HomeMy WebLinkAbout95-04135
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ALAN R. HAYAKAWA,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-4135 CIVIL
MICHELE F. TAYLOR,
Defendant/Respondent
CIVIL ACTION - LAW
IN CUSTODY
PETITION TO MODIFY EXISTING CUSTODY ORDER
AND NOW COMES, the Petitioner, Alan R, Hayakawa, by his attorneys,
Connelly, Reid & Spade, and flies this Petition to Modify Existing Custody Order and
In support thereof avers as follows:
1. The Petitioner Is Alan R, Hayakawa, currently residing at 2325 Lincoln
Street, Camp Hill, Pennsylvania 17011,
2. The Respondent Is Michele F. Taylor, c1Jrrently residing at 205 North
Hanover Street, Carlisle, Pennsylvania 17013.
3. On September 25, 1995, an Order of Court was entered in the above-
captioned action providing for shared legal and physical custody of the minor children,
Peter M. Hayakawa born May 22,1986 and Patrick M. Hayakawa born December 1,
1988. A copy of the Order is attached hereto and marked Exhibit. A.,
4. Since the date of the entry of the Order, circumstances have changed
WHEREFORE, your Petitioner, Alan R. Hayakawa. requests that the Court order
warranting a change In the existing custodial arrangement. Both parties have changed
residences with the Petitioner moving to Camp Hill and the Respondent to Carlisle.
The children continue to attend the Camp Hill School District.
a conciliation conference for the purposes of modifying the existing Order of Court
dated September 25, 1995.
Respectfully submitted,
CONNELLY. REID & SPADe
Date: 1'2.15' }11
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1997, Dauphin County. Kleinfclter. J. (Dcnying pctition to modify custody on thc basis that the
pleading did not provide sufticient notice to the respondent of those facts which would allow him
to prepare u defense). A copy of the We/I'd case is attached hereto as Exhibit "A" and is
incorporated herein by reference.
9. Not only docs Father's petition fail to allege lacts sufficient to provide the
notice to Mother necessary to prepare a defense to his pleading. he also fails to state a prayer for
reliet: His failure to allege a claim upon which relief can be granted constitutes an additional
basis for dismissal of his petition.
10. [f and in the evcntthis Honorable Court denies Mother's request to
dismiss Father's Petition to Modify Existing Custody Order, it is essential for preparation of her
defense that she be permitted to depose Father and his current wife, Barbara Hayakawa,
1 L Pa.R,C.P. 1930.5 authorizes this Honorable Court to enter an order
granting Mother's request for depositions in the pending custody matter. Pa.R,C.P. 1915.5 also
provides for discovery in cllstody matters if authorized by special order of court.
12. As a result of the woefully inadequate avennents in Father's petition to
modify, absent the requested discovery, Mother will not be able to ascertain the basis for the
petition and subsequently will be severely prejudiced in preparing her defense in this matter,
13. A conciliation conference has been scheduled for February 17, 1998
before Dawn Sunday, Esquire. Mother has requested a eontinuance of the conciliation and a
copy of the letter from Mother's counsel to Ms. Sunday is attached hereto as Exhibit "B" is
incorporated herein by reference thereto.
14. [n order for this Honorable Court to rule upon Mother's molion to dismiss
Father's petition or. in the alternative, her request for leave to take depositions and to accomplish
3
We art not unmindful of the provisions of the Divorce Code which
state that a custody order may "be modified at any time." 23 Pa.C.S,A. !5310,
We are also familiar with the language in Karis v. Karis. 518 Pa. 601, 544 A.2d
1328, 1332 (1988): "A petition lor modification of a partial custody to shared
custody order requires the court to inquire into the best interest of the child
regardless of whether II 'substantial' change in circumstances has been shown."
Defendant-petitioner would have us interpret this lang\Jage as requiring a hearing
every time a pany files a petition using the most boiler plate of averments. We
disagree. T:~e emphasis in ~ is on the word "subs'tantial." The Supreme Court
was not suggll$ting that !lQ change in circumstances need be averred.
Pennsylvania is still a fact pleading state, Pa,R.C.P, 1915.3 and 1915,15 still
require a statement of f<'lcts in support of the petition. We hold that the language
pleaded here. "Ward continues to demonstrate Instability. poor judgment. and an
inability to co-parent" do not provide sufficient notice to respondent of those facts
which would allow him to prepare a defense.
We also feel compelled to comment that court time is a precious
resource which our trial coun is under constant pressure- to allocate wisely. Where
there is alleged to be a change in circumstances which would warrant a revisitation
01 the custodial arrangement in furtherance of the best interests of the child. we
stand ready to schedule a hearing on that issue. Without such a threshold
2
showing, however, we would invite a constant stream of petitions from those
parties never satisfied with the status quo,'
We turn now to the Motion for Appointment of Counsel and Guardian
Ad Litem, In her motion plaintiff states: "2. Since entry of the order. Kenton has
experienced serious social. emo~lonal and academic difficulties." Defendant also
avers that plaintiff has filed suit against the Dauphin County Court, Judges Lewis
and Kleinfelter. and the Judicial Conduct Board. She beheves that "appointment of
counsel and guardian ad litem ." will militate against further accusations by plaintiff
against defense counsel thereby focusing the inquiry on whether the child's best
interests will be served by placing him in defendant's custody."
