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PATTI S. COOPER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
VB.,
.
.
.
.
LARRY TUBBS,
Defendant
: CIVIL ACTION - LAW
: No.
STIPULATION FOR, CUSTODY.
AND NOW comes the plaintiff, PATTI S. COOPER, by her
attorney, JAMES M. BACH, and files the within Stipulation for
Custody.
This Stipulation is in regard to the minor child, Rachael
S. Cooper, born on September 10, 1992, and living at all times
hereinbefore with her natural mother.
1, Primary physical custody shall at all times hereinafter
be with the natural mother, PATTI S. COOPER.
2, The minor child, Rachael S. Cooper, was born out of wedlock
and the natural father is LARRY TUBBS. Larry Tubbs does
hereby acknowledge paternity of said child.
3, Father may, at his option, have visitation with his child
every other sunday from 10.00 a.m. to 5.00 p.m. Father
must advise mother not later than 6.00 p.m. the preceding
Saturday of his intention to visit or not visit.
4, Father shall not be under the influence of alcohol or
drink alcohol while with the child.
5, Father must take care of the child and not leave her
with others.
6, Father must keep child clean, and feed her when necessary.
Child is a diabetic and has special needs. Father must
follow all instructions relative to food intake and
medicine intake.
7, The periods of visitation as Bet forth herein may increase
as the child gets older, by mutual consent of the parties.
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witness
S. COOPER
~/cl 't:2I
/\RRY TUBBS
PATTI S. COOPER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
NO. 95-4761 CIVIL TERM
LARRY TUBBS / :
Defendant/Petitioner: CIVIL ACTION - LAW
ORDER OF COURT
AND NOW, this ~~(~ day of ,SI'P 1<-""k , 1996,
upon consideration of the attached Complaint, it is hereby directed
that the parties and their respective counsel appear before,
Oo..w" s. S"'...\... -} , the conciliator, at
S"I w. 1"\....... st. 1"1 L'ch""i,~b"'J> on the S1~
day of octok,.. , 1996, at q:coll. .M., for a Pre-
Hearing Custody Conference. At such Conference, an effort will be
made to resolve the issues in dispute; or if this cannot be
accomplished, to define and narrow the issues to be heard by the
Court, and to enter into a temporary order. Either party may bring
the child who is the subj ect 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 entry
of a temporary or permanent order.
FOR THE COURT:
0......71 d AI .--'-aL/J-t'~C'r
Custody ~nciliato)lV' ~t9 f
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.
By:
Office of the Court Administrator
Cumberland County Courthouse
Fourth Floor
Carlisle, PA 17013
(717) 240-6200
" .
PATTI S. COOPER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 95-4761 CIVIL TERM
v.
LARRY TUBBS, :
Defendant/petitioner: CIVIL ACTION - LAW
AND NOW, this
PETITION TO MODIFY CUSTODY
day of
, 1996, comes the
petitioner, Larry Tubbs, by and through his attorney, R. Mark
Thomas, Esquire, and hereby brings this petition to modify the
custody Order previously entered in this case for the following
reasons:
1) petitioner is the father of the minor child, Rachel S.
cooper, born september 10, 1992.
2) Respondent patti S. Cooper is the mother of the minor
child, Rachel S. Cooper, born september 10, 1992.
3) The parties are not now nor have they ever been married.
4) pursuant to a stipulation for custody the court entered
an Order awarding primary physical custody of the minor child to
the mother on september 11, 1995.
A copy of that Order and
stipulation is attached hereto and marked Exhibit "A",
5) pursuant to the Order of september 11, 1995, Petitioner
has had visitation with his daughter every other sunday for a
period of approximatelY seven hours.
6) pursuant to paragraph eight of the Order of September 11,
1995 this period of visitation could be increased by mutual consent
of the parties.
. .
. '. " .
PATTI S. COOPER, : IN 'filE COURT OF COMMON PI.El\S Qt'
Plaintiff . CUMnERI.l\ND COUNTY, PENNSYLVl\NIl\
.
.
.
vs. :
.
.
LARRY TUBBS, . CIVn. l\C'rION - 1.l\W
.
Defendant . No.
.
STIPULl\TION FOR CUSTOI>Y.
AND
attorney,
custody.
This Stipulation is in regard to tho minor ohlld, Hnuhnol
S. Cooper, born on September 10, 1992, ono livinU at nll I:1moo
hereinbefore with her natural mother.
NOW cornea the plaintiff, 1'1\'1"1'1 a. COOl'lm, by hor
JAMES M. Bl\CII, and filoo tho within sl:1plllal:lon for
1, primary physical custody shall at oil timon Ilorolnoftor
be with the natural mothor, PlI'l"l'I S. COOl'EH.
2, The minor child, Rachael S. Coopor, wall born Ollt of wedlook
and the natural father is Ll\HRY 'l'unIlS. I.arry 'I'ubllo doeo
hereby acknowledge paternity of oaid child.
, '3, Father may, at his option, have visitation with hiD ohilo
every other sunday from 10.00 a.m. to 5.00 p.lII. I'ather
must advise mother not later than 6.00 (l.I11. I:ho pl'ocedinCj
Saturday of his intention to visit or not villll:.
4, Father shall not be undor tho influonco of alcohol or
drink alcohol while with tho child.
5, Father must take care of tho child ond nut loavo hor
with others.
6, Father must keep child clonn, nnd fOOl\ hor whon nocooaary.
Child is a diabetic nnd haD olloolnl noollll. I-'uther IIIUSt
follow all instructionll ro1.l1l:lvll to food Intoke Dnd
medicine intake.
7,
The periods of visitntion /In llot forth horoin
as the child geta oldor, by IIIl1tlllll. oonllllnt of
~9.'rl~- S.
lIlay increase
the parties.
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PATrI S. COOPER , . IN THE COURT OF COOMON PLEAS OF
.
plaintiff/Respondent . CUMBERLAND CXXJNTY, PENNSYLVANIA
.
.
.
vs. . NO. 95-4761 CIVIL TERM
.
.
.
LARRY TUBBS, : CIVIL ACTION - LAW
Defendant/Petitioner . IN CUSTODY
.
QUlER OF CXXlR'l'
AND tUft this--'2..-day of
consideration of the attached Custody
and directed as follows:
~
Conciliation Report,
, 1996, upon
it is ordered
1. The prior Order of this Court dated September 11, 1995, is vacated
and replaced by this Order.
2. The Mother, Patti S. Cooper, and the Father, Larry Tubbs, shall
have shared legal custody of Rachel S. Cooper, born Septerrber 10, 1992.
3. The Mother shall have primary physical custody of the Child.
4. The Father shall have partial physical custody of the Child on
alternating weekends, beginning October 19, 1996, from Saturday at 11:00
a.m. until Sunday at 4:00 p.m. After following this alternating weekend
schedule for a period of three (3) months, the parties agree to cooperate
in discussing further expansion of the Father's periods of partial custody
to the fullest extent in the Child's best interest.
5. The Father shall attend all quarterly treatment sessiona
concerning the Child's diabetic management and any other special treatment
or training sessions necessary to effectively participate in the Child's
care.
