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Home My WebLink About95-06656 '1j:~' '.~ ,'- ~~.c\ I::~ -- ~ ,rJ ca . 7 .--- ~ r:J cl> ~ J " 1O ~ ~ I . . RANDY L. BELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 96.6666 CIVIL TERM , vs. CHRISTINE M. BELL, Defendant ORDER AND NOW, this ? t.. t~ day of ~, 1996, upon rscslpt of the Conciliator's Report, it appearing that a hearing in this matter Is necessllry, It Is heraby ordered and directed as follows: A hearing Is schedulsd for the <:2/ Af day of 9, _., ----. 1996, at It} ; '/5 o'clock -A:..M., In Court Room Number L.. of the Cumberlend County Court House, Carlisle, Pennsylvania. Both parties, through counsel, will provide each other and the court with a list of witnesses ten (10) days prior to the date of the hearing along with a statemsnt as to their expacted testimony. Additionally, both parties will submit their proposal for a resolution of the matter. BY THE COURT, Lori K. Serratelll, Esquire Attorney for Plaintiff IJ~!, J. L. Rex Bickley, Esquire Attorney for Defendant ~~~l#/~"'19'. , .d'~ mlb~ 1/J/, 11(, /IA/ ~, 1'- \ ,,""1 -~ ... " " r' ;., .~ J ...- ,'" " , ,'J: ,I' . . # .;>J . '.: '. .' .' '.' :; 't:i I~J . '_ ,.J'~...\J -' ~ . . '. vs. ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. BELL, Plaintiff CHRISTINE M. BELL, Dafendant CIVIL ACTION - LAW NO. 95-6656 CIVIL TERM JUDGE PREVIOUSLY ASSIGNED: None INo Judicial Conflicts) CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8Ib), the undersigned Custody Conciliator submits the following report: 1. The pertinent Information concerning the childlren) who Islare) the subject of this litigation Is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Stephen M. Bell Jessica L. Bell 10 September 1983 7 May 1986 2. A Conciliation Conferenca was held on 21 December 1995, and the following Individuals were present: the Plaintiff and his attorney, Lori K. Serratelll, Esquire; the Defendant appeared with her attorney, L. Rex Bickley, Esquire. 3. Items resolved by agreement: None 4. Issues yet to bs resolved: All Issues. 1 ~ " .. 6. The Plalntlff'a position on custody Is as follows: Plaintiff resides In Florida. He Is requesting to racelve the child ran for tha majority of each Christmas school vacation and for the entlra summer commencing five days after school ends until one week prior to school rssumlng. The Father Is requesting that Mother pay the cost of the transportation by air flight, or bear the responsibility for driving the children to Florida since he maintains that shs Is the party who originally moved and created the distance betwsen the parties. 6. The Defendant's position on custody Is as follows: Defendant wants to alternate the Christmas holiday so that one year she has Christmas, and the other year, he has the Christmas holiday. She is willing to allow the Fathsr to have the summer vacation with the children. She Is not willing, however, to bear any expenses rslated to the transportation of the children back and forth from Florida, nor Is she willing to incur any expense related to long distance phone calls for the children to their father. 7. Need for separate counsel to represent children: None requested and the Conciliator does not believe any is necessary. 8. Need for independent psychologlcel evaluation or counseling: Nons requested and the Conciliator does not believe any is necessary. 9. A hesring in this matter is expected to take two hours. 