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JUDITH CHRISTINE WILLIAMS,
PLAINTn'..
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IN THE COURT 0.. COMMON PLIAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 95 - 3348 CIVIL TERM
v.
.
.
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STEPHEN ANDREW McCULLOUGH,
DEP'BNDANT
.
.
.
.
CUSTODY
MEMORANDUM
The Plaintiff, Judith Christine Williams (Mother), and the
Defendant, Stephen Andrew McCullough (Father), are the parents of
one (1) child, Owen Kenley Williams (age 1). Neither parent has
any other children. The parties never married. Mother lives with
her parents and siblings in Carlisle, Cumberland County,
Pennsylvania. Father lives alone in Shermansdale, Perry County,
Pennsylvania.
Following a conciliation conference this court issued an
order, dated August 10, 1995, granting Mother primary legal and
physical custody of OWen subject to Father's periods of visitation
and/or temporary or partial physical custody. The Order provided
that Mother was to keep Father reasonably advised of the child's
medical, educational progress and religious training. The Order
also stated that it was anticipated that as the child grew older
the custody arrangements would change.
Father has attempted to be an integral part of his son's life.
Mother has prevented and/or restricted Father's contact with OWen.
On February 28, 1996 Father filed a Petition To Modify Custody
seeking additional time with his son. A custody conciliation
conference was held on April 16, 1996. No final custody schedule
was reached at the conciliation. Mother agreed to allQw Father a
small increase in his time with his son, but refused to allow
Father to be alone with his son. Mother also agreed to take the
child to Father's parents at least once each month. Mother has
failed to take the child to Father's parents as agreed and ordered.
On June 13, 1996 an order was issued setting this matter for
a custody hearing on August B, 1996.
Father would like additional unsupervised time with his son.
He believes that he has an important role to play in his son's life
and would like the opportunity to build a relationship outside of
Mother's parents' home. Father has a strong extended family and
would like to make OWen a part of his family.
Father intends to have the following witnesses available for
testimony:
,
Stephen Andrew McCullough: He will testify as to his
abilities as a father and his desire to make his son part of his
life.
Judith Christine Williams: She will testify that Father has
consistently exercised his visitation rights and that he has
frequently requested additional custody periods. She will also
testify that she has denied Father the right to take his son out of
her parent's home.
Naomi McCullough (Father's mother): She will testify as to
her observations of her son with his child and his contact with
other members of his extended family. She will also testify
regarding Judith Christine Williams' statements regarding family.
Dennis Sipe (Father's employer): He will testify as to
Fathers work ethic, performance and reliability.
Catherine McCullough (Father's sister): She will testify as to
the reliability of her brother and the trust that she has in his
supervision of her young son.
Jen Fitz (Father's former landlord): She will testify as to
Father's characteristics as a tenant and to his relationship with
her small child.
Father would like a regular schedule of every other weekend
from Friday at 5:00 p.m. until Sunday at 7:00 p.m. and at least one
evening each week from 5:00 p.m. until 9:00 p.m.. He would also
like to alternate holidays and have at least four (4) uninterrupted
weeks during the year.
Respectfully submitted,
~~.~
Attorney for Defendant
: IN CUSTODY
JUDITH CHRISTINE WILLIAMS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY , PENNSYLVANIA
: NO, 95-3348 CIVIL TERM
V,
STEPHEN ANDREW MCCULLOUGH.
Defendant
PRAECIPE FOR ENTRANCE OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiff in the above-captioned action.
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Keith 8, DeAnnond, Esquire
2800 Market Street
Camp Hill, PA 17011
1.0,# 58878
(717) 730-9394
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-334B CIVIL TERM
JUDITH CHRISTINE WILLIAMS,
Plaintiff
STEPHEN ANDREW McCULLOUGH,
Defendant
IN CUSTODY
J
AND NOW, this '!J
ORDER
day of
, 1996, upon
drawal Appearance
consideration of the aforegoing Petition to
of Kristin R. Reinhold, Esquire, it is hereby ordered and decreed
that the Petition is granted/<h..l.:.d.
orge E. Hoffer
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JUDITH CHRISTINE WILLIAMS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-3348 CIVIL TERM
v.
STEVEN ANDREW McCULLOUGH,
Defendant
IN CUSTODY
PETITION TO WITHDRAWAL APPEARANCE
TO THE HONORABLE GEORGE E. HOFFER:
1. The Petitioner is Kristin R. Reinhold, Esquire,
counsel of recQrd for Judith Christine Williams, Plaintiff in the
above-captioned matter.
2. The above-captioned matter is a custody action.
3. The present action was instituted by a Petition to
Modify, filed by the Defendant, Steven Andrew McCullough on
February 2B, 1996. The parties were unable to reach an agreement
at the custody conciliation held before custody conciliator Dawn
S. Sunday, Esquire, on April 16, 1996. A custody trial has been
scheduled before the Honorable George E. Hoffer on August B,
1996.
