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HomeMy WebLinkAbout95-03339 V) """ ~ ~ '1 I/J \.. ~ C c:J ~ '~ F J .\.,' ANITA CONNORS, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 3880 S 1987 .7/A. t}~~ :3:5 3<] ()..i;i..I r..u-- v. JAMES CONNORS, Defendant CIVIL ACTION - LAW CUSTODY/VISITATION ORDER OF COURT ~~D NOW, this ~ day of , 1995, upon consideration of the enclosed Petit n to Transfer Venue, it is HEREBY ORDERED AND DECREED, that venue in this custody action be transferred to the Cumberland County Court of Common Pleas. ,..,0 ~... .o.i" ., t"'II~.1; ..~ ~:'"l"'f~ :I"..U-n,., ~~;;:'? I-~ :J: ..:( r;.) ..~ CJ:c. -., t..OO"'" ~':l~n I";:~f" .., ~. ...'"' "" ? "" N - ~ ;;:; Q ./: ~ !.O ..... ~ .. " . ~&.~~ III ~ - Ci ~ r, f: fl' ~"v ANITA CONNORS, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 3880 S 1987 7v. 'h."- 333'1 n . . I "'.J.-- CIVIL ACTION - LAW ~ CUSTODY/VISITATION v. JAMES CONNORS, Defendant PETITION TO TRANSFER VENUE 1. Plaintiff is Anita Connors, an adult individual residing at Thirty Second Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defenrtant is James Connors, an adult individual residing at 4 Ash Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Parties have agreed to modification of the existing Custody Order, dated December 31, 1987. (See attached Exhibit "A") 4. The parties and the minor children have resided in Cumberland County for more than six (6) months. 5. The parties agree to the change in venue in this matter from Dauphin to Cumberland County. Respectfully submitted, By: /{(Adll\LLLL~ e tt::.:d.,--~. Marianne E. Rudebusch, Esquire 845 Sir Thomas Court, Suite 11A Harrisburg, PA 17109 (717) 657-0632 Attorney for Defendant . . IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 3880 S 1987 CIVIL ACTION - LAW CUSTODY/VISITATION ANITA CONNORS, Plaintiff v. . . JAMES CONNORS, Defendant . . . . MODIFICATION OF CUSTODY AGREEMENT WHEREAS, Anita Connors (Mother), and James Connors (Father), are the parents of two minor children, to wit: James M. Connors, Jr. born, October 22, 1981 and Stephen P. Connors, born March 20, 1984. WHEREAS, Mother dnd Father were divorced on June 6, 1990 in the Court of Common Pleas of Cumberland County. WHEREAS, a Custody Order was issued on December 31, 1987, by the Court of Common Pleas of Dauphin County. Attached as Exhibit "All. WHEREAS, Mother and Father shall share legal custody of the minor children. Mother shall have primary physical custody of the minor child, James M. Connors, Jr. Father shall retain primary physical custody of the minor child, Stephen P. Connors. WHEREAS, Father shall have partial custody of the minor child, James P. Connors, in the form of visitation, in accordance with the following schedule: (a) Alternate weekends from Friday at 6:00 p.m. through Sunday at 6:00 p.m. (b) During the summer months of June, July, and August, Defendant shall be entitled to two, two-week segments. However, Defendant shall give the plaintiff at least thirty (30) days advance notice of his intent to utilize said visitation. (c) The parties shall alternate custody of the child on the following holidays: New Year's Day, Easter, President's Day, Memorial Day, Independence Day, Labor Day, and Thanksgiving. The times for this visitation shall begin with the Defendant having the children for Easter of 1995. (d) The Christmas holiday shall be