 des at, 291 Walnut Lall", ,;'a:1J:o"e, I,'umbellan,j "l1unty, hnillsylvanla, POll, L PlaIntIff seel\!} I,'ull I....,., .lid Phynl<'al "'l8t,]dy of the follOWIng chlldlslJ: NAHIW 1\1 I l,f! r::j:~ DATE Of' IJlkTll DUSTIN JAHEb ':r'VERT IIMBH',;U ,": W,llllut Lan., 3, 18/1)"3 l'at ; 1 r:; I f:. P^ 111) j ALEXANDREA MAl, I E ilHBFR'.Ff, ) 0 1 ~ !. ~ 111 j 1 5 i t'"' 1 1 j~ f-' 1:-/2~jI94 L," ..' 1 1. !. ill J i r! 1 I:'. P ^ 1 '101 _~ The chlltheJ1 W~le hlllfl In W~d. ",'1'.. . , Alf.oxandlf>a \Jmbel'l"l IS l'Iesf.'Jltly In til.. <'\H,t.".Jy .lenn! fel 1.\11" I alllp Und:lfll gel, wito 1 eSldes at. Dnve, Enola. l:umbetland County, 1'1\, 17();'~" uf th.. PlaIntIff, 311 South Enola DustIn Umbergel IS plesently In the custody of Christophel Umhelger. who resIdes at, 291 Walnut PA, 17013. the Defendant, Lane, Carlisle, SInce t.he chllrlJl'JI'S bllths, the chlldlt'n have follOWIng persons and al the follOWIng addresses; PERSONS ADDRESSES PlaIntIff, Defendant, and 291 Walnut Lane Mal'Y and BailY Uniliprgel CarlIsle, PA 17013 leSlded WIth the DATES 3/18/93 untll ,//93 Plalntiff. Defendant, and Dustin and I\lexandrea 7073 CarlIsle PIke 7/93 until Lot #217. l'alllsle, PA 3/28/95 Plaintiff and Alexandl'ea 7073 CarlIsle PIke 3/28/95 until Lot #217. ';arI151.., PA 3/31/95 Defendant, DustIn and MalY and Dairy Umbelgel 291 Walnut Lane Carllsle, PA 3/28/95 unti 1 Present PlaIntiff and Alp.andlea 311 South Enola Drive Enola, PA 17025 4/1/95 to Present 1'he Mothel of tl,,> chlldlPll, 15 the Pialnt1ft. Jennlfel LOl131ne 311 Houth Enula Dllve. Enola, tlmberyet. who cUll'ently l'esldes at PA, 17025. Th... Muthel IS malrler!. The Father of the children, is the Defendant, Chllstophel' Umberger, who currently resides at 291 Walnut Lant'. Carlisle, PA 17013 ' Tht' Fatht'r IS married, the Defendant to the children IS Defendant currently resides t ha t 0 f wIth tht' 4, The relationshIP of natural Father, The following persons: NAME Mary \Jmbergel Barry Umberger RELATlONSll1!' Mother Father The relationshIp of the Plalntlff, Jennlfel' LorraIne Umberger. to the children, is that of natural Motbel', The Plaintiff currently reSides wIth the follOWing person: N!\ME Alexandrea Marie Umbergel' Tanya Leese Anthony Leese l\atelyn Le",se RELlITIONGIlIP Daughter Mother Brother SIster TllpPlalllll!! dut:.'s Ilot ....11' 1\,/ l,t n l'Pl SOil nut a pill I Y t <J 1 he proceedIngs who hrl~ ph~'i,il'"l I_'\llcitlldy of ,ht:> t"hl1dlp.n 01 clalllls tll h,IV.., """Indy 01 Vl;;ltall"" 11'1111:" WIll. lesl'",.'1 In the <'hlldlen, (;, The b"r:1 1111"1"51" al1d 1'"'IIT,allplll w...llalp nt 11.., chl1dl"l1 will be set v €I'd by Y l a f1' 1 II q I h.... 1 f" 1 1 .., fl.' q q f:' f\ t e d l, e (' a \l r; eo : (al Pldlllllll IFJ "hi<, to 1'1 "vld", a lnvJI19 "I1Vllollmenl lot Ihe chlldt"", and Las dllnf' sn jc'l thf'JI pIlIJt" lIves: Ih) I'Ialn1111 1 ~ .' ali1 r~ t '-,1 PI oVldf~ pi opel cal t1 and fJuperVj.Slon fDJ the L,tllldlen and has done so tOI thPIl f'nll1" lIVes: 1(' , I'Ial11111 f I.' .' al!)e tlJ ~1lov1de a nafe. I'loper phYSIC'al enVI10nmel1t lell the d.lidteJi aile! lias dUJi" ,~" tnt thelt entlle IlVf'S; Ill) Plallll1f1 1".llf'v"n II If; In th.. i,p;,;\ IntE'tellls of the chJldlen to Le talsed loyethel, and In liVE' loyeth"l In one stable and 6"",UI" ..nVIlfm",pIlI, EllC'h pa I enl whose l'a I PIli a I lIghts 1(, the dllldten have not heell lertn1l1atE'd and tile llEfltiCdin wh" liavl" physll'al "llBtndy nt t I". chl1dl en have beell II~n\"nj rit', 1'....1 t 1 foP I!) t hl:~ rp-t. 1 Pll, WlIEHf.:f()RF., l'1 a III \ I t 1 HNN I nil' I"I<HA 1 Nf: IIMrn~f((:Fill , If.:lEilitictfuliy Lb'liji-' t, 'Ldt ttllE. Hl'Ji'>lrlliit_.. \'fHUt 'Hd~1 all Ordi!'l: III I Awitt d IIl'J I;, l!ll If j ,11ld {,,,tl'ndant Hhaled Ll'QIlJ I.'ustody Ilf t;lff millitl i'jillt1Iiffl: mInor chIldren, II a 11\1 119 PlaIntIff as th... PrImary phYSIcal (),) AWilrdllll) PlaIntIff [o'ull phYSIcal custody of the CustOll1all of the dllldlen, SlIbJect to Defendant's lIghts of PartIal PhYSIcal custody, Respectfully submitted. DATE: ~~ ( Susan Kay Candie 10. Esquire Attorney 1,0.