4. Plaintiff, Judith Christine Williams, has indicated
to counsel that she no longer wishes counsel to represent her in
this matter. Plaintiff Judith Christine Williams has indicated
to counsel that she does intend to rete in new counsel sometime in
the future.
5. Counsel's withdrawal from this matter can be
accomplished without material adverse affect on the interest oi
the Plaintiff Judith Christine Williams as Plaintiff has
approximately seven weeks to obtain new counsel to represent her
in this matter.
WHEREFORE, your petitioner respectfully requests this
Honorable Court enter an Order granting her permission to
withdrawal as counsel for Plaintiff in the above-captioned
matter.
Date: ~/dL/ J q L
Respectful submitted,
The Law 0 ices of Silliker & Reinhold
Esquire
JUDITH CHRISTINE WILLIAMS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-3348 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
v.
STEVEN ANDREW McCULLOUGH,
Defendant
CBRTIFICATB OF SBRVICE
The undersigned, Beth L. Lengel, hereby certifies that a
copy of the Order and Petition to Withdrawal Appearance was served
uPQn Judith Christine Williams on June 25, 1996, by first-class
mail, postage prepaid, addressed as follows:
Judith Christine Williams
3903 Chestnut Street
Camp Hill, PA 17011
Date:
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^T'IORNI'YS ^lI.^W ""''' r 1!l96
lfJ.l sTAn STRI'H ,JrYl
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I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. 95-3348 CIVIL TERM S 1995
I
I CHILD ACTION - LAW
: CHXLD CUSTODY
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JUDITH CHRISTINE WILLXAMS,
Plaintiff
STEPHEN ANDREW MCCULLOUGH,
Defendant
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter the appearance of JACK HARDY, ESQUIRE, Attorney
at Law, on behalf of defendant, Stephen Andrew McCullough, in the
above-captioned matter.
By:
ardy,
4540
Olde English Gap
845 Sir Thomas Court
Suite 11 B
Harrisburg, PA 17109
(717) 541-4400
DATE:~
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CERTIFICATE OF SERVICE
I, JACK HARDY, ESQUIRE hereby certify that on this date I
served a copy of the Entry of Appearance by placing the same in the
United States Mail, First Class, postage prepaid in Harrisburg,
pennsylvania, addressed to the following:
Kristen R. Reinhold, Esquire
Silliker & Reinhold
204 State Street
Harrisburg, PA 17101
Date:
(\~l ~S
Samuel L. Andes, Esquire
Andes, Vaughn & Bangs
525 N. 12th Street
Lemoyne, PA 17043
By: l
ardy
Atto ney at Law
IDI 34540
845 Sir Thomas Court
Olde English Gap
Suite 11 B
Harrisburg, PA 17109-4B43
(717) 541-4404
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JUDITH CHRISTINE WILLIAMS,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 95-334S CIVIL TERM
CUSTODY
vs,
BTBPHEN ANDREW McCULLOUGH,
Defendant
AND NOW,
th10 {O "'do' .1
, 1995, upon consideration of the
conciliator's report, it appearing that the parties agreed upon the terms of this order
which was dictated in their presence and approved by them and their counsel, we hereby
order as follows:
1. Primary legal and physical custody of the minor child, Owen Kenley Williams,
born June 4. 1995, is hereby awarded to his mother, the Plaintiff. Judith Christine
Williams. The mother shall be responsible to keep the father reasonably advised of the
child's medical condition. educational progress, and religious training when and if
that becomes appropriate in the future.
2. The father shall have the right of visitation with the child, at the mother's
Ilhome or otherwise under the mother's supervision, every Tuesday from 7:00 p.m. until
'I 9:00 p.m. In addition, the father shall have such additional periods of temporary or
partial custody as the parties may mutually agree in the future.
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II 3. The parties recognize that this order is entered at a time when the child is
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IlonlY two months or less of age and anticipate that, as the child grows older. their
II arrangements for custody and partial or temporary custody of the child will change.
liAcCOrdinglV. in the event that at any time in the future the parties cannot agree upon
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any .odification of the schedule set out in this order, either party shall be free to
request the court, or the conciliator, to review this matter further and set an
appropriate schedule.
By the Court,
J.
Kristin R. Reinhold, Esquire
Attorney for Plaintiff
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Jack Hardy, Esquire
Attorney for Defendant
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IN THB COURT OF COMHON
PLEAS OF CUHBBRLAND
COUtITY, PBNNSYLVANIA
NO. 95-334B CIVIL TBRM
JUDITH CHRISTINB WILLIAHS,
Plaintiff
)
)
)
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)
)
CUSTODY
vs.