6. Each party shall notify the other inmediately of any medical
emergencies involving the Child, including hospitalization, which occur
during that party's period of custody. Each party shall also notify the
other of any significant developnents which occur in connection with the
Child's diabetic management during that party's period of custody.
7. The parties shall have custody of the Child over the Thanksgiving
and Christmas holidays as follows in 1996:
A. Thanksgiving. The Mother shall have custody of the Child on
Thanksgiving Day in 1996.
B. Christmas. In 1996, the Father ehall have custody of the
-
"
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-4761 CIVIL TERM
PATTI S. COOPER,
Plaintiff/Respondent
LARRY TUBBS,
Defendant/Petitioner
CIVIL ACTION - LAW
PBTITION FOR CONCILIATION CONFERENCE
AND NOW, comes the Defendant/Petitioner, I,arry Tubbs, by and
through his attorney, R. Mark Thomas, Esquire, and moves this Court
to schedule a new custody Conciliation Conference in this matter
and in support thereof respectfully represents:
1. On September 24, 1996, your Petitioner filed a Petition
to Modify Custody.
2. Pursuant to the Petition which was filed a CustOdy
Conciliation Conference was scheduled to be held on october 8,
1996, before Dawn S. Sunday, Esquire, Custody Conciliator.
3. Pursuant to the conciliation Conference which was held on
October 8, 1996, an Order of Court was entered on date of October
10, 1996 which set forth a three (3) month schedule of custOdy
which was to be followed by an increase of the periods of partial
custody to be enjoyed by the Petitioner provided the parties could
agree on expanded periods of partial custody.
4. It has been more than three (3) months that the parties
have followed the Order of October 10, 1996, and despite efforts of
Petitioner to reach an amicable resolution with regard to expanding
the periods of partial custody, such an agreement has not been
obtainable. Petitioner believes and therefore avers that if a new
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MAR 1 7 1997. .
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-,
.
PATrI S. OOOPER,
Plaintiff/Respondent :
.
.
IN THE corJRT OF COOMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
NO. 95-4761
CIVIL TERM
LARRY TUBBS,
CIVIL AcrION - LAW
Defendant/Petitioner
OODER OFaxJRT
AND lOl, this l ~ day of
upon consideration of the attached Custody
ordered and directed as follows:
~g ,1997,
Conc 1 at on Report, it is
1. The prior Order of this Court dated October 10, 1996, is
vacated and replaced by this Order.
2. 'Ihe Mother, Patti S. Cooper, and the Father, Larry Tubbs,
shall have shared legal custody of Rachel S. Cooper, born Septellber 10,
1992.
3. 'Ihe Mother shall have primary physical custody of the Child.
4. The Father shall have partial physical custody of the Child
on alternating weekends beginning March 21, 1997, on Friday evening from
5:00 p.m. until 9:00 p.m. and from the following saturday at 7:30 a.m.
until Sunday at 5:00 p.m. For purposes of this provision, the Father shall
return the Child to the Mother's residence on Friday at 9:00 p.m. and shall
pick up the Child from the Mother's residence on Saturday rrorning at 7:30
a.m. The Father shall also have custody of the Child during the foregoing
time periods on the weekend of March 14, 1997. Return of the Child to the
Mother's residence for the Friday overnight period shall continue on the
Father's alternating weekends until such time as the Father obtains a
qualified person to supervise and monitor the Child's diabetic condition
during the Father's night shift at work. When the Father obtains such a
qualified person to care for the Child or whenever .the Father or the
Father's fiancee is present in the home overnight, the Father's period of
weekend custody shall run continuously from Friday at 5:00 p.m. until the
following Sunday at 5:00 p.m.
5. The Father shall also have partial physical custody of the
Child every Wednesday evening from 5:30 p.m. until 8:30 p.m. The Mother's
periods of vacation shall take precedence over the Father's periods of
custody under this provision. However, the Father shall be entitled to
make up a missed period of custody on another weekday evening.
6. The parties shall share or alternate custody of the Child on
holidays as follows:
A. christmas - The Christmas holiday shall be divided into
segment A, which shall run from 7:30 a.m. until 9:00
p.m. on Christmas Eve and Segment D, which shall begin at
9:00 p.m. on Christmas Eve and end at 8:00 p.m. on
Christmas Day. The Mother shall have custody of the
Child during segment A in odd nurrbered years and during
Segment B in even numbered years. The Father shall have
custody of the Child during Segment A in even numbered
years and during Segment B in odd numbered years.
Easter, July 4th, Thanksgiving - The period of holiday
custody on Easter and Thanksglving shall run from 7:15
a.m. until 5:00 p.m. on the day of the holiday and on
July 4th shall run from 7:15 a.m. until 8:00 p.m. on the
day of the holiday. The Father shall have custody of the
Child on Easter in odd numbered years and on July 4th and
Thanksgiving in even numbered years. The Mother shall
have custody of the Child on Easter in even numbered
years and on July 4th and Thanksgiving in odd numbered
years.
B.
C. Memorial Day, Labor Day, Mother's and Father's Day - The
period of holiday custody on Memorial Day, Labor Day,
Mother's Day and Father's Day shall run from 7:15 a.m.
until 5:00 p.m. on the day of the holiday. The Father
shall have custody of the Child in every year on Memorial
Day and Father's Day. The Mother shall have custody of
the Child in every year on Labor Day and Mother's Day.
7. The Father shall have custody of the Child during the summer
school vacation for two uninterrupted one week (7 day) periodS upon
providing three weeks advance notice to the Mother. The Father's periods
of custody under this provision shall begin on Sunday at 5:00 p.m, (on the
Mother's weekend cuatody period) and end on the following Sunday at 5:00
p.m. at the conclusion of the Father's regular weekend period of custody.
After the Child has attended Diabetes Camp (at 8 years of age), the parties
shall cooperate in expanding the Father's periods of summer custody as
consistent with the best interests of the Child. SchedUling of the Child's
diabetes camp shall take precedence over all other summer custody
arrangements.
8. Each party shall notify the other immediately of any medical
emergencies involving the Child, including hospitalization, which occur
during that party's period of custody. Each party shall also notify the
other of any significant developments which occur in connection with the
Child's diabetic management during that party's period of custody.
9. During his periods of partial custody, the Father shall be
primarily responsible for the Child's diabetic management.
10. The Father shall continue to follow all medical instructions
concerning the Child's diabetic management, inclUding requirements
governing food intake and medication administration.
5. DefendantlPetitioner believes that Rachel's best interests will be served by
making four specific revisions to the aforementioned Order:
A. On alternating weekends, DefendantIPetitioner has partial physical custody of
Rachel from Friday at 5:00 p,m. until Sunday at 5:00 p,m, DefendantlPetitioner seeks a
modification of this provision to the extent that instead ofretuming Rachel to her mother on
Sunday evening, she would remain with him until Monday afternoon, at which time he will
deliver her to her kindergarten class. DefendantlPetitioner believes that this will serve
Rachel's best interests in that it will afford her more time with her father, inasmuch as he does
not work on Monday during the day and the cost of day care would be reduced for both
parties,
B. The current Order provides that DefendantlPetitioner has partial physical
custody of Rachel every Wednesday evening from 5:30 p.m. until 8:30 p.m.