- . 64998 110 South Carlisle Street 1',0. Box 670 New Bloomfield. PA 17068 Attorney for PlaintIff JENNIFER LORRAINE UMBERGER, Pl,1\ 1 NT 1 FF V : IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. CIVIL ACTION - L1\W ACTION FOR CUSTODY CIlRISTOPIlCR UMBERGER, DEFENDANT c~RTIFl~^TE Of,SERV!CE 1, Susan Kay Candlello. Esquire. hereby certify that a true and correct copy of the foregoing COMPLAINT FOR CUSTODY was served by first class mall, postage prepaid upon: Mr. Christopher Umberger 291 Walnut Lane Carlisle, PA 17013 Date~. 19'(,5, C j\'}1- X;l- (~'h \ - Susan Ka Can ie o. Esq. 110 SO"t Carlisle Street P.O, Box 670 New Bloomfield. PA 17068 ~ J ~ l~ '" ..... ~ ~ 'J ~ ~ v " 'J\ ~ ... .- :r- , ~ IR - ~ .. , " .1) ilB; II t ~~ .aj'~ ~~ .~ i J~ I .tA, ~ ~ ~ PJ!~ I . rJl/it~f ~ ;1 ~ J, ,,: l ~ i~ I :l! ~ , . JUN 1 4 IYY~A, . . II' JENNIFER LORRAINE UMBERGER, Plaintiff IN 'rilE OOUR'r OF COOMON PLEAS OF CUMBERLAND COONTY, PENNSYLVANIA vs. NO. 95-2438 CIVIL 'l'ERM CIIRISTOPIIER UMBERGER, Defendant CIVIL ACTIOO IN CUS1\JDY 00DIlR OF mJRT llND t<<:ai, this /v' day of J._ the attached Custody conciliation Report, it as follows: , 1995, upon consideration of ia her-eby oroer-ed and dir-ected 1. The Mother-, Jennifer- Umbet'ger-, and the Father, Chdstopher Umbet'ger-, shall have shared legal and phyalcal custody of Dustin James Cover-t UrrDet'ger-, born March 18, 1993 and Alexandr-ea Made l.lrrberger-, born December- 25, 1994, 2. The par-ties shall have physical custody of the Children on an alter-nating weekly basis with the time of exchange every week to be Saturday at 3100 p.m. The alternating weekly schedule shall commence with the Mother having physical custody of the childr-en beginning on Satur-day, June 10, 1995 at 3:00 p.m. 3. The par-ty who ia receiving custody of the Children shall be responsible to provide transpor-tation for the exchange of custody. 4. The par-ties shall shar-e physical custody of the Childr-en on holidays as follows: A. CHUB'DWl The Father shall enjoy physical custody of the Childr-en every year fran December- 24 at 12:00 noon until December 25 at 12:00 noon. The Mother- shall enjoy physical custody of the Childr-en every year- fr-an December- 25 at 12:00 noon until December- 26 at 12:00 noon. 1'he Father- shall insur-e that the Children are available to attend the Mother-Is family Christmas celebr-ation each year- ~len the celebr-ation occur-s during that week in which the Father has physical custody. B. NBW YEARS D.\Y, F.ASTI!R and 'I1IAN1WGIVlNG The par-ty who has physical custody of the Children dudng the week of the above holidays shall have custody of the Childr-en on the morning of the holiday until 2:00 p.m. and the other par-ty shall enjoy custody of the Childr-en on the holiday from 2100 p.m. until fl:oo p.m. C. KIBCELLANIUJS The Mother shall have physical custody of the Children every year on Mother's Day and the Father shall have physical custody of the Children every year on Father's Day during hours to be arranged by mutual agreement of the parties. 'llie Mother shall have physical cuatody of the Children every year on March 17 and the Father shall have physical custody of the Children on March lB during hours to be arranged by mutual agreement of the parties. 5. The parties may rrodify this custody schedule by mutual agreement. Absent mutual agreement, the custody schedule outlined above shall control. 