divided into two (2) segments; segment "A" shall be defined as December 24 at noon through December 25 at noon, and segment "B" shall be defined as December 25 at noon through December 26 at noon. This visitation shall begin with the Defendant having segment "A" for 1995 and shall alternate thereafter. , A/I pJlA I p' :I J],r.I/e d Witness ' (LA- &Ai 'Pl. ~~ ~mes. M. Connors witness /2nLi,,-,Y ((!i c/H.C'1..o- Anita Connors _L . - ANITA CONNORS, Plaintif f v. JAMl:5 CONNORS, Defendant IN THE COURT OF C~~ON PLEAS DAUPHIN COUNTY, PENl/SYLVANIA NO. 3880 S 1987 CIVIL ACTION CUSTODY/VISITATION ORDER Of' COURT AND NOW, to wi t, this",? //0 t-. cr~;1 , the parties having appeared day ~f~ ('PA1<.k.;" counsel for a Custody Conciliation Conference on December 30, with their respective 1987, and having reached an agreement, IT IS HEREBY ORDERED AND DECREED as follows: 1. Primary physical custody of the minor children, James Michael, Jr., and,Stephen Patrick, shall be in the Defendant, James Connors. 2. Partial custody in the form of vi5itation shall be in the Plaintiff, Anita Connors, in accorcance with the following schedule: la) Alternate weekencs :rom Friday at 6:00 p.~. through Sunday at 6:00 p.:::. Said lo'eekends to beg:':! on January 1, 1988. It is contemplated by the parties that, generally speaking, 0:1 the weekencs that the ?lainti== has such partial custocy with these children tha. the children of Mr, Sprout will not be in attendance. I j Ii !! f;XIIIIlIT "A" .' ....... - ..... , ,," .. ' (b) During the sununer months of June, July, and August. Plaintiff shall be entitled to two ~wo-wcck segments. However, Plaintiff shall gil'e the Defendant at least thirty (30) cays advance notice of her lntent to utilize said visitation. (c) The parties shall alternate custody of the ...-....... ,.-. chUdr..e,I''''Ol1 the ZoHold'TTV 'holidays: .. ..-" -., ' New ~ear's Day, Easter, President's Day, Memorial Day, Independence Day, Labor Day, and Thanksgiving. The times for this visitation 5hall be from 9:00 a.m. through 7:00 p.m. and this visitation shall begin with the Plaintiff having the children for Easter of 1988. (d) The Christmas holiday shall be divided in two segments: segment "A" shall be defined a:; December 24 at noon through De:::er.-.ber 2S at noon, and segment "B" shall be defined as December 25 at nocn through December 26 at noon. This visitation shall begin with the Plaintiff having Segment nA" for 1988 and shall altern~t~ thereafter. ..-... ,,-'.' -,.__. .. By the Co!::::'t: I . c I .' II \! :i I ~ J. , I fJp l'ii.~ Il'o;.. ~tYi~-t<hC forego! is :'. true a.:;d correot 00 y of the Qri, v.l filed. ..' I'*', t!- .# Prothonotary , .'. ,I I I. ! '1.-. f-,. 11/' _/ ,:;) pt' " OF .r\/?y f/4R /7 IU 29 AH '95 DAUPH:. ,', ~ I., . ,- , . PF/,<, ' ", r .. I. ~ ~ ~ ..~.. l\lARlANNE Eo RUDEBLTSCH, EStlUire 845 Sir Thomas Court, Harrisburg, PA 17109 (7.17) 657,.J632 '.' , I I I i I . I I ! I ! ANITA CONNORS, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 3880 S 1987 CIVIL ACTION - LAW CUSTODY/VISITATION v. JAMES CONNORS, Defendant PETITION TO TRANSFER VENUE 1. Plaintiff is Anita Connors, an adult individual residing at Thirty Second Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is James Connors, an adult individual residing at 4 Ash Drive, Mechanicsburg, Cumberland County, pennsylvania, 17055. 