2 3 10. Other matters and comments: There was quite a delsy between the initial conference In this case and the request by the attornsys to have a hearing. The attorneys felt that they may be eble to work out the detells of the cese. Eventuelly, the Conciliator was notified thet they were not able to reach an agreement, and counsel provided him with letters as to their respective positions. The main Issue In this case seems to be the expense of transporting the children back and forth to Florida. The hearing should not be that complicated and should be fairly short. The only Issue for the Court to decide Is what is an appropriate Christmas holiday schedule and who should bear the expense of transporting the children back and forth from Florida. Date: 22 April 1996 fIt1~ (~ Michael L. Bangs y Custody Conciliator -,-<,._~..,..~.~ "'';:'W'o.,.. .~.. co, ,_......."'~...... ....,::.",., ' .""" ..", .. -.! ,! 111I'-,:- - '0<'" IJI II , !!IIlIII " IlII .. ....,---- -~ ------.--. . .. .,.', ,. I, '. II'. I ... , I tit >'1',..1.. ';". : II. ' ",",,11' ., "".'. '<'.'1. .. ,.,".'. i.lI, .,~:, " ,_'C' '.,: ' 11 .IIIIII!!~, 11I'..:_" . . .' .,,: .,.,., . ;....". !It _.. ,,' II .. .11,.'11'_,.' III... ....,,:' "'."..1IllI tllI.II..,I:.......;' I..'..... ,', ..',,'.'..., -,:;r. -I, IIIlI1 III . '. -. RID .,..,.,.,",.....:,..;'~ "1' .. II III ...11...... · II. .. . :.:. .. - .. .., II,.... 1111 .' .'lIglII III II ill,..: III, ..... 1'_' I · III 11I.-, ,III. ". II . ."11I: II _II' .,: .... . · '11 .. II I ", .'.:. ..,::" '. '..,lIIiIt I.. 11II II..., "...:....... ..'., , ...... '.' ..:;: ",.' I lIlII._ .. 1111'.... ,"::,~.: I' III -..IIIIII'II, 1IIiI'" 11III. ..'..........':..','..,.,..::.:.,.."."..:,',...,...,., ..r,,: .-., ... .. IIlIIi ..-"..., .'.'......'.....:.:....". III" .. .'" _Ill II _ . .:.',: ~ -= :a .-m';: _=..; .,..,. 11II1'. ~ '.., ,.. iii .. .-, II .,.11II ... -, 11II;' '., _Ill 1111 ,II, '..'1 .:....,..'...'. '...,11 I ~ .,11 IIII,_,...:......~ .. L' III "ill' , ...,...,. ".,. "J:' :.", , ..' _= ....... III III 1iIII..':'::_:'" '..11.... '. III -- .',_. 1IlI':; ,_ III .. III .. "'."".:,' ..' ".'. .'... WI,. ..'.'11: .,'.'11II' 'IlIIl! ."11 I. II" " _,:::."..... 11II iii _ .__ , :,. ,...',:... 11II...,.11I11I ':P I!, ."....:.. ...,' ..'.: . III II .;....... h ',I!I":'III",1'!II':"-."1BI1II I I I I --..... ~ 'IIoI.M__.~~-~''''''' " ......,.....;F.,;;: ...... :r-::t~ ;/J 'j,-~ i;:1 :?'jj It!~ 1~.~ " " ~ t!t\ ~..... ~. ~ , ~~,-~jl~ I ~ ~i1 '~ i ~ , , INCOME AND EXPENSE STATEMENT OF Christine M. Bell SSN 177-54-9703 ~NCOMB Employer: (Blue Shield) Keystone Health plan Address: 300 Corporate Drive, Camp Hill, PA Type of work: MeDer service Telephone Representative payroll Number Pay period (weekly, bi-weekl~, etc.) GrosS Pay per pay period: Itemized payroll Deductions: $842.00 108.85 63.84 8.34 23.36 Federal witholding Social Security Local wage Tax State Income Tax Retirement Savings Bonds credit Union Life Insurance Health Insurance Other (specify) Net pay per pay Period: Bi-weekly 20.82 616.79 Other IncrJme: Month ~ ~ Interest Dividends pension Annuity Social Security Rents Royalties Bxpense Account Gifts unemployment compo Workmen's Camp. support 100.00 During School Year Not paid during summer , EXPENSBS Weekly HCl1l\e Mortgage/rent Maintenance Utilities Blectric Gas Oil Telephone Water Sewer Bmployment Transportation/Lunch Taxes Real estate Personal property/occupation