We see no necessity for the appointment of counsel for the child,
Pa.R.C,P, 1915.11 which allows such a procedure does not include any standards
or guidelines. We view the role of a guardian as that of protecting the interests of
a minor child where there is no natural parent to assume that role. or where, in a
particular matter, the interests of the guardian parent are at odds with the interests
of thfl child. In the case beforfl us, both Mother and father share "legal cU3tody. of
the child as that term is defined in 23 Pa.C.S,A. \5302.. Presumably each parent
seeks to advance and protect the best interests of their minor child in filing the
cross-complaints for custody. Regarding mother's present petition to modify. there
is no reason to suspect that her interests in the action are inimical to the best
, 1SJ!i!. ~, concurring opInion of Nix. C,J.
3
Interests of her Ion. Presumably. mother's interests ere in tandem with those of
her son, For these reasons we see no purpose in appointing counselor guardian ad
litem for Kevin and the request will be denied.
Havin9 so concluded we f'nd it unnecess.ry to address plaintiff's.
preliminary objection claiming a .Iack of jurisdiction.. We also will deny the cross-
motion for counsel fees.
ORDER
"Tv\"
AND NOW, this 8" day of~, 1997, defendant's Petition to Modify
Custody and Motion for Appointment of Counsel and Guardian Ad Uem for Child
are denied. Plaintiff's Consolidated Motion (Preliminary Objection and Cross
Motion for Counsel Fees) is also denied.
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I horeby certify tr, t the forllgoing .. .
tr,l~:~: lr(j CCi~~ct CO~~ of tile original
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PrO!htnolary
4.
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Distribution:
Theresa Berrett Mele, 11 IS Pine Street, Hbg, PA 17101
David H, Ward, 2220 BoIS Street, Hbg. PA 17103
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
v.
)
)
)
)
)
)
)
NO, 413S CIVIL 1995
ALAN R. HAY AKA W A,
Plaintiff
MICHELE F. TAYLOR,
Defendant
CIVIL ACTION - LAW
CUSTODY
CERTIFICATE OF SERVICE
I, John C, Howell, Jr" Esquire, counsel for Michcle F, Taylor, Defendant in the above-
captioned action, hereby certify that a true and correct copy of the foregoing Motion to Dismiss
Petition to Modify Existing Custody Order or. in the Altemative. Motion for Leave to Take
Depositions was served upon John J. Connelly, Jr" Esquire, counsel for Plaintiff Alan R.
Hayakawa, by depositing san1e in the United States mail, first class, on January 30, 1998,
addressed as follows:
John J, Connelly, Jr., Esquire
CONNELL Y, REID & SPADE
108-112 Walnut Street
Harrisburg. PA 17101
Date:
, /?Jo/qK'
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Jo C. Howell. Jr,. qUire
WETT, KISSINGER & MILES, P,C.
130 Walnut Street
P.O, Box 810
Harrisburg, P A 17108
Telephone: 717-234-2616
Counsel for Defendant/Movant
Michele F. Taylor
VERIFICATION
I, Michele F. Taylor, hereby swrar and affirm that the facts contained in the foregoing
Motion to Dismisa Petition to Modify Existing Custody Order
or, in the Al~ive, Motion for Leave to Take Deposition.'! I1retrucl1ndcorr~ct
to the best of my knowledgc, information and belief and are made subject to the penalties of 18
Pa.C,S, ~4904 relating to unswom falsification to authorities.
1/30/98 1lkI ritdt ?T7~
DATE lCHELE F, TAV0 . - -
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ALAN R. HAYAKAWA, . IN THE COUR1' OF CCX>1MON PLF'JlS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 95-4135 CIVIL TERM
.
.
.
MICHELE F. TAYLOR, : CIVIL ACTION - LAW
Defendant CUSTODY
auJIlR or CXXJRT
AND tCM, this ~ day of IAIIhLl,
consideration of the attached Custody concfrf~tion Report,
and directed as follows:
, 1998, upon
it is ordered
1.
continue
parties.
The prior Order of this Court dated september 25, 1995, shall
in effect pending further Order of Court or agreement of the
2. The parties shall submit themselves, their minor Children and any
other family members or individuals deemed necessary by the evaluator, to a
custody evaluation to be performed by Arnold T. Shienvold. This shall be
an independent evaluation for the purpose of Obtaining professional
recommendations concerning custody arrangements (including Childrens'
participation in activities) which will best serve the interests of the
Children and shall include an ADHD evaluation with respect to the parties'
son, Peter. The parties shall provide the necessary authorization as
deemed necessary by the evaluator in order to obtain medical/psychological
records pertaining to the pacties or the Children. The advance cost of the
evaluation shall be divided between the parties, with the Father to be
responsible for 75\ of the costs and the Mother to be responsible for 25\
of the costs. The parties agree that the evaluator may recommend
reallocation of the costs, if appropriate.
BY THE COURT,
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John J.
John C.
Connelly, Jr., Esquire - Counsel for Father._ c...A.u4> m"'~~
Hewett, Jr., Esquire - Counsel for Mother ~
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I IN THE COURT-O-r'celi-!M(fr(j;LEAS-Oi'--
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION .. LAW CUSTODY
NO. 4135 CIVIL 1995
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ALAN R. HAYAKAWA,
Plaintiff
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MICHELE F. TAYLOR,
Defendant
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. ROWETr, KISSINGER" MILES, RC.
110 WALNu'r ,nun
PO~T OHIeE BOX IH~
H^RRl~8lIRU. P!NN~ 'tLV.\NI.\ 11l0t!