3. Parties have agreed to modification of the existing Custody Order, dated December 31, 1987. (See attached Exhibit "A") 4. The parties and the minor children have resided in Cumberland County for more than six (6) months. 5. The parties agree to the change in venue in this matter from Dauphin to Cumberland County. /, . )f 1 t/lIA.-It4 . t.(./IA'bn~__ Anita Connors ~Jv.~ ~es Connors . ANITA cnlNORS ,: IN THE COURT OF COMMON PLEAS Plaintiff DAUPHIN COUNTY, peNNSYLVANIA CIVIL ACTION CUSTODY/VISITATION v. JJ\MES CCtolNORS . ,. Defendant : NO. 3880 s ..!2!!1. ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before 1-lIIRIA P. C(X;NETI'I , the Conciliator, on the 2nd day of Novanber , 1987, at 11.J6 ~.m., in the Lawyers-Lounge, Dauphin County Courthouse~ Front & Market Streets, Harrisburg, Pennsylvania, for a Pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five or older shall also be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. I Cl _.,;' ,"J ~/, For The Court, Date of Order: 10-7-87 BY'~~~' YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, PA 17101 C" <:) "0 " .-. ... :7.l r.~ 0 ::0 w, -, " n' ~ ., ." ,. " ,- rr, ., - ; , , :.-- ..'#- - I " -......,.. '" 'oj ". M..\, ... ~c- -I S .. :... =' c.. = ..",. :z: .'J -i ~ ~ ~ -.. f i I I I i , , I I , i I I L.. ANITA CONNORS, I IN THE COURT OF COMMON PLEAS Plaintiff I DAUPHIN COUNTY, PENNSYLVANIA I v. I I NO. 388'0-.s 1987 JAMES CONNORS, I Defendant I . CIVIL ACTION - LAW-CUSTODY ORDER Yo~ James Connors, defendant, have been sued in court to obtain visitation of the children. James Michael, Jr., and Stephen Patrick. You are ordered to appear in person at on at .M. for a hearing. You are further ordered to bring with you the children, James Michael, Jr., and Stephen Patrick. If you fail to appear as provided by this Order or to bring the children, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. 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. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, Pennsylvania 17101 (717) 232-7536 BY THE COURT: J. ANITA CONNORS, ) IN THE COURT OF COMMON PLEAS Plaintiff ) DAUPHIN COUNTY, PENNSYLVANIA ) v. ) NO. 3~8'o . S 1987 ) JAMES CONNORS, ) Defendant ) CIVIL ACTION - LAW - CUSTODY COMPLAINT FOR VISITATION 1. The Plaintiff is Anita Connors, residing at 485 Slaseman Drive, New Cumberland, Pennsylvania. 2. Defendant is James Connors, residing at 2139 Derry Street, Harrisburg, Dauphin County, Pennsylvania 3. The plaintiff seeks temporary custody of the following children: Name James Michael Jr. Present Residence Age 10/22/8l(6yrs) 3/30/84(3yrs) 2139 Derry Street, Hbg., Pa. 2139 Derry Street, Hbg.. Pa. Stephen Patrick The children were not born out of wedlock and are presently in the custody of their natural father who resides at 2139 Derry Street, Harrisburg, Pennsylvania. During the past five (5) years, the children have resided with th~ fallowing persons and at the following addresses: 2139 Derry Street Harrisburg, Pennsylvania 1001 North Spring Street Middletown, Pennsylvania The mother of the children is currently residing at 485 Slaseman Drive, New Cumberland, Pennsylvania. She is separated. The father of the children is currently residing at 2139 Derry street, Harrisburg, Pennsylvania. He is separated. 4. Plaintiff is the natural mother of the children. 5. Defendant is the natural father of the children. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the ohildren will be served by granting custody in the plaintiff and natural mother. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant her custody of the children aocording to the fOllowing schedule: General custody of the said children James Miohael Jr., and stephen Patriok shall be with their father James Connors, subject to the following rights of temporary custody and visitation: a. The mother shall have temporary oustody of said children on alternate weekends from 6:00 O'clock p.m. on Friday until 6:00 o'clock p.m. on Sunday. This arrangement will begin on the weekend of October 1987. It will be the responsibility of the mother to pick up and deliver the children from and to their home at the approximate times. b. During the summer months of June, JUly and August the mother shall have the right of temporary custody of the said children for a four week period which period may be divided. Mother shall give father a two week advance notice of the time(s) of visitation under this paragraph. c. Mother shall have the right of temporary custody of the said children on alternate public holidays and on the birthdays of the said children, except that on birthdays and Christmas Day, each parent will have custody for one-half (1/2) day. The following hOlidays are contemplated by this Order. New Year's f Day, Easter, President I s Day, Memorial Day, Independence Day, Labor Day, Thanksgiving Day, Christmas Day and birthdays of the said children. Respectfully submitted, p.e. 17108 VERIFICATION I, Anita Connors, hereby verify that the statements made in the f(\regoing Complaint For Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to the authorities. (i/ll~ ttJ... trTn4Ur?L) Anita Connors . ~ "...<;/' - >- - -, ~ .... o ::a:: 0- - =- Q I\~'I' 'n Q ~ .' co \1'1'- 0 >- r>~ - ~~ ~ '.::loOt , .lZ >- c: O'::;"~ I...t.O!'':' ?' '.u':~~ l?- => - .'_ M - -.".:'-: .;: u.J ';-:0. UJu-:J: c:;....1- 00 .:r. a.. .... ~ ;;:0 ~ o . ., .. : . ' L .'" ANITA CONNORS ,: IN ':H!: COUl\': OF CO:,L'IOr: PLEAS r~a:':1~i:: DAt;PHI1: CO:::::'Y, pI:rn:SY:'VAUIA \' . NO. 3880 S 1987 JAMES CONNORS . , . vc:en~an~ : CUSTODY :::NS':i'.U:TIONS x Case settlec - ~ee a~~a=hed Oreer Case con~::'::::ec - Case not . , se::.:.eo. No Interi~ Order See a~tached In~erim Order Assic;r: '::) J'JCS= ::.e-;'.3 sign -..... -."........0 0.1__:_ -~''''''''.'..L_.:'.t<-t. ~' . . , It .~~..-:----...:..... -~.-',~ , -- , lit ANITA CONNORS, Plaintiff IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA NO. 3880 S 1987 v. JAMES CONNORS, : CIVIL ACTION CUSTODY/VISITATION Defendant ORDER OF COURT day of \). ~ u.... ~ ..........J , AND NOW, to wit, this ~ JiB\'.' . the part~es having appeared with their respective counsel for a Custody Conciliation Conference on December 30, 1987, and having reached an agreement, IT IS HEREBY ORDERED AND DECREED as follows: 1. Primary physical custody of the minor children, James Michael, Jr., and Stephen Patrick, shall be in the Defendant, James Connors. 2. Partial custody in the form of visitation shall be in the Plaintiff, Anita Connors, in accordance with the following schedule: (a) Alternate weekends from Friday at 6:00 p.m. through Sunday at 6:00 p.m. Said weekends to begin on January 1, 1988. It is contemplated by the parties that, generally speaking, on the weekends that the Plaintiff has such partial custody with these children that the children of Mr. Sprout will not be in attendance. '~r " : " _~...,_,.2..':..