DefendantlPetitioner seeks a modification of this provision to the extent that he would pick
Rachel up at the conclusion of her school day, The return time would not be changed.
C. At present, DefendantlPetitioner is responsible for all transportation for each
exchange of physical custody. DefendantlPetitioner believes that it would be more equitable
for the parties to equally share the transportation so that the party receiving custody would
be responsible for transporting Rachel. More importantly, this would give Rachel and
DefendantlPetitioner more time together.
PATrI S. COOPER,
plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 95-4761
CIVIL TERM
LARRY TUBBS,
Defendant/petitioner
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF CCXJRT
AND NCM, this 10
consideration of the attached
and directed as follows:
day of (Q.r-~-..J ' 1996, upon
custody ConCiliation Report, it is ordered
1. The prior Order of this Court dated September 11, 1995, is vacated
and replaced by this Order.
2. The Mother, Patti S. Cooper, and the Father, Larry Tubbs, shall
have shared legal custody of Rachel S. Cooper, born September 10J 1992.
3. The Mother shall have primary physical custody of the Child.
4. The Father shall have partial physical custody of the Child on
alternating weekends, beginning October 19, 1996, from Saturday at 11:00
a.m. until sunday at 4:00 p.m. After following this alternating weekend
schedule for a period of three (3) months, the parties agree to cooperate
in discussing further expansion of the Father's periods of partial custody
to the fullest extent in the child's best interest.
5. The Father shall attend all quarterly treatment sessions
concer.ning the Child's diabetic management and any other special treatment
or training sessions necessary to effectively participate in the Child's
care.
6. Each party shall notify the other ilTlT\ediately of any medical
emergencies involving the Child, including hospitalization, which occur
during that party I s period of custody. Each party shall also notify the
other of any significant developments which occur in connection with the
Child's diabetic management during that party's period of custody.
7. The parties shall have custody of the Child over the Thanksgiving
and Christmas holidays as follows in 1996:
A. Thanksgiving. The Mother shall have custody of the Child on
Thanksgiving Day in 1996.
B. Christmas. In 1996, the Father shall have custody of the
Exhibit "An
Child on Christmas Eve from 6:00 a,m. until 5:00 p.m. and on
Christmas cay from 6:00 a.m. until 4:00 p.m. The Mother
shall have custody of the Child from Christmas Eve at 5:00
p,m. until Christmas morning at 6:00 a.m.
6. During his periods of partial custody, the Father shall be
responsible for care of the Child and, except in extraordinary
circumstances, shall not leave her in the care of a third party.
9. The Father shall follow all medical instructions concerning the
Child's diabetic management, including requirements governing food intake
and medication administration.
., 10.
scheduled
custody.
11. The parties shall cooperate with each other in exchanging the
Child's clothing for purposes of changes in custody.
, '
The Father shall insure that the Child attends her regularly
activities which occur during the Father's periods of partial
12. The Father shall neither consume nor be under the influence of
alcohol during periods of partial custody with the Child.
13. If after following the custody schedule set forth in this order
for a period of three (3) months, the parties are unable to reach an
agreement as to expanded periods of partial custody for the Father or
custody arrangements for holidays and surraner vacation, either party may
petition the Court to have this matter relisted with the Conciliator for a
second Conference.
14. This order is entered pursuant to an agreement of the parties at a
custody Conciliation Conference. The parties may modify the provisions of
this Order by mutual agreement. In the absence of mutual agreement, the
terms of this order shall control.
BY THE COURT,
(~I &lMu il~ , ~.vt~
Edgar BV Bayley, J. u
cc: R. Mark Thomas, Esquire - counsel for Defendant/Petitioner
James M. Bach, Esquire - Counsel for plaintiff/Respondent
TRUE COpy FROM RECORD
In Testimony wh-.rcof, I here unlo sel my hand
and tho seal of said Court at Carll!le, Pa,
This ,..I.t~~.... day of......c.P.,4;...,:" 19,9.~..
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5. Paragraphs 9 and 10 of the parties' Custody Order of March 18,1997,
requlr I, , that Father assume responsibility for management of the minor
child's abellc condlllon while she Is In his custody. Including following of all medical
Instrucllons and the proper administration of medication.
6, Pelltloner's health Insurance plan through the Federal Government covers
100% of the minor child's medlcallon and treatment for her dlabellc condlllon. with no co-
payment required. Pelllloner has therefore, In recent years, provided to Respondent
during his periods of temporary physical custody, the LlfeScan Meter to measure the
minor child's glucose levels, test strips, Insulin, lancets, and needles.
7, The minor child continues to be under the care and treatment of the
Pediatric Diabetic Clinic of the Hershey Medical Center. Mrs. Glenda Hunter, RN. head
nurse of the Pediatric Dlabellc Clinic. recommends to parents that they utilize the same
glucose L1feScan Meter which has buill In memory funcllons and the same Insulin. Shs
has confirmed this In recent years and most recently on August 25. 1998.
8. The glucose L1feScan Meter. which Pelltloner has In recent years been
providing to Respondent during his periods of temporary physical custody. has a buill In
memory function which allows Petitioner to examine the glucose levels monitored by
Respondent while ths minor child Is In his custody.
9. Despite all of the above. the Respondent has decided to unilaterally stop
using all materials. Including the glucose LlfeScan Meter provided by Petitioner. and has
purchased his own medical equipment which Includes a glucose monitor which has no
memory function, He has advised Petitioner In writing of these facts and additionally that
he will request that Petitioner provide one-half (1/2) of the cost of all of the Items that he
PA'rrI S. COOPER, . IN THE COURT OF COMMON PLEAS OF
.
plaintiff/Respondent . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 95-4761 CIVIL TERM
,
. CIVIL ACTION - LAW
.
LARRY TUBBS, .
.
Defendant/petitioner , IN CUSTODY
.
ORDER OF cxxro
AND to'i, this ,) 3 AA day of 0..."'.",.....\_ ' 199B, upon
consideration of the attached Custody conci1."iation "'Report, it is ordered
and C:irected as follows:
1. A Hearing is scheduled in Courtr<J9ll1 No. .;l. , of the
cumberland County Court House, on the ~S,t:J,. day of 'j:,A:;:,,!l:::!.. '
199B, at I: '>, () o'clock, J:.m., at which time testimony in this case will
be taken. At the Hearing, the Father, Larry Tubbs, shall be deemed to be
the ITOving party and shall proceed initially with testimony. counsel for
the parties shall file with the Court and opposing counsel a MelTOrandum
setting forth each party's position on custody, a list of witnesses who
will be called to testify at the Hearing, and a sl.llTlllClry of the anticipated
testimony of each witness. These MelTOranda shall be filed at least ten
(10) days prior to the Hearing date.
2. Pending Hearing or further order of Court, this Court's prior
order dated l'.arch lB, 1997, shall continue in effect with the following
additional provision:
The Father shall have custody of the Child on Halloween
trick-or-treat night in even numbered years from 5:30 p.m. until 8:30 p.m..