STBPHBN ANDRBW HcCULLOUGH,
Defendant
JUDGB PRBVIOUSLY ASSIGNBD: None (No Judicial Conflicts)
CONCILIATOR CONFERBNCB SIItItIAllY RBPORT
IN ACCORDANCB WITH CUHBBRLAND COUNTY RULB OF CIVIL PROCBDURB 1915.3-S(b), 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:
I
NAHB
BIRTHDATB
CURRBNTLY IN
CUSTODY OF
Owen Kenley Williams
4 June 1995
Plaintiff/Hother
,I 2. A Conciliation Conference was held on 1 August 1995 and the fOllowing
I
lindividuals were present: the Plaintiff and her attorney, Kristin R. Reinhold,
I Bsquire; the Defendant and his attorney, Jack Hardy, Bsquire.
I 3. This is an action involving a very young baby. Commendably, the parties were
able to reach agreement which made further proceedings unnecessary. Also cOMmendably,
both parties were able to recognize that this agreement is only valid while the child
is young.
4. The attached order was dictated in the presence of the parties and approved by
them. With the entry of this order. no further proceedings are necessary at this time.
~~
el L. Andes
Custody Conciliator
I B August 1995
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JUDITH CHRISTINE WILLIAMS, I IN THE COURT OF COMMON
plaintiff I PLEAS OF CUMBERLAND
I COUNTY, PENNSYLVANIA
vs. I
I NO. 95-3348 CIVIL TERM
STEPHEN ANDREW McCULLOUGH, I
Defendant ) CUSTODY
ORDEIl
AND NOW, this
day of
, 1995, upon consideration of the
conciliator's report, it appearing that the parties agreed upon the terms of this order
which was dictated in their presence and approved by them and their counsel, we hereby
order as follows:
1. Primary legal and physical custody of the minor child, Owen Kenley Williams,
born June 4. 1995, is hereby awarded to his mother. the Plaintiff. Judith Christine
Williams. The mother shall be responsible to keep the father reasonably advised of the
child's medical condition, educational progress, and religious training when and if
that becomes appropriate in the future.
2. The father shall have the right of visitation with the child, at the mother's
home or otherwise under the mother's supervision, every Tuesday from 7:00 p.m. until
9:00 p.m. In addition, the father shall have such additional periods of temporary or
partial custody as the parties may mutually agree in the future.
3. The parties recognize that this order is entered at a time when the child is
only two months or less of age and anticipate that, as the child grows older, their
arrangements for custody and partial or temporary custody of the child will change.
Accordingly. in the event that at any time in the future the parties cannot agree upon
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any IOdification of the schedule set out in this order. either party shall be free to
request the court, or tbe conciliator, to review this matter further and set an
appropriate schedule.
By the Court,
J.
Kristin R. Reinbold, Esquire
Attorney for Plaintiff
Jack Hardy, Esquire
Attorney for Defendant
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* JlArti~1 (\,(. ~"'11' W, Hi..... :IN 'l'HE COUR'l' OF COMMON PLEAS OF
Plaintiff :CUHBERLAND COUN'l'Y, PENNSYLVANIA
.
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V :CIVIL AC'l'ION - LAW
.
* Stf"Ph~ 1lIl'\f1..... M( (",110",)/1 ;NO. 15'-'33LIF CIVIL 19
Defendant :CUS'l'ODY/VISI-'l'A'l'ION
ORDER OF COUR~
/'lIt>.- r d, 5"; Here,
AND NOW, this (date) , upon consideration of the
attached complaint, it is hereby directed th t the partieq ang
their respective counsel appear before c:......" .s. .5",..."... t.
the conciliator, at AC.j Lt). (1'1..;" S.t. ('I7,-d,t.,,;, "',,5
on the I b t." day of I-Je" I , 19 fl-, at '/:0(/
.1.}.-. H., for a Prehearing Custody ConIerence. At such conference,
'n 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 temporazy order. Either
party may bring the child who is the subject of this custody
action to the conference, but the child/children's attendance is
not mandatory. Failure to appear at the conference may provide
grounds for entzy of a tempqrary or permanent order.
,
FOR 'l'HE COURT:
By' t2.~cdt.r c~
YOU SHOULD 'l'AKE 'l'HIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NO'l'
HAVE A LAWYER OR CANNO'l' AFFORD ONE, GO TO OR TELEPHONE 'l'HE OFFICE
SE'l' FOR'l'H BELOW TO FIND OU'l' WHERE YOU CAN GE'l' LEGAL HELP.
OFFICE OF THE COUR'l' ADHINIS'l'RA'l'OR
COUR'l'HOUSE, FOUR'l'H FLOOR
CARLISLE PA l70l3
(7l7 )240-6200
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JUDITH CHRISTINI WILLIAMS,
Plaintiff
IN THB COURT or COMMON PLBAS
CUMBBRLANDCOUNTY, PBNNSYLVANIA
Defendant
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~O. 95-3348 CIVIL TBRM
v.
STBPHBN ANDRIN McCULLOUGH,
CUSTODY ACTION
ORDBR
You, Judith Christine Williams, have been sued in Court to
modify custody, partial custody or visitation of the child: OWen
Kenl~v Williams.