6. This Order is entered pursuant to an Agreement reached by the parties at a Custody Conciliation Conference. In the event either party desirea to rrodify this Order, that party m~y reqlleat that the case again be scheduled with the Custody Conciliator for a Conference. BY TilE OJURT, eel Susan K. Candiello, Esquire Carol J. Lindsay / Eaqui re ~'-^, ~4~ / c..~", n",,-J~ct. / tel f s-/9S, A,'f. J. JENNIFER L()[lRAINE UMllEHGEH, plaintiff 1 N 'I'm: rnllIl'l' 01" CX'X'1MCtl "L~'1IS OF CllMIIFJU.ANIl CUJN'I'Y, PENNSYLVANIA va. : NO. 95-2430 CIVIL 'I'EHM CIlRISTOPIIER UMIlEHGER, Defendant CIVll. AC'I'ICl-l IN CUSTODY CllB'lUJY lXWCILIATICJf 8lIIIAItY REI'WT IN AaDUlo\NCB wrnl aJIII!RLAND aufl'Y RULE (Xl' CIVIL PlD'lDIRK 1915.3-6, the undersigned Custody Conciliator lIuanits the following reportl 1. 'll1e pertinent information pertaining to the Children who are the subjects of this litigation is as follows: NAME OIRTIlDA1'E CllRREN'I'L Y IN CUS1'ODY OF Dustin James Covert Umberger Alexandrea Marie Umberger March H!, 1993 December 25, 1994 Defendant/Father Plaintiff/Mother 2. A Conciliation Conference waa held on ,lune 6, 1995, with the following individuala in attendance I The Mother, Jennifer Umberger, with her counsel, Susan K. Candiello, Esquire, and the ~'ather, Chrbtopher IJrrtJerger, with his counsel, Carol J. Lindsay, Esquire. 3. 1'he parties agreed to the entry of an Order in the form aB attached. Date , Ji'.L IL.l /.~ . ('C" -, II n ~"su~~f,'~~dI Custody r~nciliator JENNIFER UMBERGER, J'lalnliff VI, IN THE COURT OF COMMON l'l.EAS OF . CUMBERLAND COUNTY, PENNSYLVANIA . CIVIl. ACTION - LAW : NO, 95-2438 CHRISTOPHER M, UMBERGER. Defendanl IN CUSTODY I. Plalntiff II Jennifer L Umberger, an adult individual currenlly realdlngll 1554 Bridge Slreet, New Cumberland, PeJmlylvanl1 2, Defendanl II Chrillopher Umberller, an adult individual currently realdllllJ II Bullonwood Lane, Carli lIe, CUlllberland Counly, J'ennlylvanil, 3, The PlalnlUf and Defendlnl are Ihe Mlural parenti of Dultin Jamel Covert Umberger, bom, March IB, 1993, and A1exandrl Marie Umberger, born, December 25,1994, The children were not born oul of wedlock, Por lho pilI IIvo (5) yeara, or a1nce lhe chlldron' I birthl, lhe children have realded wilh lho foUowilllJ porlOnl Illhe followilllJ addrellet for Ihe followiOJl periodl ofllme: NAME Chriltophor UmberJler Jennifer UmberJler Ctuillophor Umberller Mary UmberJler Bany UmberJler Jennifer Umbel Jler TanYI LIeIe Tony LIeIe Klti, LIeIe Chrillopher UmberJler Y olandllJmberJler lillDRESS DATE Leibe'l Trailer Court Carlille, PA 17013 March 1993 10 March 1995 WalnuI Lane Car Iillo. I' A 17013 March 199510 January 1996 } II South J!lIull Urive EllUl., I'A 170B March 1995 10 February 1996 lIullollwolld LillO ('lllille,IIA 170IJ January 1996 10 Plllenl NAME ADDRESS DATE Jennifer Umberger Sample Bridge Road Enol&, PA 17025 February 1996 to November 1996 Jennifer Umberger Rick Sullon Hunler Drive Mechanicsburg. PA 17055 Novell1ber 1996 to February 1997 February 1997 February 1998 Jennifer UIl1ber8er Tanya Leese Tony Leese Katie Leese Second Street West Fairview, PA 17025 Jennifer Umberger MadllOn Walters Brian Walters 1554 Bridge Slreet, Apt. A New Cumber1snd. P A 17070 February 1998 Present The natural mother of the children Is Jennifer Umberger who resides u aforesaid, She is sinaIe, The natural father of the children Is Christopher Umberger who resides u aforesaid, He Is nwTied, 4, The relationship of the Plaintiff to the children Is that of natural mOlher, The Plaintiff currently resides with Brian Walters, 5, The relationship of the Defendant to the children II that of natural fslher, Defendant currently resides with Yolanda Umberger. 