~..;.,.:~.. '...;'}! } '1 ~L \:-- " "',~.,':' ,'I: - f '~ ,1'--' ,f 1.( , ; ~ :' i ~:r' '^,"" ,'< , , , ! t ~ . ';1 , , , t " , , ,-.' " : <! .. , ~, ,., : 1,/ .-~ , '!1\ .:i '~CJ ,"I.f ~"_!d ..... ^.' . ~ T i J '.. , 1" 1 . ~, ~_~, 1 <' ~:. ') ~ (;-,1 I., ;'I.ri" '! ~ n f n "';::1 :"' (~ ~ J i I:: i'!" ,l ,",! ,":,1<'1(, i r:;r;-, . ! .>; '-l~~,,'-y! ,'f -~ ~!, ; J 1 ~ ' -, . . ',' IJj;:" i,l- " ti ii','", ,-'.., '-,' 't.J'..:';t' <. T.rt:.! ;,'r;'1' r:.r. ;'1 .if ,;; L( :.1 '." -'. ,'(. . ~!: , ; f." .~. r" 1 ~ [1: , ~. "; . ~, ': I;;'d:~ . i)"Jj~~ ii .. '.,'. ." : i '. . ;" ''':" :~'t!'(1 .~. . ,'f ,;;t".. :.n: '::1) ';'\1\1 ',.1 , '/' ,ut!:lt'i, Lf1 W] B'l ! 1 Ol ", ','. -,,', ,~,'" :.' ',,, <<, u' Ii i ,'!!,.;, i ~.' i . \, I ~JiY. :i' :': c' \,", /\' . 10/\ 1;:' rq ~,n","tf'~- ..'",;. :. (;'. ;~ ~ r ',' 'c.-"i.' ,,[. " ! ,- -. i '. ~ : ; :.!~:-O r !. '\ ",'" ,:; ',fJr~\~ ,{j '1;1 ., . ~~ ",;~ J ,!., . '~, ; ('J,' "f.... I ~ J~n ".j,- , I 'l:;;p I ~ ~,: . ; ":',~! :' ',; ":" , Ii I' ;1 r ,I II i! ri I ;; H , ~', I.,., Ii .I i' I: ij i, " II I J " H " it II d Ii II ii I, II .I 'I h I I' ,I II I I, 'I II II jl 'd U I: :j I Ii ,I " " ...:. . ~ (b) During the summer months of June, July, and August, Plaintiff shall be entitled to two two-week segments. However, Plaintiff shall give the Defendant at least thirty (30) days advance notice of her intent to utilize said visitation. (c) The parties shall alternate custody of the children on the following holidays: New Year's Day, Easter, president's Day, Memorial Day, Independence Day, Labor Day, and Thanksgiving. The times for this visitation shall be from 9:00 a.m. through 7:00 p.m. and this visitation shall begin with the Plaintiff having the children for Easter of 1988. (d) The Christmas holiday shall be divided in two segments: segment "A" shall be defined as December 24 at noon through December 25 at noon, and segment "B" shall be defined as December 25 at noon through December 26 at noon. This visitation shall begin with the Plaintiff having Segment "A" for 1988 and shall alternate thereafter. J. . >. , , \.. ~,. ,~. .,....~ . ~~~~ :\'1. ft.,.. ... \'\ ,; ~i.' ,... ) . ~ t,i;1 " li , ., I,; ,-If! " '/; ~ (.' ."0 i: 1 S. 'J" , ! 'J "~-',' ;, ~'~.' ~ r r~ , 1;' i' 'it . i I~. '." , '.' f f ~ '.hl ",1 ;'/I.,(tl -J;- 1 ~ . "':\ :1 j,-, li.! \.: 1'f. . Jh(j , , :q ";r- . .~ ~,' :1 ~...:1 J.e r',r "'~ ' I ! ~ . : ! ~ " ,', , " ,.. 0" ';.\ t/; ,-(:., "'1 -,,~ ' .,'. ;!! fC" (,.j (,!'j ", ~'" ':i { ,", I,,) ", ~ l' : I ~! .' 'J" .-" _-f'; '. '~"~d:j.~:,..:,.::: ,:;,1- 'l:--' ".'" , ;-li)mr'~l'-' :;:;,1" l"j::'}:.:. .' . ' ~ ~.. :;: .,;,11 :,,;.,' rl ;!r !_~ ,"::',' -t !'! ~-Ir,' " ",' i' " ". .!!';, ";~J.tj . .~, ." J (j ~ ;,,' .: 1 ~.) ~ ;' ~ :; (f! ., t, ; \"l! : ~ j '! J b ~-, -; "J r: ,. , , -t , ! .~- i, .;~ p .~ r~ -, /, c J f: r.:n ~'," . ,1";:, .. .,' Ht<,.'.r' ,!l '1 ",,,,,',,," _r~ \ \ .~,-_~j; , - .........-., "J ~/ I.' , ' ,~ ! ''', 1(: <'::'\'~ I! L c \ ' I r Jin 1'1 ..... ..,.... it I Ii .' " , ;\ il ;1 II Ii jj II I I ,I II " r .I II ~I Ii II , ," Ii II lj I' II I I I I :'. ! ~ I !. I! il j' :, II j! jl I' I' :1 !; I' I! 1. .. " ANITA CONNORS ,: IN THE COURT OF CO~L~ON PLEAS Plai~ti=f DAUPHIU COt.:::-:y, PE:n;SY:'V;':;IA v. NO. 3880 S 1987 JAMES CONNORS . , . De:e~~an~ : CUSTODY H1STRUCTIONS x Case settled - see a~tached Order Case con~inuec - Case net settled No Interim Order See attach~d Interim Order Assign ':0 JUdge Re-Assi;n ~o JUdge .. . '. I . , , -. '. \ , . , -~~._-=---__..