Income (School tax) Insurance Homeowners (renters) Automobile Life Accident Heal tl1 ** Other Automobile Payments Fuel Repairs Medical Approximate Uninsured Unreimbursed Costs Per Month Bducation Lunches Supplies **Deducted from pay (See Page 1) Monthly Y~"'1y 470.00 97.00 60.00 20.00 16.41 196.90 10.00 43.34 120.00 520.00 192.50 40.00 50.00 25.00 30.00 10.00 . EXPENSES Weekly Monthly Personal Clothing Food Barber/hairdresser Credit payments Credit card VISA Charge account Memberships 25.00 200.00 50.00 Loans Credit Union Miscellaneous Household help Child care 45.50 Papers/books/magazines Entertainment Pay TV Vacation Gifts Legal fees Charitable contribu- tions Other child support Alimony payments Miscellaneous Other 197.17 20.00 19.98 168.00 20.00 Total Expenses: 1764.40 YFUiII"'W .'. IUUlDY L. BIlLL, : IN THE COURT OF COMMON PLEAS Plaintiff ICUMBERLAND COUNTY, PENNSYLVANIA ~..:tJI',of v. . . I No. tJ.s - 6~5(P . . I CIVIL ACTION - LAW . . CHRISTI NIl M. BIlLL, Defendant : CUSTODY ORDER OF COURT AND NOW, this l:tlh.. day of D'-c-t!-Ir'lh., , 1995, upon consideration of the attached COMPLAINT, it is hereby directed that the parties ~nd their respective counsel appear before M i ""..... L. Ibc..n (, ~'I. the conciliator, at o. . (c.,., ; 1\ 1/ , on the day of ..., 1995, at .m. for a Prehearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Either party may bring the children who are the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. By: YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND our WHERE YOU CAN GET LEGAL HELP. Office of the Court Administrator 4th Fl., Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 t5c,. I FlLtO-oFFlCc OF 71 II; flp.On-/ONOTNlY 95 Dce -5 1,/11/: 02 CUMBEflUND COUNTY PENNSYL\W.JL-\ I /Jo5'ff' acl.t~ /fl;J,~ 4 6j~. ~ '5.9$ >1~ M~ ~ df' 1~5'9> &t1 ~ ~ PI.~# , 1 , . . RANDY L. BELL, plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CHRISTINE M. BELL, Defendant CIVIL ACTION - LAW CUSTODY COMPLAINT FOR CUSTODY AND NOW COMES the Plaintiff, Randy L. Bell, in the above captioned action, by his attorney Lori K. Serratelli and the law firm of SERRATELLI, SCHIFFMAN, BROWN & CALHOON who petitions this Honorable Court to grant him shared legal and primary physical custody of the parties' children based on the following: 1. Plaintiff and Defendant are the parents of two minor children, namely: Stephen M. Bell, born September 10, 1983 and Jessica L. Bell, born May 7, 1986. 2. The Plaintiff currently resides at 4721 Orange Grove Boulevard, North Fort Myers, Lee County, Florida 33903. He resides with Bonnie Bell, his wife. 3. The Defendant currently resides at 423 A Duke Street, Enola, Cumberland county, Pennsylvania. She resides with the children. 4. During the past five years the children have resided with ~ - the following persons and at the following addresses: Persons Address Dates Christine M. Bell (Mother) Stephen M. Bell' Jessica L. Bell 423 A Duke st. Enola, PA 17025 1990 to the Present 5. The relationship of Plaintiff to the children is that of father. 6. The relationship of Defendant to the children is that of mother. 7. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 8. There was a previous action with regard to this matter, Clearfield County, Pennsylvania Docket No. 90-308-CD. The parties executed a Stipulation which was to be incorported by reference into the Divorce Decree. The Stipulation provided that the Defendant, Chris M. Bell, has sole custody of the children and that the Defendant may arrange visitation with the children through the Plaintiff. (See Exhibit A) 9. Plaintiff believes that the best interests and permanent welfare of the children will be served by granting shared legal and primary physical custody of the children to the Plaintiff. WHEREFORE, Plaintiff requests that the Court grant shared legal and primary physical custody of the parties' minor children 'stephen Bell lived with his Father in Flordia for one year in 1993. In 1994 he returned to live with his Mother at her request. to the Plaintiff. Respectfully submitted, ( Serratell , Esqu re SE TELLI, SCHIFFMAN, BROWN & CALHOON 2040 Linglestown Road Suite 106 Harrisburg, PA 17110-9483 Attorney for Plaintiff NOU-14-1995 14150 FROM SSG B TO 19419951072 P.007~10 VERIFICATION I verify that the .tate~ents made in the ~oreqoin9 Petition are true and oorrect. I understand that talse state.ents aade herein are subjeot to the penalties of 18 Pa.C.S. SBction 4904 relating to unsworn ta18ificatio~~~oriti..~ ~D-;~.1t:X " I!;YNIRIT .& ~4~-''''''-''-'''' ~j,.'1.-'_-'. . IN THE COURT OF COMMON PLEAS OF CLEARFIELD COUNTY, PENNSYLVANIA CIVIL DIVISION CHRIS M. BELL, 'I Plaintiff I I , .1 'i . II vs. NO: 90-308-CD IN DIVORCE RANDY L. BELL, Defendant DIVORCE DECREE I :1 cse in divorce having been presented to the Court on Complaint ., , I ., :1 I' , !. AND NOW, to-wit, this 21st day of August, 1990, this grounds pursuant to Section 201(c) of Act Number 1980-26 and the complaint alleging the marriage is irretrievably broken and , ninety days have elapsed from the date of filing of the comPlainti I :, and the parties have filed their respective ~f~jdavit evidencing ! il consent to the divorce; the Court being satished therewith does i iI therefore decree upon payment of costs, CHRIS M. BELL, the Plain-; 1t :1 :1 :1 '. II tiff, be divorced and separated from the bonds of matrimony con- tracted with: RANDY L. BELL, the Defendant, and that all and every the duties, rights and claims occurring to either of the 'I said parties by reason of the said marriage shall hereafter cease . '. and determine, eKcept as agreed to by the parties under the terms. and conditions of the Stipulation Agreement dated August 13, 1990, which is attached hereto and incorporated herein by reference and said parties be severally at liberty to marry again in like manner, as if they had never been married. BY THE COURT: /s/Josech S. Ammerman Judge _.~..... I IN THE COURT OF COMMON PLEAS OF CLEARFIELD COUNTY, PENNSYLVANIA CHRIS M. BELL, Plaintiff, CIVIL ACTION-LAW DIVORCE VS. No. 90-J08-CD RANDY fi. BELL, ATTORNEY FOR PLAINTIfF: V. JOSEPH JAMES 561 MARKET STREET JOHNSONBURG, PA 15845 (S14) 965-3237 Defendant STIPULATION AND NOW, this 13th day of AUllust 1990, , the parties agree and stipulate to the following concerning custody, support and legal fees. It is agreed by the parties . that the below stipulations would be incorporated by reference into the Divorce Decree. 1. Chris M. Bell, Plaintiff, has sole custody of the children. The Defendant may arrange visitation with the children through the Plaintiff. 2. All property matters have been settled prior to divorce and both parties release the other from any liabilities or claims as a result of this marriage. 3. The Defendant, Randy Bell, agrees to pay the sum of ,,"',: , J':' I: f \ "'/5: "3" ,1-,..... ~OO i ~ ,''''JH " N.L ""n ''''''',': 1',,:, I r .. -". ---.