6, Plaintiff hu 1101 partlcipaled as a party or wilnesl, or In any other capacity In other litigation, concerning cuslody of the children, 7, Plaintiff hu no Information of any custody proceedings concerning the children pending In any Court of this Commonwealth, 8, It is In the best interesl and pemlanenl welfsre of the children to grant the relief requested because: a,) She is more than willing to facilitale the relationship between the other parent and the child, 9, The Plaintiff does not know of any person on Ihe part of the proceedings who claims to have custody or visitation right a with respect to the children, WHEREFORE. Plaintiff requesta your Honorable Court to enler an Order granting prinwy physical cuslody with the Plaintiff and establishing a schedule of temporll}' physical cuatody with the Defendant, Respectfully submitted, ORIFF;:ASSOCliS' ~'/ ,. }J:;' / I A'.'"I'''''.v/,/\ _/Thomu S, Diehl, ElQulre Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-SSS I (BOO) 347.SSS2 VEIU I-leA TION I VERIFY HlA l' THE STATEMENTS MA~ IN THE FOREGOING DOCUMENT ARE TURE AND CORRECT UNDERSTAND TIIAT FALSE 51' A TEMENTS HEREIN MADE ARE SUDJECT TO TIlE PENALTIES OF 18 PAC,S, SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, Dale: l f'~', (r:)\fff, ,~. ,/ Plaintiff IN THE COURT OF rolMOO PLEAS OF FYMBERL~DI!COUNTY, PENNSYLVANIA NO. 95-243~ CIVIL TERM ",\ JENNIFER UMBERGER, vs. l : ': CIVIL ACTION - LAW CHRISTOPHER M. UMBERGER, Defendant CUSTODY mDI!R OF CXlR1' AND r<<:Ji, this ~ day of 'MM consideration of the attached CUstody COncil at 0 and directed as follows: , 1999, upon Report, it is ordered I. The Mother, Jennifer Urrberger, and the Father, Chdstopher M. lJ1TDerger, shall have shared legal custody of Dustin James Covert lJJ1Derger, born March IB, 1993, and Alexandra Marie Umberber, born December 25, 1994. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being inclUding, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. To the extent one parent has possession of any such records or information that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Each party shall keep the other advised of any medical emergenciea or illnel!lses pertaining to the Children while they are in his or her custody. The Father shall notify the Mother of any upcoming school events to give the Mother an opportunity to participate or attend. 2. The Father shall have primary physical custody of the Children. 3. The Mother shall have partial physical custody of the childrem in accordance with the following schedule I A. BCRD. YEAR: During the school year, the Mother shall have custody of the Children on alternating weekends from Friday at 6100 p.m. through Sunday at 6:00 p.m. and every Thursday (beginning May 13, 1999) from after school until 6130 p.m. In addition, the Mother shall be entitled to have custody of the Child for 5 additional days (to be taken consecutively or non-consecutively) when the Children are not in school upon providing 30 days advance notice to the Father. The 5 additional days under this provision shall not be scheduled to interfere with the Fatherls periods of holiday custody which are specified in this order unless otherwise agreed by the parties. U. BlIIlI!R SCIJJOL BREAK: During the sunmer school break, the Mother shall continue to have custody of the Children on altemating weekends from Friday at 6:00 p.m. through Sunday at 6:00 p.m. In addition, the Mother shall have custody of the Children for 4 non-consecutive weeks (to be scheduled to include the Motherls regular weekend period of custody) upon providing 60 days advance notice to the Father. 4. In 1999, the parties agree that the Father may have custody of the Children for a scheduled vacation over what would have been the Mother's regular weekend period of custody. 