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ALAN R. HAYAKAWA, )
Plainti ff )
)
v. ) NO. 95 - 4135
)
MICHELE F. TAYLOR, ) CIVIL ACTION - LAW
Defendant ) IN CUSTODY
ACCEPTANC~-2~ SERVIQ~
I, John C. Howett, Jr., Esquire, attorney for the above-
named Defendant, accept service of the Complaint for Custody and
accept same on behalf of my client, Michele F. Taylor.
Date:
.Auaust 11. 1995
/ ____14) c
~owett, Jr., Es
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ALAN R. HAYAKAWA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 95-4135
CIVIL TERM
MICHELE F, TAYLOR,
Defendant
CIVIL ACTION - LAW
CUSTODY
, 1995, upon
tion Report, it is hereby
1. The Mother, Michele F. Taylor, and the Father, Alan R. Hayakawa,
shall have shat'ed legal and physical custody of Peter M. Hayakawa, born May
22, 1986 and Patrick M, Hayakawa, born December 1, 1988.
2. Prior to January 14, 1996, the parties shall share physical custody
of the Children on a mutually agreeable schedule. Beginning January 14,
1996, the parties shall share physical custody of the Children on a biweekly
basis with the exchange of custody occurring on alternating Sunday evenings
at 6:00 p.m. The Mother shall have physical custody of the Children during
the first biweekly period beginning January 14, 1996.
3. During each biweekly period, the non-custodial parent shall have
physical custody of the Children on the first Friday evening during the
period from 5:00 p.m. until 10:00 p.m. and shall provide all transportation
fo~ exchange of custody under this paragraph.
4. During summer vacation, each party shall enjoy physical custody of
the Children for four consecutive weeks, with the first four week period
(Segment A) beginning at 6:00 p.m. on the Sunday tollowing the Chilciren's
last day of school and the aecond four week period (Segment B) beginning
four weeks later. In 1996, Segment A shall begin on Sunday, June 16 at 6:00
p.m. and end on Sunday, July 14 at 6:00 p.m. Segment B shall begin on
Sunday, July 14 at 6:00 p.m. and end on Sunday, August 11 at 6:00 p.m. The
Father shall have physical custody of the Children during Segment A in 1996
and in even-numbered years thereafter and during Segment B in odd-numbered
years. The Mother shall have physical custody of the Children during
Segment B in 1996 and in even-numbered years thereafter and during Segment A
in odd-nUmbered years. During each four week period under this paragraph,
the non-custodial parent shall have partial custody of the Children one
evening per week from 5:00 p.m. until 10:00 p.m. unless the custodial parent
is traveling with the Children and is out of the area. At the conclusion of
Segment Beach surrrner, the regular custody schedule shall resume wi th the
Father having custody of the Children for the first biweekly period in
even-numbered years and with the Mother having custody of the Children for
the first biweekly period in odd-numbered yeara.
5. The parties shall alternate custody on holidays as follows:
A. The Mother shall have physical custody of the Children:
1. In odd-numbered years - Christmas from the beginning of the
school recess until 7:00 p.m. Christmas Eve, Thanksgiving from
the Wednesday before Thanksgiving until the following Sunday
evening, Labor Day (three day weekend), Presidents' Day (three
day weekend), and Halloween trick or treat: night.
2. In even-numbered years - Christmas from the beginning of
the school recess until the evening of December 28,
Thanksgiving from Sunday evening following Thanksgiving until
the end of the 3chool r.ecess, Easter from the beginning to the
conclusion of the school recess, Memorial Day (three day
weekend), and 4th of July (three day weekend if the holiday
falls on a Friday or Monday).
3. In every year - Mother's Day from 9:00 a.m. until 8:00 p,m.
and Veteran's Day.
B. The Father shall have physical custody of the Children:
1. In odd-numbered years - Christmas from 7:00 p.m. Christmas
Eve until the end of the school recess, Thanksgiving from
Sunday evening following Thanksgiving until the end of the
school recess, Easter from the beginning to the conclusion of
the SGhool recess, Memorial Day (three day weekend), and 4th of
July (three day weekend if the holiday falls on a Friday or
Monday) .
2. In even-numbered years - Christmas from the evening of
December 28 until the end of the school recess, Thanksgiving
from the Wednesday before Thanksgiving until the following
Sunday evening, Labor Day (three day weekend), Presidents' Day
(three day weekend) and Halloween trick or treat night.
3. In every year - Father's Day from 9:00 a.m. until 8:00 p.m.
and Columbus Day from Sunday evening preceding the holiday
until the Tuesday morning after Columbus Day.
6.
The holiday custody schedule shall supersede the regular schedule.
7.
receiving
exchanges
Except as provided in paragraph 3 of this Order, the party
custody shall be responsible to provide transportation for
of custody under this Order.
8. Each party shall have reasonable telephone contact with the
Children when they are in the custody of the other party. Reasonable
contact shall mean one telephone call per day unless circumstances dictate
otherwise. The custodial parent shall ensure that telephone messages left
by the other party are promptly answered by the Children.
9. Neither party shall criticize the other party's parenting stylo in
the presence or hearing of the Children and neither party shall attempt to
interfere in any way with the childrea.ing practices of the other party when
the Children are in the other party's custody.
10. The parties may modify the custody schedule set forth in this Order
by mutual agreement. In the absence of mutual agreement, the terms of this
Order shall control.