The Mother shall have custody of the Child on trick-or-treat night in odd
numbered years.
()
BY THE COURT,
J ~ I &/.4;:'- il3. 03-c>J..e<f-
Edgar B. yley
J.
co: Charles Rector, Esquire - counsel for Mother
paul J. Esposito, Esquire - counsel for Father
TitUE COpy Fr.0M RECORD
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PATTI s. COOPER,
Plaintiff/Respondent
IN THE COURT Or' COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSi'L VANIA
vs.
NO. 95-4761 CIVIL TERM
LARRY TUBBS,
Defendant/Petitioner
CIVIL ACTION - LAW
CUSTODY
PRIOR JUDGE: Edgar B. Bayley
CUSTODY COOCILIATIOO SllMMARi' REPORT
IN ACCORDANCE WITH CUMBERLI\ND COUNTY RULE OF CIVIL pROCEDURE
1915.3-8, the undersigned custody Conciliator submits the following report:
1. The pertinent information concerning the child who is the subject
of this litigation is as follows:
~
DATE OF BIRTII
CURRENrLY IN cusrooy OF
Rachel F. Cooper
september 10, 1992
plaintiff/Mother
2. A Conciliation Conference was held in this matter on January 15,
1998, with the following individuals in attendance: The Mother, patti S.
Cooper, with her counsel, Charles Rector, Esquire, and the Father, Larry
Tubbs, with his counsel, Paul J. Esposito, Esquire.
3. This Court previously entered Orders in this matter on October
10, 1996 and March 18, 1997, both of which were based upon agreements of
the parties at Custody Conciliation Conferences. The Father filed this
Petition seeking shared transportation for exchanges of custody and minor
extensions of his periods of partial custody. There was a great deal of
hostility between the parties at the Conference and the parties had
difficulty communicating with each other in such a way as to focus on the
Child's best interest. This is a serious problem as the Child is diabetic
which requires special cooperation between the parties. It will be
necessary to schedule a Hearing in this matter.
4. The Father's position on custody is as follows: The Father
proposed to add an additional overnight period to his alternating weekend
custody schedule as well as an additional one and one-half hour period to
his Wednesday evening period of custody with the child, as the r'ather is
off work during those times. The Father also sought equally shared
transportation and an opportunity to take the Child trick-or-treating in
alternating years. The Father wants to spend m:lre time lIith the Child and
believes he has been doing a good job in maintaining the Child I s diabetic
care. The Father feels that the Mother I s concerns regarding the child I s
blood sugar levels and allergies are unfounded, but was willing to make a
special appointment with the Child I s physician to discuss the Child I s
PA'l'rI S. OXlPER / . IN THB COURT or COMMON PLEAS or
.
plaintiff/Respondent , CUMBERLAND COUNTY, PBNNSYLVANIA
.
.
,
vs. NO. 95-4761 CIVIL TBRM
:
LARRY TUBBS, CIVIL AcrION - LAW
Defendant/Petitioner .
.
ORDER or CXXJRT
"
AND tm, this J S day of
upon consideration of the attached Custody
ordered and directed as follows:
"'"rI\ a.....cfi- ' , 1997,
Conciliation Report/ it is
1. The prior Order of this Court dated October 10, 1996, is
vacated and replaced by this Order.
2. The Mother, Patti S, cooper, and the rather/ Larry Tubbs,
shall have shared legal custody of Rachel S. Cooper, born September 10/
1992.
3. The Mother shall have primary physical cust~y of the Child.
4. The Father shall have partial physical custody of the Child
on alternating weekends beginning March 21, 1997, on Friday evening from
5:00 p.m. until 9:00 p.m. and. from the following Saturday at 7:30 a.m.
until Sunday at 5:00 p.m. ror purposes of this provision, the Father shall
return the Child to the Mother's residence on Friday at 9:00 p.m. and shall
pick up the Child from the Mother's residence on Saturday rrorning at 7:30
a.m. The Father shall also have custody of the Child during the foregoing
time periods on the weekend of March 14/ 1997. Return of the Child to the
Mother's residence for the Friday overnight period shall continue on the
rather's alternating weekends until such time as the Father obtains a
qualified person to supervise and monitor the Child's diabetic condition
during the Father's night shift at work. When the Father obtains such a
qualified person to care for the Child or whenever the rather or the
Father's fiancee is present in the home overnight, the Father's period of
weekend custody shall run continuously from Friday at 5:00 p.m. until the
following sunday at 5:00 p.m.
5. The rather shall also have partial physical custody of the
Child every Wednesday evening from 5:30 p.m. until 8:30 p.m. The Mother's
periods of vacation shall take precedence over the Father's periods of
custody under this p:-ovision. However/ the Father shall be entitled to
make up a missed period of custody on another weekday evening.
6. 'l'he parties shall share 0:- altemate cust05J' of the Child on
holidays as follows:
.-' ~ .....
A. Christmas _ The christmas holiday shall be divided into
segment A, which shall run from 7:30 a.m. until 9:00
p.m. on Christmas Eve and Segment B, which shall begin at
9:00 p.m. on Christmas Eve and end at 8:00 p.m. on
Christmas Day. The Mother shall have custody of the
Child during segment A in odd numbered years and during
segment B in even numbered years. The Father shall have
custody of the Child during segment A in even numbered
years and during segment B in odd numbered years.
B. Easter, July 4th, Thanksgiving - The period of holiday
custody on Easter and Thanksgiving shall run from 7:15
a.m. until 5:00 p.m. on the day of the holiday and on
July 4th shall run from 7:15 a.m. until 8:00 p.m. on the
day of the holiday. The Father shall have custody of the
Child on Easter in odd numbered years and on July 4th and
Thanksgiving in even numbered years. The Mother shall
have custody of the Child on Easter in even numbered
years and on July 4th and Thanksgiving in odd numbered
years.
C. Memorial Da , Labor Da , Mother's and Father's Da - The
period of holiday custody on Memorial Day, Labor Day,
Mother's Day and Father's Day shall run from 7:15 a.m.
until 5:00 p.m, on the day of the holiday. The Father
shall have custody of the Child in every year on Memorial
Day and Father's Day. The Mother shall have custody of
the Child in every year on Labor Day and Mother I s Day.
7. The Father shall have custody of the Child during the summer
school vacation for two uninterrupted one week (7 day) periods upon
providing three weeks advance notice to the Mother. The Father's periods
of custody under this provision shall begin on Sunday at 5:00 p.m. (on the
Mother's weekend custody period) and end on the following sunday at 5:00
p.m. at the conclusion of the Father's regular weekend period of custody.
After the Child has attended Diabetes Camp (at 8 years of age), the parties
shall cooperate in expending the Father's periods of surr:ner custody as
consistent with the best interests of the Child. scheduling of the Child's
diabetes camp shall take precedence over all other surr:ner custody
arrangements.
,
,
I
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"
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8. Each party shall notify the other irranediately of any medical
emergencies involving the Child, including hospitalization, which occur
during that party I s period of custody. Each party shall also notify the
other of any significant developments which occur in connection with the
Child's diabetic management during that party's period of custody.