-.- ..-...- .... ." ~. ---___. ___. -"0_. ......._ $485. QO as leqal tees incurred by the Plaintiff in this divorce matter. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals on this 13 t h day of A.1I~II~r .MJ::~ (fc~ q]If, ~a (/ C~M. Bell , 1~-;&df Randy L Witness, , 1990. (SEAL) (SEAL) ~\, .,'1 oW' ''''':i' 't,<' ~~.lI" ':'1".-,- l$~'''' 't'fPr ;;10'":' ,..;': 'l,:> ~'..". , ~ . ....' ...T'f.i ;'f/i 0;;-::::' M'" .....,~. '$, "?',,: ;#~ \P.l",~: ,"i":' ~.- . ..J", i~~:..: :j;\:; :fo,'':'' I..~ . . -,:. . I':.' ,,:::",- t, . ~ m: N' 0:> ' -.:r -' ~ - c:::I~ " = ~ .. ' ...'e ;1... ~"'~\::Jo~' c.J.':r.'Q~ Lf~> u~.. w,~c:.:~. dl-~...., O'~~"'" ....c..g:;.Z,.: .....WW21 :;::~~~ ,_ Z. l"~ ." ~ \' ~\ .~ ~~ ~~ ~~ t~ ~~ ll<1ll Z~ Eo< Orol J~~ !ll< Z o - - ~ U~ ..... :j~ J-~' ..... ~ 8 !::'. r..g; ...t rollll i j~: 00 -+I lQ'tl ..:II': I': U Eo<U tJ.:; . QJ p:: 2:..... i:: ~ ;: PO lQr-l QJ ~~ ll< . ~O 0 ... - . > Eo< ..:I I-t III Eo< P glrol i:: III U gj ~ li! ZP = I-tU U _MU..AO..II..,.r."..... nit. Ofrtf'lllllO~OOA"""~I'II"1I1'" . . -c" ..0...... SUIlATlUI. SCHiffMAN Ilc BlOWN. p,c, lurlaD6 JotO IJNULNnM'N liwl UAU.I\llJau.rA 17110."1.1 NO\' ~ ,j ;:;~tk .. .: I"RI K. SERRAlf.1.U SnVf.N), SclllffMAN MICHAEL F, BROWN Ro~A1.O L CAulOON GARY L RoTHSCHIUl ROBERT 0, HAMILTON GARTH A. STEPHENSON OF CoUNSEL (MD Ie DC a.w ONLY) Sum 106 2040 L1NCWTO'&'N Ro.w HAuJ...u... rA 17110.9445 (7171 HO.'170 FAX(7In5-ICJ.~81 ...." November 20, 1995 Prothonotary Cumberland County Courthouse Carlisle, PA 17013 Re: Bell v. Bell Dear Sir/Madame: Enclosed for filing, please find the original and three copies of a Complaint for custody. Please time and date stamp the copy and return it to me in the enclosed envelope. Also, would you please forward it to the conciliator as Boon as DOBslble lcustoctv at:Christ:ma-.' i.': an issuel for scheduling and return the Order to me in the enclosed envelope after it has been executed. A self- addressed envelope has been enclosed for the Defendant. A check in the amount of $45.50 is enclosed. Thank you for your assistance in this matter. Sincerely, SERRATELLI, SCHIFFMAN, ~#~;;;l LKS/dae Enclosure cc: Randy L. Bell .,., .....~-"-,,~,,_..-.,.~~.-..... ..-.-_..,,_. "..,...~ .. - ,,~.~. :', ~}:t:,~,~...i;~~1":':'::;;:':"::"-~,.,::- :'-f::.-;i:-" .,- "~r',I!" '" .. RANDY L. BELL, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. CHRISTINE M. BELL, Defend.ant 95-6656 CIVIL TERM ORDER OF COURT AND NOW, this 21st day of June, 1996, upon consideration of the custody complaint in the above-captioned matter with respect to the parties' children, stephen H. Bell, born September 10, 1983, and Jessica L. Bell, born Hay 7, 1986, fOllowing a hearing and pursuant to an agreement of the parties on most of the issues as presented on the record by counsel, it is ORDERED and DIRECTED as follows: 1. Legal custOdy of the children shall be shared by the parties. 