You are ordered to appear in person before
at
on
conciliation conference.
If you fail to appear as provided by this Order, an Order for
custody, partial custody or visitation may be entered against you,
or the Court may issue a warrant for your arrest.
at
M. for a
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Office of the Court Administrator
Courthouse, 4th Floor
Carlisle, Pennsylvania 17013
Telephone No. (717) 240-6200
FOR THE COURT,
~
JUDITH CHRISTINI WILLIAMS,
Plaintiff
IN THB COURT or COMMON PLBAS
CUMBBRLANDCOUNTY, PBNNSYLVANIA
Defendant
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NO. 95-3348 CIVIL TBRM
v.
STIPHBN ANDRIN McCULLOUGH,
CUSTODY ACTION
PBTITION TO MODIFY CUSTODY ORDER
1. The Plaintiff is Judith Christine Williams residing at
3903 Chestnut Street, Camp Hill, Cumberland County, PA 17011.
2. The Defendant is Stephen Andrew McCullough, residing at
2258 Ruby Road, Harrisburg, Dauphin County, PA 17104.
Respectfully submitted
The Defendant seeks to Modify the Order dated August 10, 1995
by providing for unsupervised specific periods of Temporary
Physical Custody and providing that he be granted joint Legal
Custody of his child.
-rA'''''UUJ D. J}J11,dJ
Thomas D. Gould, Esquire
ID #36508
2 E. Main Street
Shiremanstown, PA 17011
(717) 731-1461
Fax 761-1974
..'
VlRIFICATION
I , Stephen A. McCullough, hereby certify that the foregoing
PBTITION TO MODIFY CUSTODY ORDER is true and correct to the best
of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
DATED:
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AUG G 9 1995
V
JUDITH CHRISTINE WILLIAHS, I IN THE COURT OF COHHON
Plaintiff I PLEAS OF CUHBERLAND
I COUNTY, PENNSYLVANIA
vs. I
I NO. 95-334S CIVIL TERH
STEPHEN ANDREW HcCULLOUGH, I
Defendant I CUSTODY
ORDER
.
AND NOW, this /o.tlv day of
~ ' 1995, upon consideration of the
conciliator's report, it appearing that the parties agreed upon the terms of this order
which was dictated in their presence and approved by them and their counsel, we hereby
order as follows:
1. Primary legal and physical custody of the minor child, Owen Kenley Williams,
born June 4, 1995, is hereby awarded to his mother, the Plaintiff, Judith Christine
. . .
Williams. The mother shall be responsible to keep the father reasonably advised of the
child's medical condition, educational progress, and religious training when and it
that becomes appropriate in the future.
2. The father shall have the right of visitation with the child, at the mother's
. . .:.
home or otherwise under the mother's supervision, every Tuesday from 7:00 p.m. until
9:00 p.m. In addition, the father shall have such additional periods of temporary or
partial custody as the parties may mutually agree in the future.
3. The parties recognize that this order is entered at a time when the child is
only two months or less of age and anticipate that, as the child grows older, their
arrangements for custody and partial or temporary custody of the child will change.
Accordingly, in the event that at any time in the future the parties cannot agree upon
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any modification of the schedule set out in this order. either party shall be free to
request the court. or the conciliator. to review this matter further and set an
appropriate schedule.
. By the Court,
Kristin R. Reinhold. Esquire
Attorney for Plaintiff
Jack Hardy, Esquire
Attorney for Defendant
." '.
In T~;'~~.. ~?~~ FP.l:'M RECORD
d : . II ;,..F. I h. m ll~to SJt my hand
or. the seal AB.d Courl al Carlisle, Pa.
This .......I.~..... day Of".....~..... ....... 19..1.:f.
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SHIRl-M.A.t~~-.'OWN PA 17011
717-7~1-14r.1
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JUDITH CHRISTINE WILLIAMS,
Plaintiff
IN THE COURT OF Ca1MON PLEAS OF
CUMBERLAND COUNTl!, PENNSYLVANIA
vs.
NO. 95-3348
CIVIL TERM
STEPHEN ANDREW McCULLOUGH,
Defendant
IN CUSTODY
OODBR OF cam
AND ~, this /3 'k day of
consideration of the attached Custody conciliat on
directed as follows:
I. A Hearing is scheduled in Court Room nurrber ..3 , of the
Currberland County Court House, on the f3 ,rel day of AU(AUA-, 1996,
at /:3.:) o'clock, -.I2.m., at which time testimony wil1 be;Jtaken in this
case. At this Hear~, the Father, Stephen Andrew McCullough, will 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 and also setting
forth a list of witnesses who will be called to testify at this Hearing
along with a SUlllllSry of the anticipated testimony of each witness. This
memorandum shall be filed at least ten (10) days prior to the Hearing date.