9. During his periods of partial custody, the Father shall be
primarilY responsible for the Child's diabetic management.
10. The Father shall continue to follow all medical
concerning the Child's diabetic management, includin;J
governing food intake and madication administration.
instructions
requiremonts
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PA'I'l'I S. CXlOPER , . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. . NO. 95-4761 CIVIL TERM
.
. CIVIL ACTION - LAI~
.
LARRY TUBBS, :
Defendant : IN CUSTODY
OODER OF CXXlRT
AND ~,this --:2.~ day o~ J7 ~
consideration of the attached Custody Conciliat on Report,
and directed as follows:
, 1998, upon
it is ordered
1. The prior orders of this COurt dated April 15, 1998, January 23,
1998 and March 18, 1997 shall remain in full force and effect.
2. Based upon the agreement of the parties at the october 20, 1998
Custody COnciliation Conference, the Mother's Petition for Contempt is
dismissed.
Edgar B.
J.
cc: Charles Rector, Esquire - Counsel for Mother
Paul J. Esposito, Esquire - COunsel for Father
('.~n->";"J.J., 1(J/~3ItjJ.
-I) .& .6'.
~
,
PA'I'l'I S. CXlOPER , . IN 'l.'HE COURT OF <XlMMON PLEAS OF
.
plaintiff . CUMBERLAND COONTY, PENNSYLVANIA
.
.
.
vs. NO. 95-4761 CIVIL TERM
LARRY TUBBS, . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
PRloo JUOGB: Edgar B. Bayley
CUSI<DY CXH:ILlATION SlHV\RY REPCm'
m AC(XlUll\OCB WITH ClI'IBERLl\ND cx:unY RULE OF CIVIL PROCEOORE
1915.3-8, the undersigned Custody conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
~
DATE OF BIRTH
CllRRfNrLY m CUS'lOOY OF
Rachel F. Cooper
September 10, 1992
Mother
2. A conciliation COnference was held on october 20, 1998, with the
following individuals in attendance: The Mother, Patti S. Cooper, with
her counsel, Charles Rector, Esquire and the Father, Larry Tubbs, with his
counsel, Paul J. Esposito, Esquire.
3. As represented by counsel, the parties agreed to entry of an order
in the form as attached.
Oc.-IvbfA dO, /99f
Date
IQU/I~~
Dawn S. sunday, Esquire
custody conciliator
-
"
..
the order as an individual who may transport Rachael on those occasions when
Defendant/Petitioner is unable to do so.
B. Defendant/Petitioner should be given first priority for addlUonal
periods of partial physical custody of Rachael when he is available and
Plaintiff/Respondent is not, as opposed to having Rachael be with a child care
provider.
C. Plaintiff/Respondent should be responsible for transporting Rachael
at the conclusion of each period of Defendant/Petitioner's partial physical
custody.
D. Plaintiff/Respondent has not adhered to that portion of paragraph
5 of the order of this Court dated March 18, 1997, which remalns in full force
and effect in that she has not afforded Defendant/Petitioner make-up evenings of
partial physical custody on at least two occasions. Defendant/Petitioner wishes
to have two make-up periods of partial physical custody and the assurance that
he \vill have such make-up times in the future.
6. The parties. through their counsel, have endeavored at length to
resolve these issues by agreement, however, they have been unable to do so.
7. Defendant/Petitioner believes and therefore avers that the foregoing
suggested modifications \vill serve Rachae1's best interests.
WHEREFORE, Defendant/Petitioner respectfully requests that this
..
"
PA'I'l'I S. CXlOPER , . IN THE COURT OF ~ PLEAS OF
.
Plaintiff : CUMBERLAND CCXlN'l'Y, PENNSYLVANIA
.
.
vs. . NO. 95-4761 CIVIL TERM
.
. CIVIL ACTION - LAW
.
LARRY TUBBS, .
.
Defendant . IN CUSTODY
.
OODER OF <XXlRT
AND~, this ~8" day of ro~U", , 1998, upon
consideration of the attached Custody concilfation Report, it is ordered
and directed as follows:
1. The prior orders of this court dated April 15, 1998, January 23,
1998 and March 18, 1997 shall remain in full force and effect.
2. Based upon the agreement of the parties at the OCtober 20, 1998
CUstody Conciliation Conference, the Mother's Petition for Contempt is
dismissed.
BY THE COURT,
I~I f'AlI-t\.... 73. "il"lA.jJ::t.
EdgarB~i1BaY1ey, ~O"cr J.
cc: Charles Rector, Esquir~ - Counsel for Mother
Paul J. Esposito, Esquire - counsel for Father
T"":~''':' .-..... "".' :-~....\, \ ....':='rl"RD
if .\ -. "
c' I , .'; :.'! ~1'1 hand
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fill. Ol 8 d~i' of (]2d..." t9....frf.'
..""...........-J.A...~~.e ..,..4,e~
:,....~".......
0(1' . Prolhonorary
Exhibit -A-
.,' .'
.
.
PA'I'l'I S.' CXlOPER, . IN THE COURT OF COMMON PLEAS OF
.
plaintiff . CUMBERLAND CCXlN'l'Y, PENNSYLVANIA
.
.
.
vs. . NO. 95-4761 CIVIL TERM
.
:
LARRY TUBBS, . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
PRloo JUOGB: Edgar B. Bayley
='!\.OY CXH:ILIATION SlJoIMI\RY REPCm'
m AClXIUlANCE WITB ClJ1BERLAND cxnmc RULE OF CIVIL ~
1915.3-8, the undersigned custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
~
Rachel F. cooper
DATE OF BIRTIl
september 10, 1992
Cll11RENTLY m cu:;'!OOY OF
Mother
2. A conciliation COnference was held on october 20, 1998, with the
following individuals in attendance: The Mother, patti S. cooper, with
her counsel, Charles Rector, Esquire and the Father, Larry TUbbs, with his
counsel, Paul J. Esposito, Esquire.
3. As represented by counsel, the parties agreed to entry of an order
in the form as attached.
Or.AJ1xA ;J.O, /C;9f
Date '
i::~
Dawn S. S~~
custody conciliator
.
.'
on Easter and Thanksgiving shall run from 7:15 a.m. until 5:00
p.m. on the day of the holiday and on July 4th shall run from
7:15 a.m. until 8:00 p.m. on the day of the holiday. The
Father shall have custody of the child on Easter in odd
numbered years and on July 4th and Thanksgiving in even
numbered years. The Mother shall have custody of the Child on
Easter in even numbered years and on July 4th and Thanksgiving
in odd numbered years.
C. HEMCJUAL DAY, LABOO. DAY, HOl'fIER'S AND FATlIER'S DAY: The
period of holiday custody on Memorial Day, Labor Day, Mother's
Day and Father's Day shall run from 7:15 a.m. until 5:00 p.m.
on the day of the holiday. The Father shall have custody of
the Child in every year on Memorial Day and Father's Day. The
Mother shall have custody of the Child in every year on Labor
Day and Mother's Day.
D. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
7. The Father shall have custody of the Child during the summer
school vacation for two uninterrupted one week (7 day) periods upon
providing three weeks advance notice to the Mother. The Father's periods
of custody under this provision shall begin on sunday at 5:00 p.m. (on the
Mother's weekend custody period) and end on the following sunday at 5:00
p.m. at the conclusion of the Father's regular weekend period of custody.
After the Child has attended Diabetes Camp (at 8 years of age), the parties
shall cooperate in expanding the Father's periods of summer custody as
consistent with the best interests of the child. scheduling of the Child'S
diabetes camp shall take precedence over all other summer custody
arrangements. The Father shall not schedule his vacation periods of
custody under this provision at a time when the Child has cheer1eading.
8. The party receiving custody of the Child shall be responsible to
provide transportation for the exchange of custody, with the exception of
the Father's Wednesday periods of custody for which the Father shall
provide all transportation. The parties shall make a reasonable effort to
be personally present for exchanges of' custody. However, in exigent
circumstances, the parties may have another responsible adult who is
familiar to the Child provide the transportation on his or her behalf.
9. Each party shall notify the other irrrnediate1y of any medical
emergencies involving the Child, inclUding hospitalization, which occur
during that party's period of custody. Each party shall also notify the
other of any significant developments which occur in connection with the
Child's diabetic management during that party's period of custody.
10. During his periods of partial custody, the Father shall be
primarily responsible for the Child's diabetic management.
11. The Father shall continue to follow all medical
concerning the Child's diabetic management, including
governing food intake and medication administration.
instructions
requirements
PA'I'l'I S. CXlOPER , . IN THE COURT OF COMMON PLEAS OF
.
plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. . NO. 95-4761 CIVIL TERM
.
.
.
LARRY TUBBS, . CIVIL ACTION - LAW
.
Defendant/petitioner . IN CUSTODY
.
PRIoo JUOGB: Edgar 8. Bayley
CUS'lOOY CXH:ILlATION 5lI!MARY REPCRr
m ACXXlUlANCE WITH ClJoIBERLAND CXXlN'fi RULE OF CIVIL J?R()CEIXlRE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
~
DATE OF BIRTH
CtlRRalTLy IN CUS'lOOY OF
Rachel S. Cooper
september 10, 1992
Mother
2. A conciliation COnference was held on october 28, 1999, with the
following individuals in attendance: The Mother, patti S. Cooper, with her
counsel, Charles Rector, Esquire, and the Father, Larry Tubbs, with his
counsel, Paul J. Esposito, Esquire.
3. The parties agreed to entry of an order in the form as attached.
IU,~&A
Date
/,/777
.
Da~d1:~
custody conciliator
I'A'ITI S, COOPHIl
Pl.AINTIFF
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v.
95-4761 CIVIl. ACTION I.AW
LARRY TUlIIIS
DEFENDANT
IN CUSTODY
OIwtm OF COllllT
AND NOW. Wednesday, Mar. 1 I, 2005 .upon considerlltionofthe lI11nehed COOlplllinl,
it is hereby dirccted 11mt purties nnd thcir respeclive counselnppear bcfore Dawn S. Sunday, Esq. . the conciliator.
nt 39 West Main Slreel. Mechanlcsburg. PA 17055 on Tuesdav, May 31, 2005 at 1:00 PM
for a Pre.llearing Custody Conti:rence. At such conli:rence, nn effort will be Olnde 10 resolve the issues in dispUle; or
iflhis cnnnol be nccomplished. 10 deline nnd narroW the issues to be hemd by Ihe courl. and to enter into n leOlpOrnr)'
order, All children aile live or older may nlso bc present U\ the conli:rence, Fnilure to appenr nlthe conli:rence may
provide grounds for entry of a tcmpornry or pennanent order,
The eourl hereh)' dlrecls Ihe pnrllcs 10 furlllsh UII)' und nil exlslllll: I'roleelloll frol\1 Abuse orders,
Speclnl Hellef orders,nlld Cuslod" orders 10 Ihe conclllnlor -18 hours prior 10 scheduled henrln\!.
FOil TIlE COUIlT.
By: .J!!!-.- DlIIvn S. SundllJ'J Esq. jY
Cuslody COlleilintor
The Court ofC0l11111011 Plens ofCUl11berllllld Coullty is required by IlIw to cOl11pl)' with Ihe A11lericnns
with Disnbilites Acl of 1990, For infonlll11ion nboutnceessible litdlilics nnd rensonllble nceonll11odntions
uvuilnble to disnbled individunls huvinll business before the court, pleuse eontnctour oflice. AlIurrungements
l11ust be mnde ntlensl 72 hours prior tonny hearing or business hetllre Ihe court. You muslnllend the scheduled
conti:rence or heuring,
YOU SIIOUl.D TAKE TillS PAPER TO YOUR ATroRNEY AT ONCE, IF YOU DO NOT
IIA VI' AN ATTORNEY Oil CANNOT AFFORD ONE. GO TO OR TELEPHONE TIlE OFFICE SET
FOIlTH BELOW TO FIND OUT WIIERE YOU CAN GET LEGAL IIELI',
Cumherlllnd Counly Bnr Assodnlion
n South Bedford Street
Cnrlisle. Pennsylvnnin 171113
Telephone (7171 ~4l).31 r.r.
PATTI S. COOPER,
Plaintiff/Petitioner
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-4761
CIVIL ACTION - LAW
IN CUSTODY
LARRY TUBBS,
Defendant/Respondent
PETITION TO MODIFY
ORDER OF CUSTODY
AND NOW, comes the Petitioner, Patti S. Cooper, by and through her
attorney, Charles Rector, Esquire, and files a Petition to Modify Order of
Custody, and support thereof, avers the following:
1. Petitioner Is Patti S. Cooper, Mother, who currently resides at
205 N. Locust Point Road, Mechanlcsburg, Cumberland County, Pennsylvania.
2. Respondent Is Larry Tubbs, Father, who currently resides at 162
E. Louther Street, Apt. 1, Carlisle, Cumberland County, Pennsylvania.
3. The parties hereto are the f.larents of the minor child Rachel S,
Cooper, born September 10, 1992.
4. On November 4, 1999, the Honorable Edgar B. Bayley entered
an Order of Court consistent with the agreement reached by the parties at
their Custody Conciliation before Dawn S. Sunday, Esquire, which Order
granted Mother primary physical custody of the minor child with periods of
temporary physical custody to Father on alternating weekends, alternating
holidays, etc. (see Exhibit "A" attached),
PA'I'l'I S. CXlOPER, . IN THE COURT OF CClMMOO PLEAS OF
.
plaintiff/Respondent . CUMBERLAND COUNTY, PENNSYLVANIA
.
:
vs. . NO. 95-4761 CIVIL TERM
.
:
LARRY TUBBS, . CIVIL ACTION - LAW
.
Defendant/Petitioner . IN CUSTODY
.