2. Primary physical custody of the children shall be in the mother. Temporary or partial physical custody of the children shall be in the father at the following times: a. From one week after commencement of the children's summer vacation (or from Father's Day, if such day occurs sooner than that time) until one week prior to resumption of the children's school. b. On an alternating yearly basis, during the children's Christmas vacation: from two days following commencement of the vacation until two days prior to the end of " the vacation, or from two days after Christmas until a day prior to the end of the vacation. c. At such other times as the parties mutually aqree upon. 3. with respect to each exchanqe of custody, transportation arrangements and expenses related thereto shall be the responsibility of the party receiving custody at the time. 4. Telephone expenses in connection with communications with the children shall be the responsibility of the party who is speaking with the children on the occasion in question. Nothing herein is intended to prohibit the parties from making arrangements different from those provided for herein by mutual agreement. J LORI K. SERRATELLI, ESQUIRE suite 106 2040 Linqlestown Road HarriSburg, PA 17110-9445 For the Plaintiff L. REX BICKLEY, ESQUIRE 121 South Street Harrisburg, PA 17101 For the Defendant _ ~ n>.;..p.<l101~,,,191.. .ob~ wcy J::;.ll.cl,:V ?l2o.J.lCJ.-Jo-tfiM.y O~Rc.c.. Ju..A...lf.. .;l.c. I 199 f". .:::u>1 . ~'-\ L. €,c\\ Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION LAW . ; NO.l(k5C:, CIVIL 19 qS : CUSTODY VISITATION v. . C\\ris"'C\t.~. ~\ \ Defendant ORDER OF COURT And now, this~, upon considemtion oClhe attached cO.lT\plaint, it is here~ directed that the aboveparlies and theirrespe tiveco~eta pear before Sj\(N\C" \ L. ~5:::' , Esquire, the conciliator, at . , . . Pennsylvania, on the.?1) day of 1999, at ~. \:f.'l A.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. All children age five or older may be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA WYBR OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 }-800-990-9108 ;- '~.::"1 .~.\:j ';" ,": Or" ~,. ;: '-:''f)T,t.j1Y 99 WG -II PH 3: 35 CUMU:'F!wN.:; COUNlY PE.I.JNS'(LVN-:!A f.I{Jlf &d. ~~ -/; 4 ~. ~''1'9'1 ~ ~ Z- ~. 1'114; t"l1 ~ ~ 711.,67 ~ . RANDY L. BELL, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 95.6656 CIVIL TERM : CIVIL ACTION - LAW : CUSTODY Plaintiff vs. CHRISTINE M. BELL, Defendant ORDER YOU, , Defendant, have been sued in Court to obtain custody, partial custody or visitation of the child(ren): You are ordered to appear in person at the Cumberland County Courthouse, Carlisle, Pennsylvania, on . 1999, at .m. before in Room _ for _ a conciliation or mediation conference _ a pretrial conference _ a hearing before to Court. If you fail to appear as provided by this Order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warmnt for your arrest. Pursuant to Pa. R.C.P. 1915.11 the child _ shall be _ shall not be required to attend a hearing before the court or a conference. YOU SHOULD TAKE TInS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, P A 17013 (717) 240-6200 BY THE COURT: J. RANDY L. BELL, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 95-6656 CIVIL TERM : CIVIL ACTION - LAW Plaintiff vs. CHRISTINE M. BELL, Defendant : CUSTODY PETITION TO MODIFY CUSTODY AND NOW comes the Plaintif17Petitioner, Randy L. Bell, by and through his attorney, Lori K. Serratelli, Esquire, and the law firm of Serrate iii, Schiffman, Brown & Calhoon, P.C., and avers as follows: 1. Petitioner is Randy L. Bell, an adult individual residing at 4721 Orange Grove Boulevard, North Fort Myers, Florida 33903. 2. Respondent is Christine M. Bell, an adult individual residing at 423-A Duke Street, Enola, Pennsylvania 17025. 3. The Petitioner and Respondent are the parents of two minor children, namely Stephen M. Bell, born September 10, 1983; and Jessica L. Bell, born May 7, 1986. 