'l'he parties agree to cooperate in rescheduling the Mother's missed weekend custody period over another weekend during the summer. 5. The parties shall share or alternate having custody of the Children over holidays as follows: A. CllRIS'DWl: The Chriatmas holiday shall be divided into Segment A, which shall run from Decenber 24 at 2:00 p.m. through Christmas Day at 2:00 p.m., and Segment B, which shall run fran Christmas Day at 2:00 p.m. through DecenDer 26 at 2:00 p.m. The Mother shall have custody of the Children during Segment A in odd nUllbered yeara and during Segment B in even nUllbered years and the Father shall have custody of the Children during segment A in even nunbered years and during Segment B in odd nUllbered years. The party who has cuatody of the Children during Segment B shall also have custody of the Children for the first half of the remaining vacation days before school resumes after the Christmas holiday. The party who has custody of the Children during Segment A shall also have custody of the Children during the second half of the remaining vacation days before school resumes after the Christmas holiday. For purposes of this paragraph the remaining vacation period shall run from Decenber 26 at 2:00 p.m. through the day before school resumes at 6:00 p.m. B. 'l'IW<<BGIVING/EAB'ft!R: The Mother shall have custody of the Children on Thanksgiving Day and Easter sunday fran 9:00 a.m. until 2:00 p.m. in odd nUllbered years and from 2:00 p.m. until 8:00 p.m. in even numbered years. The Father shall have custody of the Children on Thanksgiving Day and Easter sunday from 9:00 a.m. until 2100 p.m. in even nunDered years and from 2:00 p.m. until 8:00 p.m. in odd nUllbered years. C. KJ.I'IIJ!R'8 ~Y/FA'11IER'8 ~Y: 'l'he Mother shall have custody of the Children every year on Mother's Day from !l:00 a.m. until 6:00 p.m. and the Father shall have custody of the Children every year on Father's Day from 9100 a.m. until 6100 p.m. D. MI'JDUAL ~Y/JULY 4'111/~ ~Y: The parties shall ahare or alternate having custody of the Children on Memorial flay, ,Jul Y 4th and Labor Day each year as arranged by agreement between the parties. ~ ,. " .'- Dustin James Covert March la, 1993 lJnDerger Alexandra Marie Umberger December 25, 1994 Father JENNIFER UMBERGER, Plaintiff IN TilE COURT 01' CC\'>IMOO PLEAS OF CUMBERLAND CaJNTi', PENNSYLVANIA vs. NO. 95-2438 CIVIL TERM CIlRISTOPIlER M. UMBERGER, Defendant CIVIL ACTION - LAW CUSTODY PlUm JlDGBl J. WeBley Oler, Jr. CUS'laJY CXH:ILIATI~ BlMIARY REPCItT IN ACXDUW<<:Il WI'111 cnmmtAND m.Nl'Y RULE 01." CIVIL PAl' .....JUl 1915.3-8, the undersigned Custody Conciliator submits the following reportl I. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NMB \lATE 01." DIR'I1I <UUUWl'LY IN amaJY 01." Father 2. A Conciliation Conference was held on May 11, 1999, with the following individuals in attendance: The Mother, Jennifer UOOerger, with her counsel, Kristin G. Densen, Esquire, and the Father, Christopher Umberger, with his counsel, Carol J. Lindsay, Esquire. 3. The parties agreed to entry of an Order in the form as attached. / lid I..J, 1 ,} ? 'l Date IJ... itb.~/11 Dawn S. Sun ay, EsquK-e CUstody Conciliator , ,lit" eli .~ .... J ~ ~ ~IB~ S] ff~J~ ~~ i ~ I !~ i ~~ t;lj . iU~ ~!~u I ~ . II IE: IW i . . . . . "IN;.