AND~, this 4 ih
consideration of the attached
~,d directed as follows:
OODER OF CXXlRT
day of ~ftffihe R
Custody Conc 1 at on Report,
, 1999, upon
it is ordered
1. The prior orders of this COurt dated october 28, 1998, April 15,
1998, January 23, 1998 and March 18, 1997 are vacated and replaced with
this order.
2. The Mother, Patti S. Cooper, and the Father, Larry Tubbs, shall
have shared legal custody of Rachel S. cooper, born September 10, 1992.
3. The Mother shall have primary tflysica1 custody of the Child.
4. The Father shall. have partial physical custody of the Child on
alternating weekends fran Friday at 5:00 p.m. until Sunday at 5:00 p.m.
The Father shall also have partial physical custody of the Child every
Wednesday fran 3:30 p.m. (when the Father shall pick up the Child at the
school latchkey program or other childcare provider) until 8:30 p.m. The
Mother's periods of vacation shall take precedence over the Father's
periods of custody on Wednesdays. However, the Father shall be entitled to
make-up a missed period of Wednesday custody on another weekday evening.
5. The parties shall cooperate in arranging a make-up 1 day (fran
8:00 a.m. until 5:00 p.m.) period of custody for the Father during the
summer school break in 2000.
6. The parties shall share or alternate having custody of the Child
on holidays as follows:
A. CIIRIS'nlAS: The Christmas holiday shall be divided into
Segment A, which shall run fran 7:30 a.m. until 9:00 p.m. on
Christmas Eve and Segment B, which shall begin at 9:00 p.m. on
Christmas Eve and end at 8:00 p.m. on Christmas Day. The
Mother shall have custody of the Child during Segment A in odd
numbered years and during segment B in even numbered years.
The Father shall have custody of the Child during Segment A in
even numbered years and during segment B in odd numbered
Years.
B. EASTER, JULY 4th, TIIANKSGIVING: The period of holida
EXHIBIT
I~
on Easter and Thllnkogivin'.l oha11 run from 7115 lI.m. until 5:00
p.m. on the day of the holiday ond on July 4th ohall run from
7115 a.m. until 8100 p.m. on tho day of the holiday. The
Father ohall hovo cuotody of the Child on Easter in odd
nurrtlerod yoara IInd on July 4th ond 1hllnksgiving in even
numberod yoars. The Mother IIhllll havo cuotody of the Child on
Eaoter in oven nurrlJorod yeara ond on July 4th II1ld Thanksgiving
in odd numbered yellrs.
C. ~~ OIlY, LAIDI IlIIY, HC71'll/!II'S J\ND FATIIER'S DAY: The
period of holiday custody on Memorial ~y, Lllbor Day, Mother's
Day and Father's Day shll11 run from 7:15 lI.m. until 5:00 p.m.
on the day of the ho1idllY, Tho Father shall have custody of
the Child in overy yellr on Memorial Day and Father's Day. The
Mother shall have custody of the Child in every year on Labor
Day and Mother's Day.
D. The holiday cllstody schedule shall supersede and take
precedence over the regular custody schedule.
7. The Father shall have custody of the Child during the sunmer
school vacation for two uninterrupted one week (7 day) periodS upon
providing three weeks edvance notice to the Mother. The Father's periods
of custody under this proviaion shall begin on Sunday at 5:00 p.m. (on the
Mother's weekend cuatody period) and ond on the following Sunday at 5:00
p.m. at the conclusion of the Father's regular weekend period of custody.
After the Child has attended Diabetos Camp (at 8 years of age), the parties
shall cooperate in expanding the Fllthor' s periods of summer custody as
consistent with the best interesta of the child. Scheduling of the child's
diabetes camp shall take precedence over all other summer custody
arrangements, '1110 Fathor shall not schedule his vacation periods of
custody under this provision at a time when the Child has cheer1eading.
8. The party roceiving custody of the Child shsll be responsible to
provide transportation for the exchange of custody, with the exception of
the Father's Wodnesday periods of custody for which the Father shall
provide all transportation. 'llie parties shall make a reasonable effort to
be personally present for oxchanges of custody. However, in exigent
circumstances, the parties may have another responsible sdu1t who is
familiar to the Child provide the trsnsportation on his or her behalf.
9. ElIch party shall notify the other irrmediate1y of any medical
emergencies involving the Child, including hospitalization, which occur
during that party's period of custody. Each party shall also notify the
other of any significant dovelo(Xnents which occur in connection with the
Child's diabetic management during that party's period of custody.
10. During his periodo of partial custody, the Father shall be
primarily reDponsible Cor tho Child IS diabetic management.
11. 111a I'nthllr /lhall continue to follow all medical
concerning the Child's diabetic management, including
governil)(J Cood intake and modication administration.
instructions
requirements
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PATTI S. COOPER,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 95-4761
LARRY TUBBS,
Defendant/Respondent
CIVIL ACTION - LAW
IN CUSTODY
PETITION TO MODIFY
ORDER OF CUSTODY
AND NOW, comes the Petitioner, Patti S. Cooper, by and through her
attorney, Charles Rector, Esquire, and files a Petition to Modify Order of
Custody, and support thereof, avers the following:
1. Petitioner is Patti S. Cooper, Mother, who currently resides at
205 N. Locust Point Road, Mechanicsburg, Cumberland County, Pennsylvania.
2. Respondent is Larry Tubbs, Father, who currently resides at 162
E. Louther Street, Apt. 1, Carlisle, Cumberland County, Pennsylvania.
3. The parties hereto are the parents of the minor child Rachel S.
Cooper, born September 10, 1992.
4. On November 4, 1999, the Honorable Edgar B. Bayley entered
an Order of Court consistent with the agreement reached by the parties at
their Custody Conciliation before Dawn S. Sunday, Esquire, which Order
granted Mother primary physical custody of the minor child with periods of
temporary physical custody to Father on alternating weekends, alternating
holidays, etc. (see Exhibit "AU attached).
5. Petitioner believes and therefore avers that Respondent has
separated from his wife and has resided alone in an apartment in Carlisle for
approximately six (6) months.
6. Petitioner further believes and therefore avers that the
conditions inside the apartment are sufficiently unsanitary to have caused the
minor child to contract pin worms, which condition was diagnosed on April
28, 2005, and requires medical treatment by a physician.
7. The minor child, while in the custody of her father, does not
have her own sleeping arrangements and Petitioner believes and therefore
avers that mattresses are placed on the floor of the small apartment during
father's weekends of temporary physical custody.
8. The pin worm condition that the minor child is currently
suffering from can be caused by unsanitary bedding and is highly contagious.
WHEREFORE, Petitioner respectfully requests that your Honorable
Court suspend alternating periods of temporary physical custody pending a
Conciliation of this matter and further pending improvement of the living
conditions of the minor child while in the custody of Respondent.
Respectful
d:
----
Date:
1 / ~
S '-t'( 0 j'
I verify that the statements made herein 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 authorities.
r~.j~
Patti S. Cooper
Date: 5' Y I 0 S'
PA'ITI S. CX::OPER,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
vs.
: NO. 95-4761
CIVIL TERM
:
Defendant/Petitioner
: CIVIL ACTION - LAW
: IN CUSTODY
LARRY TUBBS,
AND tOi, this 4 :I:b
consideration of the attached
and directed as follows:
aIDER OF CXXlRT
~Yem6el<.