-.a.,~~. . " \. h~~ " ,\ till\! rt .~ II .,)1 "n ;'Y ~ ~", .. " ," ~ ,t ,- ~~, ~'""'7-'_ ...~":.. . -... ~ . , . . - ".",.. . -. , ... .. /I"t N/,/~'.c '. . 'J"". /..~/ /-~ .." .,1 /~' ANITA CONNORS, . IN THE COURT OF COMMON PLEAS . Plaintiff . DAUPHIN COUNTY, PENNSYLVANIA . . . -v- . NO. 3880 S 1987 . . . JAMES CONNORS, . CIVIL ACTION LAW . Defendant : CUSTODY/VISITATION AMENDED ORDER OF COURT AND NOW, to wit, this I) -tl day of 1Yl~1 I <Y'i"~1 Bllclllllbllr, 1987, the parties having appeared with their respective counsel for a Custody Conciliation Conference on Decembsr 30, 1987, and having reached an agreement, IT IS HEREBY ORDERED AND DECREED as followS: I. Primary physical custody of the minor children, James Michael, Jr., and stephen Patrick, shall be in the Defendant, James Connors. 2. Partial custody in the form of visitation shall be in the Plaintiff, Anita Connors, in accordance with the following schedule: (a) Alternate weekends from Friday at 6:00 p.m. through Sunday at 6:00 p.m. Said weekends to begin on January I, 1988. It is contemplated by the parties that, generally speaking, on the weekends that the Plaintiff has such partial custody with these children that the children of Mr. Sprout will not be in attendance. (b) During the summer months, July, and August, .'~ '. . . . Plaintiff shall be entitled to two two-week segments. However, Plaintiff shall give the Defendant at lest thirty (30) days advance notice or her intent to utilize said visitation. (c) The parties shall alternate custody of the children on the following holidays: New Year's Day, Easter, President's Day, Memorial Day, Independence Day, Labor Day, and Thanksgiving. The times for this visitation shall be from 9:00 a.m. through 7:00 p.m. and this visitation shall begin with the Plaintiff having the children for Easter of 1988. (d) The Christmas holiday shall be divided in two segments; segment "A" shall be defined as December 24 at noon through December 25 at noon, and segment "B" shall be defined as December 25 at noon through December 26 at noon. This visitation shall begin with the Plaintiff having Segment "A" for 1988 and shall alternate thereafter. (e) The parties shall share custody of the children on their respective birthdays as follows: The non-custodial parent shall enjoy visitation with both boys (the birthday boy and his brother) on the evening before the birthday from 6:00 p.m. to 9:00 p.m. The custodial parent will keep the boys on the birthday itself. If a birthday falls on a weekend when Plaintiff has custody, Defendant will be the non-custodial parent and will have birthday visitation according to the above schedule. / , . ( J. , . . . . -....... ....~. z ,- " --' ,.......:. -'.': - ~- ~ '":4- ;"-0 " ::.:;. ~.' -, -' -' ,0 5 , "iile.. ~....~ Ent...,,! ,"; - ,~.-i ...._... f _. ANITA CONNORS, Plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-3339 CIVIL ACTION - LAW CUSTODY/VISITATION v. JAMES CONNORS, Defendant AND NOW, this ORDER OF COURT ~ day of consideration of the , 1995, upon for Modification of a Custody Agreement, it is HEREBY ORDERED AND DECREED, that the attached Custody Agreement in this custody action be entered as an order of Court. BY THE COURT: /J/ """' = .