, 1996, upon
s ordered and
2. Pending the Hearing, this Court's prior Order of August 10,
1995 shall continue in effect with the following modification:
A. The Father shall have visitation with the Child at the
Mother's residence every Tuesday from 5:00 p.m. until 8:00
p.m.
B. During one weekend each month, the Mother shall transport
the Child on saturday morning to the paternal
grandparents' residence in Media, Pennsylvania where the
Child shall remain, (unsuperviSed by the Mother) until
late afternoon or evening of the following Sunday in the
paternal grandparents' care. The Father shall have
unlimited contact with the Child during these weekends
while the Child is in the paternal grandparents' care.
The. Mother shall provide all transportation for purposes
of this provision. The times and dates for the weekend
periods of custody shall be arranged by the parties.
,
3. The parties agree that they shall cooperate with eachother in
undergoing drug testing at the other party's request prior to Hearing.
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JUDITH CHRISTINE WILLIAMS, . IN THE COURT OF CQ'\MON PLEAS OF
.
Plaintiff : CUMBERLAND cotJNTY, PENNSYLVANIA
:
vs. . NO. 95-3348 CIVIL TERM
.
.
.
STEPHEN ANDREW MCCULLOUGH :
Defendant . IN CUSTODY
.
PRIOO JUDGB: George B. Hoffer
aBroDY aH:ILIATICIf 5lMlARY RBl'(Rl'
IN AaDUlANCB wrm l>>IBBRLAND CXXHlY R1ILB OF CIVIL PRe- .",,~
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The relevant information pertaining to the Child who is the
subject of this litigation is as follows:
NAME
BIRTHDATE
CURRENTLY IN CUSTODY OF
Owen Kenley Williams
June 4, 1995
Plaintiff/Mother
2. A Conciliation Conference was held on April 16, 1996 with the
following individuals in attendance: The Mother, Judith Christine Williams,
with her counsel, Kristin R. Reinhold, Esquire, and the Father, Stephen
Andrew McCullough, with his counsel, Thomas D. Gould, Esquire.
3. This Court's prior Order dated August IO, 1995 was entered as
a result of an agreement reached by the parties at a prior Custody
Conciliation Conference and awarded primary physical and legal custody to
the Mother with the Father to have visitation with the Child at the Mother's
hane on Tuesday evenings from 7:00 p.m. until 9:00 p.m. The Order
recognized that the visitation schedule would change as the Child grows
older as the Child was only two (2) months old at the time of the initial
Conference.
4. The Father
Order to obtain expanded
custody of the Child.
filed this Petition to Modify the August IO, 1995
and unsupervised partial custody and joint legal
5. The Father's position on custody is as follows: The Father
would like to have additional periods of custody with the Child which can
occur away from the Mother's residence. The Father stated that it is
distracting at the Mother's residence as older children play video games and
other activities in the same room. The Father stated that he is able to
care for the Child's needs and has experience in changing diapers and
feeding small children. The Father strenuously denied the Mother's
allegations regarding current drug use by the Father. The Father proposed a
gradually expanding partial custody schedule which would ultimately result
in periods of weekend overnight custody. The Father expressed willingness
to submit to drug testing either prior to expanded visiation or a Hearing if
necessary.
6. The Mother's position on custody is as follows: The Mother
stated that she would not agree to anything but supervised visitation in her
home. The Mother expressed concern regarding her belief that the Father has
been and continues to be involved in serious drug use. The Mother stated
that the Father's housing is unsuitable and that he has an unstable
background regarding frequent changes in jobs. The Mother indicated that
the Father is not very attentive to the Child when he visits as told to the
Mother apparently by the Maternal grandmother who is frequently present
during the Father's periods of visitation. The Mother was not willing to
consider the Father's request for substantially expanded supervised
visitation because it would inconvenience her or her Mother to be present
during additional times.
7. The Conciliator found the Mother's position to be somewhat
unreasonable in that she is not willing to allow the Father to spend
significantly more supervised time with the Child in her home because it
would interfere with her schedule but, on the other hand, would not consider
the Father taking the Child out of the home for short periods during which
the Mother would not need to be available. It should be noted that this
Conciliation Report and proposed Order were held in the Conciliator's office
pending the Mother's request that she be given further time to consider
additional periods of supervised visitation and also the possibility that
she would agree to unsupervised visitation after agreed upon drug testing by
the Father in lieu of a Hearing. However, in a recent cOlllnunication with
the Mother's counsel, the Conciliator was advised that a hearing will be
necessary in this matter.
8. The parties were
arrangements pending the Hearing,
Order.
able to agree to temporary visitation
as reflected in the attached recommended
Date
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ID, /9.9(,
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Dawn S. Sunday, Eaqu re
custody Conciliator
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JUDITH CHRISTINE WILLIAMS,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO]N~~ PENNSYLVANIA
93". .33~$' c.4.4r ~"1
NO. S 1995
STEPHEN ANDREW MCCULLOUGH.