\ ! . , JENNIFER (UMBERGER) WALTERS, Plaintiff IN 'I'IlE l'OUIl'1' OF ffi'lMON PLEAS tW CUMBEHLAND aJUN'J'Y, PENNSYLVANIA vs. NO. 95-243U CIVIL TEllM CIlHISTOPIlER M. UMUEIlGEH, Defendant CIVIl, AC'l'lON - LMI CUS1'ODY OODf2l OF mJRT AND 1'0'/, this 2S'1t day of consideration of the attached Custody and directed as follows: .J ;~..I'H.l..L,l :l ' 2000, upon cO:l1iat1on IHeport, it is ordered 1. A Ilearing is scheduled in Court Room No. I ,of the Cumberland County Court Bouse, on the {1 a day of y(\~ ' 2000, at q', ,~Q o'clock, ,&.m. at wh ch time testimony w I be taken. For purposes of this Hearing, the Mother, Jennifer Walters, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the Hearing and a sun.nary of the anticipated testimony of each witness. These Memoranda shall be fileu at leaet 10 days prior to the Hearing date. 2. Pending further Order of Court or agreement of the plrties, the prior Order of this Court dated May 19, 1999 shall continue in effect. BY TilE CXlUR1', eel Kristen G. Densen, Esquire - Counsel for Mother Carol J. Lindsay, Esquire - counsel tor Father _/.ba(w~~ '()d:ti~~ I/~t';(}~{) ,~V JENNIFER (UMBERGER) WAL'I'EHS, Plaintiff vs. : IN TilE COUR1' 01' CU1MON PLEAS OF : CUMBEHLAND CCUN'I'Y, PENNSYLVANIA : : NO. 95-243B CIVIL 'I'ERM : CIIIUS1'OPIII,Jl M. UMBf.JlGER, Defendant CIVIL AC'I'ION - LAI~ CU5'I'ODY I'RIOO JUlJGE: J. Wesley oler, Jr. ClJ.'l'IUJ\ <XB:ILIA1'I~ BlI9tARY REIun' IN AcmmANCE WI'll1 a.ttD~U.AN() (llM'Y RULB IF CIVIL PRO'I<IQtE 1915.3-11, the undersigned Custody Conciliator submits the following report: 1. 1'I1e pertinent information concerning the Children who are the subjects of this litigation is as follows: ~ [lA'm IF IIIR'l11 cmnmrLY IN CU8'roOY OF Dustin James Covert Ulllberger Alexandra Marie Unberger March lB, 1993 December 25, 1994 Father Father 2. A conciliation Conference was held on January 12, 2000, with the following individuals in attendance: 1'he Mother, Jennifer 11alters, with her counsel, Kristen G. llonsen, Esquire, and the Father, Christopher M. Unt>erger, with hia counsel, carol J. Lindsay, Esquire. 3. 'I'hle Court previously entered an Order on May 19, 1999 under which the Father had primary physical custody of the Children and the Mother had partial physical custody 011 alternatinq weekends and some periods during the week. 1'he Mother filed this Petition for Modification requesting that primary physical custody be transferred to her. The parties were not able to reach an agreement and it will be necessary to schedule a lIearing in thia matter. 4. '11111 Mother's position on custody is as follows: 'I'he Mother belieVlls it would be III the Children's best interest to primarily reside wilh hllr llli/cau...", III her view, the ~'ather's livillg c1rculnatances have change<l I!I\lnl Ilcant1y. The Filthe: has separated from his second wife and the Mother belIeves that the Childrell spend the weekd"y overnight periods and other perlc.ja whell the Father Is workl"'.l at the paternal grandparent's home. C_l the olhvr h",,,J, acconUII(J to the Mother, the ~lother has rernarried and 18 lIvll.J in a heo"e tllat. would "nwlde IlKJre than adequate space for the ('lIl1dnm. 'l1,e Moth", I"lill"d 111111 "I", lIi1a obtained II new job which will be<Jln ,Janua,y ll, wloldl Dl ten.. her it f I.'xlbl" Bchedule at 20 to 2'> houra pur wlll!k. 'I'll.. Muth"r "xI",cts 10 be i\V1lj];;ble under thla tlclll,dule to provl<16 ,'.u" fm the D]d"AI <'lIlld Whell 1<11" III 1I0t III Hchool alld for the I"ull..", yo,m'J,,"t ('Iolld ,'11<1 II,,, ('Idld Dl Ill" Motl,er's ""cond marda'l" wllell \I,.. Mo\l'''I''~ ,,,,,,1..11<1 1M lor,( ,IV"llill"". '1'1", Motller prol'(JI3ed 111M t.lle Father JENNI FEP. UMBERGER, IN TilE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIl, ACTION - LAW I N CUSTODY CHRI STOPHER M. UMBERGER, Defendant 95-2438 CIVIL TERM IN RE: CONTINUANCE ORDER OF COURT AND NOW, this 17th day of May, 2000, upon consideration of the Plaintiff's Petition for Modification of Custody, and upon motion of De fendant' s counsel, Ca rol ,]. Lindsay, Esqui re, for a continuance of the