-, ..~ . , ., J ,.:: c:? c., (.~-I ,..- ::c -~ . ....; <.J"O -" ANITA CONNORS, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-3339 v. JAMES CONNORS, Defendant CIVIL ACTION - LAW CUSTODY/VISITATION MODIFICATION OF CUSTODY AGREEMENT WHEREAS, Anita Connors (Mother), and James Connors (Father), are the parents of two minor children, to wit: James M. Connors, Jr. born, October 22, 1981 and Stephen P. Connors, born March 20, 1984. WHEREAS, Mother and Father were divorced on June 6, 1990 in the Court of Common Pleas of Cumberland County. WHEREAS, a Custody Order was issued on December 31, 1987, by the Court of Common pleas of Dauphin County. Attached as Exhibit "A". WHEREAS, Mother and Father shall share legal custody of the minor children. Mother shall have primary physical custody of the minor child, James M. Connors, Jr. Father shall retain primary physical custody of the minor child, Stephen P. Connors. WHEREAS, Father shall have partial custody of the minor child, James P. Connors, in the form of visitation, in accordance with the following schedule: -. ~ (a) Alternate weekends from Friday at 6:00 p.m. through Sundar at 6:00 p.m. (b) During the summer months of June, July, and August, Defendant shall be entitled to two, two-week segments. However, Defendant shall give the Plaintiff at least thirty (30) days advance notice of his intent to utilize said visitation. (c) The parties shall alternate custody of the child on the following holidays: New Year's Day, Easter, President's Day, Memorial Day, Independence Day, Labor Day, and Thanksgiving. The times for this visitation shall begin with the Defendant having the children for Easter of 1995. (d) The Christmas holiday shall be divided into two (2) segments; segment "A" shall be defined as December 24 at noon through December 25 at noon, and segment "B" shall be defined as December 25 at noon through December 26 at noon. This visitation shall begin with the Defendant having Segment "A" for 1995 and shall alternate thereafter. . Al"IlA I ,',:l12r.1;e ~1 Witness (LA. ..A) 'Pl, r~~ ~mes. M. Connors Witness th " '-I 1 u.j[~.....~, (lhv/. /..tV..l- Anita Connors _L . .' ANITA CONNORS, IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 3880 S 1987 CIVIL ACTION CUSTODY/VISITATION Plaintiff v. JAMES CONNORS, Defendant ..- ORDER Of' COURT -- "-AND' ;OW, to wit, thi-~/;Ot-. day ~f~ "PA")(.f.p.;,~ cr~J , the parties having appeared with their respective counsel for a Custody Conciliation Conference on December 30, .- ..... 1987, and having reached an agreement, IT IS HEREBY OROERED AND DECREED as follows: 1. Primary physical custody of the minor children, James Michael, Jr., and,Stephen Patrick, shall be in the Oefendant, James Connors. 2. Partial custody in the form of vi5itation shall ~e in the Plaintiff, Anita Connors, in accordance with the fOllowing schedule: (a) Alternate weekends ~rom Friday at 6:00 p.m. :hrough Sunday et 6: 00 p.lll'. Said weallends to begi:! aD . January 1, 1988. It is contemplated by the parties that, generally speaking, o~ the weekends that the Plaintiff has ,such partial custody with these children that the children of Mr. Sprout will not be in attendance. .' I i H EXlltBIT "A" .'11I" .