11. This order is entered pursuant to an Agreement reached by the
parties as a result of a Custody Conciliation Conference. The parties agree
that neither party shall attempt to modify this Order absent a significant
change in circumstances. In the event that either party attempts to modify
this order, the parties agree that they shall request that the Court make a
findir'1 as to whether or not there has been a significant change in
circumstances and, if the Court finds that there has not been a significant
change in circumstances, then the party initiating the modification action
agrees to pay the counsel feea, costs and expenses incurred by the other
party in connection with the modification proceeding_
OY THE COURT,
J.
cc: patricia A. Mil~s, Esquire
John J. Connelly, Jr., Esquire
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ALAN R. HAYAKAWA,
Plaintiff/Petitioner
v,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 95-4135 CIVIL
MICHELE F. TAYLOR,
Defendant/Respondent
CIVIL ACTION - LAW
IN CUSTODY
ORDER
AND NOW, upon consideration of the attached Petition, it Is hereby directed
that the parties and their respective counsel appear before,
, Esquire. the Conciliator, on the _ day of
19_, at ,M., at the 4th Floor, Cumberland County Courthouse, Carlisle,
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 accornpllshed, to
define and mmow 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, Notification to the Defendant by the Prothonotary's Office is
waived.
For the Court,
Date of Order:
By:
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE,
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR iELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberlond County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
,
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EXHIBIT tt A"
.
SEP 2 5 19S: IJ.
ALAN R. HAYAlCAWA,
Plaintiff
IN 'I'!IE COURT OF ca1MON PLEAS OF
CUMBERLAND COONTY, PENNSYLVANIA
vs.
NO. 95-4135
CIVIL TERM
ro.
MICHELE F, TAYLOR,
Defendant
CIVIL ACTION - LAW
CUSTODY
CIlDER OF CXXlRT
AND toi, this J.StJ. day of ~r-'c
consideration of the attached Custody Conciliation Report,
ordered and directed as follows:
, 1995, upon
it is hereby
1. The Mother, Michele F. Taylor, and the Father, Alan R. Hayakawa,
shall have shared legal and physical custody of Peter M. Hayakawa, born May
22, 1986 and Patrick M. Hayakawa, born December 1, 1988.
2. Prior to January 14, 1996, the parties shall share physical custody
of the Children on a mutually agreeable schedule. BegiMing January 14,
1996, the parties shall share physical custody of the Children on a biweekly
basis with the exchange of custody occurring on alternating Sunday evenings
at 6:00 p.m. The Mother shall have physical custody of the Children during
the first biweekly period begi~ning January 14, 1996.
3. During each biweekly period, the non-custodial parent shall have
physical custody of the <.':hildren on the fit"st Friday evening during the
period from 5:00 p.m. until 10:00 p.m. and shall pt"ovide all transportation
for exchange of custody under thi.s paragraph.
4. During slJlllll8r vacation, each party shall enjoy physical custody of
the Children for four consecutive weeks, with the fit"st four week period
(Segment A) beginning at 6:00 p.m. on the Sunday following the Children's
last day of school and the second four week period (Segment 8) beginning
four weeks later. In 1996, Segment A shall begin on Sunday, June 16 at 6:00
p.m. ,and end on Sunday, July 14 at 6:00 p.m. Segment 8 shall begin on
Sunday, July 14 at 6:00 p.m. and end on Sunday, August 11 at 6:00 p.m. The
Father shall have physical custody of the Children during Segment A in 1996
and in even-numbered years thereafter and during Segment B in odd-numbered
years. The Mother shall havo physical custody of the Children during
Segment B in 1996 and in even-numbered years thereafter and dut"ing Segment A
in odd-numbered years, During each four week ;Jeriod under thi", paragraph,
thl) non-custodial parent shall have partial custody of the Children one
evening per week from 5:00 p,m. IJntil 10:00 ;l.m. unless the custodial parent
is traveling with the Children and is out of the area, rlt the conclusion of
Segment 8 each SUlTlller, the regular custody schedule shall resume with the
rather having custody of the Children fat" the fit"st biweekly ;Jeriod in
<lV4tn<-numberecl years and wi th the Mother having custody of the Children for
the first biweekly period in odd-numbered years.
5. The parties shall alternate custody on holidays as follows:
A. The Mothe~ shall have physical custody of the Children:
1. In odd-numbered years - Ch~istmas from the beginning of t.he
school recess until 7:00 p.m. Christmas Eve, Thanksgiving from
the Wednesday before Thanksgiving until the following Sunday
evening, t.abor Day (three day wHkend), Presidents' Day (three
day weekend), and Halloween trick or treat night.
2. In even-numbered years - Christmas from the begiMing of
the school recess until the evening of Decllmber 28,
Thanksgiv~ng from Sunday evening following Thanksgiv,ing until
the end of the school recess, Easter from the begiMing to the
conclusion of the school ~ecess, Memorial Day ( th~ee day
weekend), and 4th of July (three day weekend if the holiday
falls on a F~iday or Monday).
r.-
3. In every year - Mothe~'s Day from 9:00 a.m. until 8:00 p.m.
and Veteran's Day.
B. The Father shall have physical custody of the Children:
1. In odd-numbered yea~s - Christmas f~om 7:00 p.m. Christmas
Eve until the end of the school recess, Thanksgiving f~om
Sunday evening following Thanksgiving until the end of the
school recess, Easter f~om the beginning to the conclusion of
the school t'ecess, Memorial Day (thne day woekend), and 4th of
July (tht'ee day w..ekend if the holiday falls on a F~iday or
Monday) .