Defendant
CHILD ACTION - LAW
CHILD CUSTODY
o R D E R
AND NOW, this ~L"j., day of -/.....n,.. ,1995, in
consideration of the attached Complaint, it is hereby directed that
the parties and }hetr respective counsel, shall al'''rr before
S<'112';,r-' I (/t""'l~t., the Conciliator, on the Is" - day of
I<'hL,:;,f . 995, at 4P .m.. at .SDS- N. I':}..th 50/,
L.,~l"Y'\thl n t'- Ol~ t
for a Pre-Hea'ring Custody Conference. At such conference, an
effort will be made to resolve the issues in dispute; or if this
cannot be accomplished, to define and narrow the issues to be heard
by the Court, and to enter into a Temporary Order. All children
age five or older may also be present at the conference. Failure
to appear at the conference may provide grounds for the entry of a
temporary or permanent Order.
FOR THE COURT:
Dated:
.b" 30-<.,
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.
COURT ADMINISTRATOR, FOURTH FLOOR
Cumberland County Courthouse
One Courthouse Square
Carlisle, Pennsylvania 17013-3387
(717) 240-6200
JUl 3 3 27 PH '95
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JUDITH CHRISTINE WILLIAMS,
Ph,intiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
S 1995
STEPHEN ANDREW MCCULLOUGH,
Defendant
CIVIL ACTION - LAW
CHILD CUSTODY
NOT I C E
YOU HAVE BEEN SUED IN COURT. If you wish to defend
against the claims set forth in the following pages, you must take
action within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by attorney
and filing in writing with the Court your defenses or objections to
the claims set forth against you. You are warned that if you fail
to do so the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any
money claimed in the in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property,
or other rights important to you. including child custody, or child
visitation.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR, FOURTH FLOOR
Cumberland County Courthouse
One Courthouse Square
Carlisle, Pennsylvania 17013-3387
Telephone: (717) 240-6200
~
.
JUDITH CHRISTINE WILLIAMS,
Plainti ff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
S
1995
STEPHEN ANDREW MCCULLOUGH,
Defendant
CIVIL ACTION - LAW
CHILD CUSTODY
COMPLAINT FOR CHILD CUSTODY
AND NOW comes the Plaintiff, Judith Christine Williams,
by and through her attorney, Kristin R. Reinhold, Esquire, and
respectfully requests this Honorable Court award her custody of the
subject minor child, and in support thereto, avers the following:
1. Plaintiff is Judith Christine Williams, an adult
individual residing at 3903 Chestnut Street, Camp Hill, Cumberland
2. Defendant is Stephen Andrew McCullough, an adult
County, Pennsylvania. 17011.
individual residing at R.D. 1. Box 271, New Bloomfield, Perry
County, Pennsylvania. 17068.
3. The subject minor child is Owen Kenley Williams, date
of birth June 4, 1995.
4. The relationship of the Plaintiff to the subject
minor child is that of natural mother.
5. The relationship of the Defendant to the subject
minor child is that of natural father.
li
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6. The minor child has resided with the Plaintiff,
Judith Christine Williams, his natural mother, along with his
maternal grandparents, Chrissy D. Williams and William E. Williams,
as well as his two maternal uncles, Corbin R. Williams and Stewart
R. Williams, since the time of his birth at 3903 Chestnut Street,
Camp Hill, Cumberland County, Pennsylvania.
7. There have been no prior actions for custody of the
subject minor child in this or any other jurisdiction.
8. The Plaintiff is not aware of the existence of any
other individuals who have any type of claim whatsoever regarding
the custody of the subject minor child.
9. The Plaintiff believes, and therefore avers that
she is much better able to meet the needs of the subject minor
child than the Defendant.
10. The Plaintiff believes, and therefore avers that it
is in the best interest of the subject minor child that he be
placed in her legal and physical custody.
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WHEREFORE, Plaintiff requests this Honorable Court award
her custody of the subject minor child.
Date:
C, /"::)0 / (1 )j-
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Respectful
di R.
SIL IKER. RE HOLD LAW OFFICES
204 State Street
Harrisburg, PA 17101
(717) 233-1000
1.0. No. 57911
Attorney for Plaintiff,
Judith Christine Williams
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afore going is true and correct to the best of my knowledge,
information and belief. I understand that false statements
herein are made subject to the penalties of'19 Pa. C.S. 4904
relating to unsworn falsification to authorities.
Dated: In. IC', _c-\~
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AUG 06 1996 tf
JUDITH CHRISTINE WILLIAMS.
, Plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
: NO. 95-3348 CIVIL TERM
V.
: IN CUSTODY
STEPHEN ANDREW MCCULLOUGH.
Defendant
ORDER
, AND NOW. this day of August. 1996. the hearing scheduled in the above
/'
r" captioned matter for 1:30 P.M on Thursday. August 8. 1996. is hereby rescheduled for
- o'clock _.M, on the day of . 1996
BY THE COURT.