- ., ~.. . .. (b) During the summer months of June, July, and August. Plaintiff ahall be entitled to two two-week segments. However, Plaintiff shall give the Defendant at least thirty (30) days advance notice of her intent to utilize said visitation. lc) The parties shall alternate custody of the o _'M ..._u.o .,.-. ehJ.,~r-vil""on the ;:oHold~ 'hol Ida}'s: ., '.-'-" New Yea:-'s Day, Zaster, President's Day, Memorial Day, Independence Day, Labor Day, and Thanksgiving. The times for this visitation shall be from 9:00 a.m. through 7:00 p.m. and this visitation shall begin with the Plaintiff having the children for Easter of 1988. (d) The Christmas holiday shall be divided in two segments; segment "A" ilhall be defined ail Deoembcr 24 at noon through De::er..ber 25 at noon, and segment "5" shall be defined as December 25 at noon through Decemoer 26 at noon. This visitation shall begin with the Plaintiff having Segment "A" for 1988 and shall altern~t~ thereafter. .............-.. -...- .. ....--... By the Court: ~(!. I . I " Ii II :i ~ ~ J. , O' ,pj? ('ij": tlby ~h~-t<hC forii'gOi is ~ true r.J:d oorreot 00 y' of the ari <'.1 filed. /--. t!- , L c* TOTAL PAGE.004 ** @ ~ - ?;~ -TO- :c _-:-.'":..: a... ~~ ~: L: ;r. ~ :~~~~~::': r-ll--. ~r / ("I") . ~ IJI 1__,t!.Z , ,iJj-z t-....I ,_ :~. ::-:~ ,.~ '" ~v L'> => << . - /. MAR1ANNE E. RUDEBUSCH, Esquire 845 Sir Thomas Court, Harrisburg, PA 17109 (717) 657-0632 AUG 0 3 199~~ ,I': .~.r ~f bo ::a '1 ~ J~ ~ . . o "'fV <"/ o{, J) 3 ') Ct.;.;...I ~'- ... f rlln,..d t\,.: R"mht.,..~ -.Iotln II.J91 o ,I 0 COURT-OF COMMON PLEAS DAUPHIN COUNTY CIVIL ACTION SUITS 1987 111- S 3880 I ------ Com lalnl X ) --- ~- .-. Dale of Enlry October' 2 19 B7 Pelllloll C A eal C Wrll of Exec:ullon Issued: Custody f Tres ass C Appeerance For: Assum III I Plalnllff: Melville G.H. Walw PC VIsitation f X ) Divorce Defendanl: Morl a e F oreclolure ( ) OIan e of Name << I Ejeclmenl << ) Anita Connor's leI Tille I VB Appl. of Viewers ) JameB Connor' Re levln << I Declarallon of Taklns << ) Fonna Pauperis << I MenIal Heallh << ) Prolecllve Order ( I DIstrict Maslstrate ( I ~lall<:A 7, 1988 - TIll! Llit!LIl Ilt!", t!cl,Lvt! c.oun"t!1. Oil a. ell"',,,d!! [oneL1.i.aU.on [on(t!llcnr~c on iJceembt!1l ]0, 1987, und IlavLn . llt!ac./,t!d u ,Ilt!e-- mt'nl" IT IS 1If..'illflY O'il/Jl'ilf..!J IIIt'i! iJlC.'illltJ a" (oU,"",,: I. Plli.mClIlI A "i,.:a1. "1111.0.1 of I.At! mLnOIl c.AL1.dllcn, 9amt!" ~Lc.Aae1., 91l. and Stt! Aen PatllLek "Aall bt! Ln tAt! OcfcndClnl., 9C1mc" (onnoll". 2. PalltLa1. ell"tod La tAt! vL"Ltlltion 1ha1.1. in t./,. Pla;,nU.f/, IIn;,I,,, (:oJ'lI'tlll", La uc.c.tlfl(/t!no~p. ",;,/./, t./,t! ,,J.1.owLar. ".,~/,edIlJe.....: Jee {(lml'l.c/,t! IImr.ndr.d (}lldt!1l 0 [Olllll" LLt!d." 901111 L. dowLLII 'Iud ,(!. Amount Amount Flllns Fee Ally, Appearance Sherlrros Costs Discontinuance Rule or Reference 35 50 Adm. Fee - Divorce Allm. Fee - Custody "I',,'t, or Master Cash Bond Escrow Funds 65 00 __ 3!l~O S 1987 AnLta Conno~~ v~ Jame~ Conno~~ ~'::.."!:.....?_'_ _ t~!~__- Upon considern tion of the enclosed is HEREBY ORDERED AND DECREED, that venue in this --.!.o th~ Cumberland County Court of Common Pleu. See Order of Court Filed. --- - .--- -...--.---------------.--.-----------, -. ~.._-- June 9 1995 - The above actLon L~ t~an~6e~~ed tothe Cou~t 06 Common Plea~ 06 Cumbe~tand County. i h""#-.. ~'Ul<ll~~n:;. troo anu 'vi;;, _..~: ...v -----------. Petition to TranBrer,V~nup, it custody action bet~ilnB'iP.~r('d ----...- . /~! William W. Lipsitt, Juda