2. In even-numbered years - Ch~istmas f~om the evening of
December 28 until the end ot: the school recess, Thanksgiving
f~om the Wednesday befo~e Thanksgiving Wltil the following
Sunday evening, t.abo~ Day (th~ee day weekend), Presidents' Day
(three day weekend) and Halloween trick or t~eat night.
3. In every year - Fathe~'s Day from 9:00 a.m. until 8:00 p.m.
and Columbus Day from Sunday evening pt'eceding the holiday
until the Tuesday morning after Columbus Day.
6. The holiday custody schedule shall supe~sede the regula~ schedule.
7. Except as pt'ovided in pat'agraph 3 of this Ordet' , the party
receiving custody shall be responsible to p~ovide transportation for
exchanges of custody under this Order.
8. Each party shall have reasonable telephone contact wJ.th the
Childt'en when they are in the custody of the other .,arty. Reasonable
contact shall mean one telephone call per day unless circumstances dictate
otherwise, The custodial parent shall ensure that ~elephone messagos left
by the other pa~ty are promptly answet'ed by thl/ ChiJ.dt'en,
9. Neithet' ;:ar.y shall cnticize the other par~y's .,arenting stj<'le in
the presenceJt' hearing of :he:hi ldt'en and neithet' .,arty shall at~empt to
interfet'e in any way with the cnildreat'ing ilractices of the other party when
"
EXHIBIT "S"
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ALAN R. HAYAKAWA,
PLAINTIFF
v,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO,
MICHELE F, TAYLOR,
DEFENDANT
CIVIL ACTION - LAW
IN CUSTODY
COMPLAINT FOR CUSTODY
1. The Plaintiff is Alan R. Hayakawa, residing at 1801 Peters Mountain
Road, Dauphin, Dauphin County, Pennsylvania 17018,
2, The Defendant Is Michele F. Taylor, residing at 465 Country Club Road,
Camp HIli, Cumberland County, Pennsylvania 17011.
3. Plaintiff seeks custody of the following children:
NAME
PRESENT RESIDENCE D.O.B.
Peter M. Hayakawa
465 Country Club Road OS/22/86
Camp Hill, Pennsylvania
Patrick M. Hayakawa
465 Country Club Road 12/01/88
Camp Hill, Pennsylvania
Peter M, Hayakawa was born out of wedlock,
Patrick M. Hayakawa was not born out of wedlock.
The children are presently In the custody of Michele F, Taylor, who resides 81
465 Country Club Road, Camp Hill. Pennsylvania,
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ALAN R. 'lAYAI<AWA, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
VS. . NO. 95-4135 CIVIL TERM
.
:
MICHELE F. TAYLOR, : CIVIL ACTION - LAW
Defendant . CUSTODY
,
auJI!lR OF CXXRl'
,l
AND~, this I \ day of JJ,..." c .., l. ~ J , 1998, upon
consideration of the attached Custody Conciliation Report, it is ordered
and directed as follows:
1. A Hearing is scheduled in Court Room # / ' of the
Cunilerland County Court House, on t.lJe ..3/V1.- day of .:J_~/.-.u,~,
199~, at 1:30 o'clock, -1l.m.~e Father shall be ~ Ee1EFie
mov1lii3 party for the purpose of this Hearing and shall proceed initially
with testimony. Counsel for the parties shall file with the Court and
oppo.sing counsel a Memorandum setting forth each party's position on
custody, a list of witnesses who will be expected to testify at the Hearing
and a SUlllll!lry of the testimony of each witness. These Memoranda shall be
filed at least ten (10) days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the
prior order of this Court dated September 25, 1995 shall continue in
effect.
BY THE COURT,
J.
eel
John J. Connelly, Jr., Esquire - Counsel for Father
John C. Howett, Jr., Esquire - Counsel for Mother -<,~.<.(A .'>>L.<......h.L JI- J.+ 'i' f
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ALAN R. HAYAKAWA,
PLAINTIFF
v,
IN THE. COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 4135 1995
MICHELE F, TAYLOR,
DEFENDANT
CIVIL ACTION - LAW
CUSTODY VISITATION
ACCE~ANCE,OF SERVICE
I, John C. Howett, Esquire, attorney for the above-named Defendant, accept
service of the Order and Petition to Modify Existing Custody Order on behalf of mv
client, Michele F. Taylor.
Date: ll? ('l...O J q tt
~l!~
J . Howett; squire .........
Howett, Kissinger & Miles
130 Walnut Street
Harrisburg, PA 17101
(717) 234-2616
Al.AN R. HAY AKA W A,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBER1.AND COUNTY, PENNS Yl. VANIA
v.
CIVIL ACTION - LAW
MICHELE F. TAYLOR,
Defendant
NO. 95-4135 CIVIL TERM
ORDER OF COURT
AND NOW, this '!o~ay of January, 1999, upon agreement of counsel, the hearing
previously scheduled in this matter for February 3, 1999, is CANCELLED. The hearings
scheduled for February 2, 1999, and February 17, 1999, remain as previously scheduled.
BY THE COURT,
John J. Connelly, Jr., Esq.
134 Sipe Avenue
Hummelstown, P A 17036
Attorney for Plaintiff
. . 1 /."\/49
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John C. Howett, Jr., Esq.