Conciliation Report,
day of
Custody
, 1999, upon
it is ordered
1. The prior Orders of this Court dated October 28, 1998, April 15,
1998, January 23, 1998 and March 18, 1997 are vacated and replaced with
this Order.
2. The Mother, Patti S. Cooper, and the Father, Larry Tubbs, shall
have shared legal custody of Rachel S. Cooper, born September 10, 1992.
3. The Mother shall have primary physical custody of the Child.
4. The Father shall have partial physical custody of the Child on
alternating weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m.
The Father shall also have partial physical custody of the Child every
Wednesday from 3:30 p.m. (when the Father shall pick up the Child at the
school latchkey program or other childcare provider) until 8:30 p.m. The
Mother's periods of vacation shall take precedence over the Father's
periods of custody on Wednesdays. However, the Father shall be entitled to
make-up a missed period of Wednesday custody on another weekday evening.
5. The parties shall cooperate in arranging a make-up 1 day (from
8:00 a.m. until 5:00 p.m.) period of custody for the Father during the
summer school break in 2000.
6. The parties shall share or alternate having custody of the Child
on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into
Segment A, which shall run from 7:30 a.m. until 9:00 p.m. on
Christmas Eve and Segment B, which shall begin at 9:00 p.m. on
Christmas Eve and end at 8:00 p.m. on Christmas Day. The
Mother shall have custody of the Child during Segment A in odd
numbered years and during Segment B in even numbered years.
The Father shall have custody of the Child during Segment A in
even numbered years and during Segment B in odd numbered
years.
B. EASTER, JULY 4th, THANKSGIVING: The period of holida
EXHIBIT
J~
on Easter and Thanksgiving shall run from 7:15 a.m. until 5:00
p.m. on the day of the holiday and on July 4th shall run from
7:15 a.m. until 8:00 p.m. on the day of the holiday. The
Father shall have custody of the Child on Easter in odd
numbered years and on July 4th and Thanksgiving in even
numbered years. The Mother shall have custody of the Child on
Easter in even numbered years and on July 4th and Thanksgiving
in odd numbered years.
C. MEMCiUAL DAY, LABOR DAY, MOl'HER'S AND FATHER'S DAY: The
period of holiday custody on Memorial Day, Labor Day, Mother's
Day and Father's Day shall run from 7:15 a.m. until 5:00 p.m.
on the day of the holiday. The Father shall have custody of
the Child in every year on Memorial Day and Father's Day. The
Mother shall have custody of the Child in every year on Labor
Day and Mother's Day.
D. The holiday cllstody schedule shall supersede and take
precedence over the regular custody schedule.
8. The party receiving custody of the Child shall be responsible to
provide transportation for the exchange of custody, with the exception of
the Father's Wednesday periods of custody for which the Father shall
provide all transportation. The parties shall make a reasonable effort to
be personally present for exchanges of custody. However, in exigent
circumstances, the parties may have another responsible adult who is
familiar to the Child provide the transportation on his or her behalf.
9. Each party shall notify the other immediately of any medical
emergencies involving the Child, including hospitalization, which occur
during that party's period of custody. Each party shall also notify the
other of any significant developments which occur in connection with the
Child's diabetic management during that party's period of custody.
10. During his periods of partial custody, the Father shall be
primarily responsible for the Child's diabetic management.
11. The Father shall continue to follow all medical
concerning the Child's diabetic management, including
governing food intake and medication administration.
instructions
requirements
12.
scheduled
custody.
The Father shall ensure that the Child attends her regularly
activities which occur during the Father's periods of partial
13. The parties shall cooperate with each other in exchanging the
Child's clothing for purposes of changes in custody.
14. Neither party shall consume or be under the influence of alcohol
during periods of custody with the Child.
15. The noncustodial party shall have reasonable telephone contact
with the Child during the other party's periods of custody.
16. This order is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of
this order by IlRltual consent. In the absence of IlRltual consent, the terms
of this order shall control.
BY THE COURT,
~~~~ ~,':
1i,!}(.9i/,;I./f 4/r:
, ". :' ':-~;!~~ ~.~~~O
:r;@:1JJ;~
p'ail)f)~~
cc: Charles Rector, Esquire - Counsel for Mother
Paul J. Esposito, Esquire - Counsel for Father
PATrI S. CXXJPER,
plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 95-4761
CIVIL TERM
LARRY TUBBS,
Defendant/Petitioner
CIVIL ACTION - LAW
IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
CUSl'ODY <:xECILIATIOO SUMMARY REPCRI'
IN AC<XIIDANCE WITH <nmERLAND <XXlNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
DATE OF BIRTIl
CURREN.rLY IN CUSl'ODY OF
Rachel S. Cooper
September 10, 1992
Mother
2. A Conciliation Conference was held on October 28, 1999, with the
following individuals in attendance: The Mother, Patti S. Cooper, with her
counsel, Charles Rector, Esquire, and the Father, Larry Tubbs, with his
counsel, Paul J. Esposito, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
1U~-6vI
Date
/ /777
,
~
Custody Conciliator
N ~ -{Q ::) ~,
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r
PATTI S. COOPER
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
95-4761
CIVIL ACTION LA W
LARRY TUBBS
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Wednesday, May 11, 2005
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear befc"e Dawn S. Sunday, Esq.
at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, May 31, 2005
, the conciliator.
at -1.:00 PM
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 tive or older may also be present at the conference. Failure to appear at the confcrence may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/
Dawn S. Sundav, Esq. _~_Y_
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR A TTORNEY AT ONCE. IF YOU DO NOT
HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OffiCE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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PATTI S. COOPER,
Pia i ntiff /Petition er
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 95-4761
LARRY TUBBS,
Defendant/Respondent
CIVIL ACTION - LAW
IN CUSTODY
ACCEPTANCE OF SERVICE
I, Jane Adams. Esquire, counsel for the Defendant, Larry Tubbs, accept service
of the Petition to Modify Order of Custody, received on
fhtu; J~. ~M,j- ,
/
and certify that I am authorized to do so.
D't'~
PATTI S. COOPER
Plaintiff
RECEIVED JUN 15 2005~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
95-4761
CIVIL ACTION LAW
LARRY TUBBS
Defendant
IN CUSTODY
Prior Judge: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
L The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Rachel S. Cooper
September 10, 1992
Mother
2. A conciliation conference was held on June 13, 2005, with the following individuals in
attendance: The Mother, Patti S. Cooper, with her counsel, Charles Rector, Esquire, and the Father,
Larry Tubbs, with his counsel, Jane Adams, Esquire.
3. The Mother filed this Petition for Modification for the purpose of addressing certain health
concerns regarding the Child. The issues were resolved at the conference with no further need for an
additional Order at this time.
~
Date
/ 3 .kx::; S
.
V~J.
Dawn S. Sunday, Esq1;1
Custody Conciliator
cc: Charles Rector, Esquire - Counsel for Mother
Jane Adams, Esquire - Counsel for Father
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