hearing in this case, which motion is not opposed by the Plaintiff, the Defendant's motion for a continuance is granted, and this matter is rescheduled for Monday, July 31, 2000, at 9:30 a.m" in Courtroom Number 1, cumberland county Courthouse, Carlisle, Pennsylvania. By the Court, Bradley Griffie, Esquire For the Plaintiff (/ "1 / ,/ . -I (." , c, (.: J. " es ey 0 e , r" Jf2-li~ ;f)aJ,J 5 -1'6.00 /H K'-3 - , ,', ,.., " ~ . '1 ,j ,~ .1 :;' ':-1 ;, u . ., ;~ '''' Carol J. Lindsay, Esqul re For the Defendant It JENNIFER L. UMBEltGER, I'luintill' : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY , PENNSYLVANIA \" : CIVIl. ACTION . LAW CIIRISTOI'IIEIt M, UMBEIUiER, Dcfcndant NO, 95-243K l'\VIL TERM IN CUSTODY 1)llA[CII)[ TO TIlE PROTIIONOTARY: Plcasc change nalllc of thc Plaintill', Jcnnifer L. Umbcrgcr, 10 Jcnnlfcr L. Wullcrs us I'luintlll' hus rcmarrlcd, Rcspcctfully submlllcd, ( --7 ,G' IC, Esquirc ICY for Plaintlll' GRIFFIE & ASSOCIATES 200 North Ilnnowr Slrccl Curlislc, I' A 17013 (717) 243-5551 (KOO) 347-5552 Dale: 51; JJ 0 tl ii.', L~ , 'I' ':1 I ~ c,~ . ,', 1.1.1 ii 1'"' II'. l, l' : " L I l I , i , , I I : JENNIFER UMBElHlElt : I'lainlil1' IN TilE COURT OF COMMON PLEAS OF l'l JMBERI.ANI> CO! JNTY, I'ENNS YL VANIA v, CIVIL ACTION I.A W CllIUSTOPllIm M, UMBEIHlElt DclclIlllIlIl NO, lJ5-2431l CIVIl. TI:RM UIWElt OF COURT ANI> NOW, Ihis .1'd dllY or August, 2000, upon rclation or counscl Ihal a slipulalion will bc cntcrcd ill Ihis ClIse, Ihe henl'ln!! pl'cviously schcdulcd lill' .Iuly 31. 2000, is conlinued gellcrnlly, COUNSEL IIrc dirccled 10 conlllct thc court Irthcy desirc II hearing inlhis maller, BY TIlE COllifl'. "I _l/t ~,.~ -S~LJ'tl Lficslcy (lIer, Jr..' J, (, I Brodley Orlllle. Esq, 200 N, Ilanovcr Slrecl Carlislc. I' A 17013 Allol11ey fill' l'lainliff ) Co,,'t4 ".,.,[..L p/4'" ~ Coml J, 1.I11dsoy, Esq, 111~oslllil!h Slreet Carllslc,l'A 17013 Allorney lilr I>crendlllll :rc JENNIFER L. (UMBERGER) WALTERS, : IN TilE COURT OF COMMON PLEAS OF I'lainliff : CUMBERLAND COUNTY,I'ENNSYLVANIA v, : CIVIL ACTION - LAW CIIRISTOI'IIER M, UMIlElHiER, Dclcndunt : NO, 1)5-243H CIVIL TERM : IN CUSTODY 1)I{AECII)E TO TIlE PROTIIONOTARY: Plcasc modify thc nalllc of Ihc Plaintiff in thc abuvc captiuncd uctiun froll1 Jcnnifcr L. Umhcrgcr to Jcnnifcr L. Waltcrs bascd upun her rcccnlmurriugc und chungc uf numc, Dulc: 'i</J r-J D () i i i JENNIFER L. UMBERGER, I Plaintiff I , I' VB. I' " Jrjr < (~i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 95. 2438 CIVIL TERM CHRISTOPHER M. UMBERGER, Defendant IN CUSTODY i AND NOW this 3rJ day of t\) t. ~ (' -l'L.cJ ,2000, upon consideration of the within Stipulation of the Parties, the terms thereof are hereby mede an Order of Court, t~ 1ilU /1-3-00 V.. ~.-"'J RTf ' ',/' ( (.~ ) By the Court, IJIO.'fn~ SId'J\ II w, H........' l'o'-, PA ( " I, ------ umbargar '''pulallon 08/31/00 tJb . (2) During Week Two, from Tuesday at 100 pnl unlil Wednesday at noon or at such time as she delivers the children to school during the school year, (3) During Week Three, from Monday at noon unlil Tuesday at noon or such time as she delivers the children to school dUring the school year, (4) During Week Four, from Friday at noon until Sunday at900 a,m and from noon on Wednesday until noon on Thursday or such time as she delivers the children to school during the school year, (5) For three (3) uninterrupted weeks during the SUll1mer, which weeks are to be defined as seven days, Father shall also have custody of the children for three uninterrupted weeks during the summer The parties will give each other 60 days written notice in advance of the time when they wish to exercise their weeks of custody during the summer, In the event that there Is a