130 Walnut Street
Harrisburg, PA 17101
Attorney for Defendant
:rc
I.IS11 Illlrherll,
!'I>limitl
IN TilE COURT OF COMMON PLEAS OF
('UMIIERI.I'."l[) ('OUNTY,!'ENNSYL VANIA
CIVil, ACTION -l.AW
v,
Anthony J. lI11rheru,
Dclcmlant
No. 95-50119 CIVIl. TERM
IN DIVORCE
CE
AND NOW, this 1st day of February. 1999.1. Robert G. Frey, hereby swear that I huve
served u true certified copy of the Complaint in Divorce. with Notice to DC:fend. in the above-
cuptioned matter upon
Anthony J, Barbera
1249 Decrlield Parkway. ApI. 103
Buffalo Grove. IL 60090
by depositing same in the Unitcd Slates Mail, postagc prepuid. ccrtified mail uddressee only. return
rcccipt rcqucsted und by United Statcs Mail. poslugc prcpaid. first c1uss mail on Scptcmber 27,
1995. The Complaint in Divorce with Notice to Defend was relurned to my oflke unopenned; the
Complaint in Divorce. with Noticc to Dcfend. sent by United States Mail. postuge prepuid. lirst
class mail on Septcmber 27. 1995 wus not returned at any time.
---1_
Rohert G. Frey
Attomcy for Plainti 1'1'
5 South Hanover Street
Carlisle. Penm.ylvania 17013
(717) 243.5838
Sworn and subscribed 10 before me Ihis
I st day of Fcbruary. 1999
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B. Every other Monday evening beginning Monday, February 15, 1999.
The children will be pickod up by their Mother at their residence at 5:00
p.m. and dropped off by the Mother at 8:00 p.m. The next Monday
visit would be Monday, March 1, 1999 and will continue every other
week thereafter.
3. The parties shall alternate the Thanksgiving and Christmas holidays as
follows:
A. The Mother shall have Thanksgiving in odd numbered years. She
will pick up the children at 5:00 p.m. on the last day of school and the
parties will meet at 6:00 p.m. at the designated exchange point (Red
Horse Steakhouse) the evening before school resumes. The Father shall
have the Thanksgiving holiday in even numbered years.
B. Christmas school holiday will be divided into two (2) segments. In
odd numbered years, the Mother will pick up the children at their
residence at 5:00 p.m. on the last day of school and return them to the
Father at the designated exchange point (Red Horse Steakhouse) at
6:00 p.m. on December 24"'. The Children will spend the remainder of
the Christmas holiday with the Father. In even numbered years, the
mother will pick up the children at their residence at 5:00 p.m.
December 24'" and return them to the Father at the designated
~
exchanga point (Rad Horse Steakhouse) at 6:00 p.m. on the day befora
school resumas.
4. As to the other holidays, the Mother will have Memorial Day, Spring
Break and Easter each year. In the event Mother's regular alternating weekend adjoins
a school holiday on Martin Luther King Jr. Day, Presidents Day or Columbus Day, she
will retain them for a three (3) day weekend with the children being exchanged at
6:00 p.m. on the evening of the holiday at the regular exchange point (Red Horse
Steakhouse). The Father will have Labor Day weekend and July 4t". The July 4'"
holiday shall include the weekend in the event the Fourth of July falls on a Friday,
Saturday, Sunday or Monday which creates a three (3) day weekend. On the
Memorial Day, Spring Break and Easter holidays the children willl::e picked up at their
residence at 5:00 p.m. on the day school ends and will be exchanged at the Red
Horse Steakhouse at 6:00 p.m. the evening before school begins.
5. The Mother shall have five (5) weeks of partial custody in the summer
beginning on a Sunday evening (five weeks prior to the children's return to school)
with the Mother picking up the children at 5:00 p.m. at their residence with the
return of the children being exchanged at the Red Horse Steakhouse on the Sunday
before school begins at 6:00 p.m. In the event school begins on a Monday, the
children will be exchanged at the Red Horse Steakhouse on the preceding Saturday at
6:00 p.m. and will commance on a Saturday. The alternating weekend visitation
schedule would continue during the summer months with fathar receiving what
J
would ordinarily be his weekend on an alternating rotation during Mother's periods of
partial custody unless either perent is traveling. The exchanges for Father's
weekends during Mother's summer vacation period shall take place at 6:00 p.m. on
Friday and Sunday at the Rad Horse Steakhouse.
For partial custody in the s(Jmmer of 1999, the Mother's schedule shall begin
with pick-up at the children's residence at 5:00 p.m. on Saturday, July 24, 1999 and
with the transfer of the children at the Red Horse Steakhouse at 6:00 p.m. on
Saturday, August 28, 1999. In the event either parent is traveling during their
periods of custody in the summer, thereby precluding the other parents alternating
weekend, the traveling parent will give the other parent thirty (30) days notice of the
travel plans which would preempt the regular alternating weekend schedule.
6. Mother's Day shall be with Mother and Father's Day shall be with
Father regardless of the weekend rotation from 5:00 p.m. Friday when the children
shall be picked up at their residence until Sunday at 6:00 p.m. when they shall be
exchanged at the designated location (Red Horse Steakhouse) .
7. The holiday schedule shall supersede the regular visitation schedule. If
any scheduled holiday other than Christmas would give either parent more then two
(2) consecutive weekends, the alternation of the weekends shall resume following
the second consecutive weekend.
8. Each Darent shall provide the other with his or her home telephone
number to be used only for urgent matters regarding the children or for rellonable
4
telephone contact with the children. Each parent shall also provida an itinerary and
specific talephona numbers when he or she is traveling with the children so that the
non-custodial parent can contact the children evory other day.