J.
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.
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JUDITH CHRISTINE WILLIAMS,
PlaintitT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-3348 CIVIL TERM
V.
IN CUSTODY
STEPHEN ANDREW MCCULLOUGH,
Defendant
MOTION FOR CONTINUANCE
I. Movant, Judith Christine Williams, has retained Keith B. DeArmond. Esquire to
represent her in the above referenced mailer.
2, A hearing in the above referenced mailer has been scheduled for August 8, 1996 at 1:30
P,M,
3, Movant was fonnally represented by Kristin Reinhold, Esquire,
4. Movant recently retained Keith B. DeArmond, Esquire as her allorney.
5. Movant's present counsel did not receive a copy of Movant's file from Attorney
Reinhold until late last week.
6. Counsel was unaware of the hearing until receipt of Movant's file and is unable to
adequately prepare for said hearing.
7. As Counsel was not in receipt of the Order scheduling the aforementioned hearing,
Counsel has not prepared the required Memorandum.
8, Counsel has contacted Thollllls Gould, Esquire allorney for the Defendant, and
Attorney Gould does not concur with this motion
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WHEREFORE, Movant, Judith Christine Williams, respectfully requests this Honorable
Court to reschedule this matter so her counsel can adequately prepare.
Respectfully submitted,
DeArmond & DeArmond
4fzW A_ /
Keith B. DeArmond, Esquire
ID #58878
2800 Market Street
Camp Hill, PA 17011
(717) 730-9394
DATE: i~",
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. Plaintiff
v,
STEPHEN ANDREW MCCULLOUOH,
Defendant
/\U(i 0 G 1996~
. IN Till! COUllT OF COMMON PLEAS OF
: CIJMIlI!IU.ANI> COIJNTY,I'ENNSYLVANIA
: NO IIS..Il-11l CIVil, TBI\M
. IN CUSTOI>Y
ORDER
AND NOW,thla day of AugUII, 1996,tho hearing scheduled in the above
captioned mailer for 1:30 P,M on Thursday, Augult 8, 1996, il hereby rescheduled for
o'clock _.M. on tho day of -' 1996
BY nm COURT,
J.
.
JUDITH CHRISTINE WILLIAMS,
Plaintiff
; IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 95.3348 CIVIL TERM
V.
IN CUSTODY
STEPHEN ANDREW MCCULLOUGH,
Defendant
MOTION FOR CONTINUANCE
I. Movant, Judith Christine Williams, has retained Keith B. DeArmond, Esquire to
represent her in the above referenced matter.
2. A hearing in the above referenced matter has been scheduled for August 8, 1996 at 1:30
P.M.
3. Movant was fonnally represented by Kristin Reinhold, Esquire.
4. Movant recently retained Keith B, DeArmond, Esquire as her attorney.
5. Movant's present counsel did not receive a copy of Movant's lile from Attorney
Reinhold until late last week.
6. Counsel was unaware of the hearing until receipt of Movant's lile and is unable to
adequately prepare for said hearing.
7. As Counsel was not in receipt of the Order scheduling the aforementioned hearing,
Counsel has not prepared the required Memorandum.
8. Counsel has contacted Thomas Gould, Esquire attorney for the Defendant, and
Attorney Gould does not concur with this motion
Page 2
WHEREFORE, Movanl, Judith Chrisline Williams, respectfully requests this Honorable
Court to reschedule this mailer SIl her counsel can adequately prepare.
Respectfully submitted,
DeArmond & DeArmond
/qW A_ /
Keith B, DeArmond, Esquire
ID 1/58878
2800 Market Street
Camp Hill, PA 17011
(717) 730-9394
DATE:_i*"
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JUDITH CHRISTINE WILLIAMS,
. Plaintiff
V.
STEPHEN ANDREW MCCULLOUGH,
Defendant
IIUG 06 lOOfitf
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 95-3348 CIVIL TERM
: IN CUSTODY
ORDER
AND NOW, this day of August, 1996, the hearing scheduled in the above
captioned matter for 1:30 P.M on Thursday, August 8, 1996, is hereby rescheduled for
o'clock _.M. on the day of . 1996
\
BY THE COURT,
J.
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JUDITH CHRISTINE WILLIAMS.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-3348 CIVIL TERM
V.
IN CUSTODY
STEPHEN ANDREW MCCULLOUGH,
Defendant
MOTION "'OR CONTINUANCE
I. Movant, Judith Christine Williams, has retained Keith B, DeArmond, Esquire to
represent her in the above referenced matter,
2. A hearing in the above referenced matter has been scheduled for August 8, 1996 at 1:30
P.M
3. Movant was formally represented by Kristin Reinhold, Esquire.
4. Movant recently retained Keith B. DeArmond, Esquire as her attorney.
5, Movant's present counsel did not receive a copy of Movant's file from Attorney
Reinhold until late last week,
6. Counsel was unaware ofthe hearing until receipt of Movant's file and is unable to
adequately prepare for said hearing.