conflict In the weeks scheduled for vacation, the party who notifies the other first shall have preference, None of the three weeks of custody In the summer for either party shall be consecutive, but either party may take a vacation week prior to or subsequent to a custodial weekend (6) For seven (7) days during the school year during which time the children are not required to attend school, Father shall have seven (7) days during the school year for custody of the childlen as well. The parties shall provide each other 60 days notice for the periods of school year vacation which they Intend to take 5 The parties shall share transportalion on the weekends with the receiving party picking up For mid-week visits, Mother shall provide the transportation to and from the periods of partial custody, Nevertheless, if it is convenient for Father to pick up the children or to deliver them on his way to or from work, he may provide the transportation 6 Mothel Will be responsible for getllng the children to school on time dUring her penods 01 partial custody She Will not withdraw them from school or call them off sick without consulling With Father by 600 a m on the mornings she believes the children cannot attend 2 umberger Ittpulltton IJb 08/31/00 school by virtue of illness or some other compelling reason, Father will notify Mother by 8:00 a,m, when the children are too ill to attend school, 7, In the event that the children require daycare while in Mother's custody, they will be brought to their primary daycare provider, Tricia Zeigler. Mother agrees that Tricia Zeigler Will provide daycare in the event that she must leave the children unattended for more than three hours, In the event that Mother has notice that she will require Tricia Zeigler's services, she will provide Ms, Zeigler one week advance notice or as much notice as Mother herself receives, 8, The parties will cooperate In the scheduling of the children's extra curricular activities, Whichever party has custody of the children will see to it that they attend their extra curricular activities In a timely manner. 9, For the school year, the parties will be In charge of seeing to it that the children complete their homework during their periods of custody and will provide them with a lunch and appropriate school clothing, 10, The parties shall alternate custody of the children over the following holidays: A, ~: The Christmas holiday shall be divided Into Segment A, which shall run from December 24 at 2:00 p,m. through Christmas Day at 2:00 pm" and Segll1ent B, which shall run froll1 Christmas Day at 2:00 p,m, through December 26 at 2:00 p,m, Mother shall have custody of the children during Segment A in odd numbered years and during Segment B in even nUll1bered years and Father shall have custody of the children during Segll1ent A In even numbered years and during Segll1ent B In odd numbered years, The party who has custody of the children during Segment B shall also have custody of the children for the first half of the remaining vacation days before school resumes after the Chrlstll1as holiday, The party who has custody of the children during Segment A shall also have custody of the children during the second half of the remaining vacation days before school resumes after the Christmas holiday, For purposes of this paragraph, the remaining vacation period shall run from December 26 at 2:00 p,m. through the day before school resumes at 600 p.m, B, THANKSGIVING/EASTER: Mother shall have custody of the children on Thanksgiving Day and Easter Sunday froll1 9:00 a,m, until 200 P,Il1 in odd numbered 3 ;;: lfl ,. ." c f; wh ~: , (' , - " l-~ : (',! 1_'.. );j ,,,, , 'I ;. r.~ I :- , rl'I r 'l;i. . I, ,':" I ( , ':1 Ij I.