9. Each party shall have reasonable telephone contact with the childran
when they are in the custody of the other party. Reasonable contact shall mean one
telephone call per day unless circumstances dictate otherwise. The custodial paront
shall ensure that telephone messages left by the other party are promptly answered
by the children.
1 Q. Both parents shall be responsible during their periods of custody for
getting the children to their significant activities wh..:h shall be deemed to include
school performances, tests, major scout trips and opening days for soccer and
baseball. To the extent that these activities may fall during Mother's period of partial
custody, Father shall provide notice of such activities to Mother at the time such
activities are first scheduled.
11. The Mother shall contact Peter's allergy doctor, Diane Schuller, M.D. at
(717) 531-5338 regarding his medications and will see that the medication directions
of Dr. Schuller and the children's pediatricians, Drs. Christopher Ryder and Kevin
Barnes, are followed during Mother's periods of custody. During her periods of
custody, Mother shall arrange for the timely administration of Peter's scheduled
allergy desensitization shots and agrees to administer to either of the children any
5
medications which they are prescribed during her periods of partlel custody or which
they prescribed on an ongoing basis.
12. During each perent's poriods of partial custody when the children Ire in
school, that parent shall be responsible for the children completing their homework
assignments.
13. The Mother agrees to promptly return to Father the children's PllssportS.
The Father will promptly apply for new passports which will be mllintained in his
possession. If Mother and the children will be taking vacation or other trip that
would require the children to have possession of passports, Father will surrender the
passports to Mother thirty (30) days in advance of the commencement of the trip and
the passports will promptly be returned to Father upon the completion of the trip or
upon cancellation of the trip.
14, Both parents shall exercise their best efforts to insure that items of
personal possessions brought with the children to the other parent's home are
returned with the children to the first parent's home at the end of each period of
partial custody. The parties recognize that the nature and type of personal
possessions that the children may have with them at any given time can be quite
varied and agree that both parties shall encourage the ch;ldren themselves to keep
track of the items that they bring with them so that they can be returned at the end
of the pillriod of partial custody. In the event an item is forgotten, at the time of the
exchange of partial custody, the parent in possession of the item or items shill bringÿ
6
It to the next exchange. In the case of urgently needed school materials. the parent
will be responsible for overnlghting the item or items to the other parent.
, 5. The parties may modify the custody schedule set forth In this Ordar by
mutual agreement. In the absence of mutual agreement. the tarms of this Ordar shell
control.
"
.,
Sundey when the childrlln will be exchenged between the perents et the
i=led Horse Steakhouse outside of Frederick, Marylend near US Route
15. The alternate weekend schedule shall begin on Friday, February 19,
1999.
B. Every other Monday evening beginning Monday, February 15. 1999.
The children will be picked up by their Mother at their residence et 5:00
p.m. and dropped off by the Mother at 8:00 p.m. The next Monday
visit would be Monday, March 1. 1999 and will continue every other
week thereafter.
3. The parties shall alternate the Thanksgiving and Christmas holidays as
follows:
A. The Mother shall have Thanksgiving in odd numbered yaars. She
will pick up the children at 5:00 p.m. on the last day of school and the
parties will meet at 6:00 p.m. at the designated exchange point (Red
Horse Steakhousel the evening before school resumes. The Father shell
have the Thenksgiving holiday in even numbered years.
B. Christmas school holiday will be divided into two (2) segments. In
odd numbered years, the Mother will pick up the children at their
residence at 5:00 p.m. on the last day of school and return them to the
Father at the designated exchange point (Red Horse Steakhouse) at
6:00 p.m. on December 24'". The Children will spend the remainder of
9
the Christmas holiday with the Father. In even numbered years, the
mother will pick up the children at their residence at 5:00 p.m.
December 24'. and return them to the Father at the designated
exchange point (Red Horse Steakhousel at 6:00 p.m. on the day before
school resumes.
4. As to the other holidays, the Mother will have Memorial Day, Spring
Break and Easter eech year. In the event Mother's regular alternating weekend adjoins
a school holiday on Martin Luther King Jr. Day, Presidents Day or Columbus Day, she
will retain them for a three (3) day weekend with the children being exchanged at
6:00 p.m. on the evening of the holiday at the regular exchange point (Red Horse
Steakhousel. The Father will have Labor Day weekend and July 4'". The July 4'"
holiday shall include the weekend in the event the Fourth of July falls on a Friday,
Saturday, Sunday or Monday which creates a three (3) day weekend. On the
Memorial Day, Spring Break and Easter holidays the children will be picked up at their
residence at 5:00 p.m. on the day school ends and will be exchanged at the Red
Horse Steakhouse at 6:00 p.m. the evening before school begins.
5. The Mother shall have five (5) weeks of partial custody in the summer
beginning on a Sunday evening (five weeks prior to the children's return to school)
with the Mother picking up the children at 5:00 p.m. at their residence with the
return of the children being exchanged at the Red Horse Steakhouse on the Sundey
before school begins at 6:00 p.m. In the event school begins on a Monday, the
to
children will be exchanged at the Red Horse Steakhouse on the preceding Saturdey et
6:00 p.m. and will commence on a Saturdey. The alternating weekend vis/tItian
schedule would continue during the summer months with father receiving what
would ordinarily be his weekend on an alternating rotation during Mother's periods of
partial custody unless either parent is traveling. The exchanges for Father's
weekends during Mother's summer vacation period shall take place at 6:00 p.m. on
Friday and Sunday at the Red Horse Steakhouse.