7. As Counsel was not in receipt of the Order scheduling the aforementioned hearing,
Counsel has not prepared the required Memorandum.
8, Counsel has contacted Thomas Gould, Esquire attorney for the Defendant. and
Attorney Gould does not concur with this motion
~, . ~
Page 2
WHEREFORE, Movant, Judith Christine Williams, respectfully requests this Honorable
Court to reschedule this matter so her counsel can adequately prepare,
DATE: i~c.,
Respectfully submitted,
DeArmond &. DeArmond
kW A_ /
Keith B. DeArmond. Esquire
ID #58878
2800 Market Street
Camp Hill, PA 17011
(717) 730-9394
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ATTORNEYS AT lAW
2800 MARKET STREET
CAMP Hill. PA 17011
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Thomas D. Gould, Esquire
30 West Main Street
Shiremanstown, PA 17011
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IN THB COURT or COMMON PLIAS
CUMBBRLANDCOUNTY, PENNSYLVANIA
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v.
NO. 95-3348 CIVIL TIRM
STBPHBN ANDRIN McCULLOUGH,
Defendant
CUSTODY ACTION
CUSTODY ORDBR
AND NOW, August 8, 1996, the parties having appeared for
hearing with their respective counsel, Keith B. DeArmond, Esquire,
for the Plaintiff, and Thomas D. Gould, Esquire, for the Defendant,
and having reached an agreement between Judith Chri.tine Willi...,
hereinafter referred to as Mother, and Stephen Andrew McCullough,
hereinafter referred to as Father, the following Order of Court is
entered:
I. Mother and Father shall share legal custody of the child,
OWen K. Williams, born June 4, 1995, which means that each party is
to have equal access to the child's personal, school and medical
records and each party is to inform the other of significant events
that occur in the child's life. Each parent shall have access to
medical, dental and school records,
2. The parties shall share physical custody of the child.
a. Mother shall have primary physical custody of OWen
subject to Father's periods of partial custody.
b. Beginning Saturday, August 17, 1996, Father shall
have OWen from 10:00 a.m. to 6:00 p.m., on Saturday, August 24,
,
,
1996, from 10100 a.m. to 6100 p.m.; on Saturday, August 31, 1996,
and Sunday, September 1, 1996, from 10100 a.m. to 6100 p.m. (the
child shall not stay overnight Saturday); Saturday, September 14 at
9100 a.m. until Sunday, September 15 at 7100 p.m. (Father shall
take Owen to his parents' house for the entire period).
c. Beginning September 27, 1996, Father shall have
partial custody of Owen on alternating weekends from Friday at 5100
p.m. until Sunday at 7100 p.m. throughout the year.
d. Father shall have partial custody of Owen one (I)
weekday evening each week from 5100 p.m. until 9100 p.m.
e. Bach calendar year each parent shall be entitled to
a total of four (4) weeks of uninterrupted periods of custody, but
no more than two (2) consecutive weeks. Bach parent shall give the
other a minimum of 30 days notice of his/her intention to exercise
their respective weeks of custody. A weekly period must include
the regularly scheduled weekend to have custody of the child and
shall run from Friday at 6:00 p.m. until Friday at 6:00 p.m..
f. Father shall have Owen New Years Day, Memorial Day
and Labor Day in odd years and Baster, Independence Day and
Thanksgiving in even years. The holiday shall take precedence over
regular weekends and shall begin at 5:00 p.m the day before the
holiday and end at 7:00 p.m. the day of the holiday.
g. Father shall have Owen from December 24th at 6100
p.m. until 11100 a.m. December 25 in odd years and from 11100 a.m.
December 25th until 7:00 p.m. December 26th in even years.
h. Father shall have Owen on Father's Day and Mother
2
shall have the OWen on Mother's Day,
i. At other times mutually agreed upon by the parties.
3. The Father shall be responsible for transporting the
child for the exchange of custody, and Mother shall assist Father
with transportation whenever possible.
4. Each parent is to notify the other if they are intending
to travel with the child outside the Commonwealth of Pennsylvania.
5. Father must notify Mother at least 48 hours prior to his
scheduled period of temporary physical custody Ir HB DOBS "OT
INTBND TO IXBRCISB HIS PBRIOD or TEMPORARY PHYSICAL CUSTODY.
6. Both parents understand the need to provide a loving and
stable environment for their child.
7. Mother and Father agree to place their personal
differences aside and work for the best interests of the child.
8. The parties shall provide for reasonable telephone access
to the child and shall cooperate in accommodating changes in the
custodial schedule for matters that may arise from time to time.
9. Neither party shall make derogatory comments about the
other in the presence or hearing of the child.
10. Each party is to inform the other within seven days of
any change in employment, residence and/or telephone number.
11. The child shall not be left alone with Father's dog until
Mother gives her permission, which shall not be unreasonably
denied.
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