For partial custody in the summer of 1999, the Mother's schedule shall begin
with pick-up at the children's residence at 5:00 p.m. on Saturday, July 24, 1999 and
with the transfer of the children at the Red Horse Steakhouse at 6:00 p.m. on
Saturday, August 28, 1999. In the event either parent is traveling during their
periods of custody in the summer, thereby precluding the other parents alternating
weekend, the traveling parent will give the other parent thirty (30) days notice of the
travel plans which would preempt the regular alternating weekend schedule.
6. Mother's Day shall be with Mother and Father's Day shall be with
Father regardless of the weekend rotation from 5:00 p.m. Friday when the children
shall be picked up at their residence until Sunday at 6:00 p.m. when they shell be
exchanged at the designated location (Rad Horse Steakhouse) .
7. The holiday schedule shall supersede the regular visitation schedule. If
any scheduled holiday other than Christmas would give either parent more then two
11
(2) consecutive weekends, the alternation of the weekends shall resume following
the second consecutive weekend.
8. Each parent shall provide the other with his or her home telephone
number to be used only for urgent matters regarding the children or for reasonable
telephone contact with the children. Each parent shall also provide an itinerary and
specific telephone numbers when he or she is traveling with the children so thet the
non.cust~dial parent can contact the children every other day.
9. Each party shall have reasonable telephone contact with the children
when they are in the custody of the other party. Reasonable contact shall mean one
telephone call per day unless circumstances dictate otherwise. The custodial parent
shall ensure that telephone messages left by the other party are promptly answered
by the children.
10. Both parents shall be responsible during their periods of custody for
getting the children to their significant activities which shall be deemed to include
school performances, tests, major scout trips and opening days for soccer and
baseball. To the extent that these activities may fall during Mother's period of pertial
custody, Father shall provide notice of such activities to Mother at the time such
activities are first scheduled.
11. The Mother shall contact Peter's allergy doctor, Diane Schuller, M.D. lit
(717) 531-5338 regarding his medications and will see that the medication directiOM
of Dr. Schuller and the children's pediatricians, Drs. Christopher Ryder and Kevin
12
Bernes, are followed during Mother's periods of custody. During her periods of
custody, Mother shall arrange for the timely administration of Peter's scheduled
allergy desensitization shots and agrees to administer to either of the children any
medications which they are prescribed during her periods of partial custody or which
they prescribed on an onGoing basis.
12. During each parent's periods of partial custody when the children are in
school, that parent shall be responsible for the children completing their homework
assignments.
13. The Mother agrees to promptly return to Father the children's passports.
The Father will promptly apply for new passports which will be maintained in his
possession. If Mother and the children will be taking vacation or other trip that
would require the children to have possession of passports, Father will surrender the
passports to Mother thirty (30) days in advance of the commencement of the trip and
the passports will promptly be returned to Father upon the completion of the trip or
upon cancellation of the trip.
14. Both parents shall exercise their best efforts to insure that items of
personal possessions brought with the children to the other parent's home are
returned with the children to the first parent's home at the end of each period of
partial custody. The parties recognize that the nature and type of personal
possessions that the children may have with them at any given time can be quite
veried and agree thet both parties shall encourege the children themselves to keep
13
track of the items that they bring with them so that they can be returned at the end
of the period of partial custody. In the event an item is forgotten, at the time of the
exchange of partial custody, the perent in possession of the item or items shall bring
it to the next exchange. In the case of urgently needed school materials, the parent
will be responsible for overnightlng the item or items to the other parent.
15. The parties may modify the custody schedule set forth in this Order by
mutual agreement. In the absence of mutual agreement, the terms of this Order shell
control.
NOW THEREFORE, the parties mutually agree as follows:
WHEREFORE, the parties hereto set forth their signatures intending to be
legally bound.
WITNESSES:
I~L~( 7<. ~(;t-UktidMJe.""
A an R. Hayakawa
oh
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vMtc-hele . Tayldt"
14
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GARY L JAMES
MAX J. SMITI~ JR.
KAREN DURKIN
JOlIN J. CONNhL Y, JR.
STUART J. MAGDlILE
FRANK P CLARK
SUSAN E. LEDERER
STEVEN A. STINE
JOlIN J. M(.'NALL Y,III
(iREOORY K. RJCHARlJII
SCOTf A. DIElTERJCK
JARADW.IIANDELMAN
LA W OFFICES
Jamlls, Smith, DurAl" & Connelly LV
P.O. BOX 6~0
UERSUEY. PENNSYLVANIA 17033
Strect IIddrcas
134 SIPE AVENUE
IIlJMMELSTOWN, PENNSYl.VANIA 17036
E.mall address: Inror;iUsdlc,all.:om
1I.,nlb... om..,
101.112 WolnUISlrt'1
Ih,,,llbu'io PA 17101
(7/7)231-4776
(717) 53),)210
FAX (717) 5J).2795
February 17, 1999
The Honorable J. Wesley Oler, Jr.
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA \7013
Re: Alan R. Hayakawa v. Michele F. Taylor
No. 95-4135 - [n Custody
Dear Judge Oler:
Pursuant to this office's telephone conversation with your office, please cancel the above.
referenced hearing scheduled for Wednesday, February [7, [999, at [:30 p.m. as the parties and
their respective counsel have executed a Stipulation and will be forwarding an Order for your
signature.
JJC:jlk
Very tl1,l1y-yours,
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John C. Howett, Jr., Esquire
Alan R. Hayakawll
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