4. A Stipulation and Order of Court was entered June 21, 1996 providing that the parties had shared legal custody and that Respondent had primary physical custody of the children with Petitioner having temporary or partial physical custody. (See Stipulation and Order attached hereto as Exhibit "A"). S. Both children have expressed a strong desire to be in the Petitioner's custody in Florida. 6. Petitioner believes he can provide an excellent home and school system for the children and a strong religious and moral background in which they will flourish. WHEREFORE, Petitioner prays that primary physical custody be awarded to him with temporary or partial custody rights awarded to Respondent. Further. Petitioner and Respondent would continue to share legal custody. Respectfully Submitted, Lo rratelli. Esquire 1 NO. 27426 SERRATELLl, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg. P A 17110 (717) 540-9170 Auomey for PlaintilflPetitioner \ . JUL. 7.1999 10:3BAIl S. S. B. & C. Rbe. P'I. 17110 NO. ~673 .P. 4/4 f' . . "RRt.Jt!.'l'tOIl \ I I I \ I ;are true and a~ the statoMents mado in tho foreqoinq petition ect. I understand that false statements herein are the penalties of 18 Pa. c.s. section 4904, relatinq ification to authorities. I lllade subject !to unsworn fal : ; I I . . jDate: I I Randy Bell I I , . i ,I I ! . . . , , . CERTI.ICATE O. SERVICE this I, Lori K. Serratelli, :n -/1, day of -'" ...1., . Esquire, do hereby certify that on , 1999, I served a copy of the foregoing document by United states Mail, First class, postage pre-paid, to the following person(s): Christine Bell 423-A Duke Street Enola, PA 17025 ... 17110 Attorney for plaintiff I .4' ~ Q .. ~~ N 8~ .- :>' z:: . .iI: ~n t:a r;)~ 0; :t ~ -~ N "2 ~ Rim t=' -, ct;. a.. u. C\ rj~ U en a . . . . -"U..'D..".....nu..... hue OttI'lllCU OOA""'" 1r011 11....,.,., \J .. J ~ ~ !i! l!: ~;- ~ oli~_.. i~sJ5~':' .. 00 !jiJ ::~~: _ II "" ~ ~ -- J . . . .' a... DtfIl16 SIUATlLU. SCH/rrMAN. IllOWN at CAUlOON. ~c. IVlnJOI ,0001.INUU.nOWN InAl' H"....."'w.PA l7110.9670 JUt 3 01999 b/J ,. SEP 14 199~ RANDY L. BELL, PJalntiff ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-6656 CIVIL TERM CIVIL ACTION - CUSTODY VB. CHRISTINE M. BELL, Dcfcndant ORDER AND NOW this /J. -Il day of ~ . 1999, it being reported to thc Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undcrsigned Conciliator hereby relinquishes jurisdiction and returns the maller FOR THE COURT, to the Court Administmtor. If either of the parties wishes further proceedings in this action, they should petition the Court anew. I .HAEJ.!.. BAN, Custody Conciliator cc: Lori K. Sermtelli, Esquire Austin F. Grogan, Esquire ~~! ~.;-, ~ Ii t:'.- ~.i":' ~~.' ';lj"" i!" ~:!0, ;r~~~; . -~.. 'R ~:, ~ co: ~ b .. i5~ - ~Z ~) U;;: ,.~. :;;r j5i ~~ TO In ~c. u r~ ,"u 0.., k fEp F' w en ... u. Cf> :s <.:.) Cf> c..> .. . ,~:,'~:~~4iit\4d~:',l.;. . :'~ '~::";'~:"~f~{t~B':.:!~,. , .",' '-::~t:\ -:oo~~' .~~~;~; :;0; ti.... '". c.' ~ t" I 71!:1!1!1\' RANDY L. BELL, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 95-6656 CIVIL TERM : CIVIL ACTION - LAW Plaintiff vs. CHRISTINE M. BELL, Defendant : CUSTODY ORDER AND NOW, this J II ft. day of ~ y;r; ~~(t. 1999, upon consideration of the foregoing Stipulation to ModifY Custody, it is hereby ORDERED and DECREED as follows: 1. Legal custody of the children, Stephen M. Bell, born September 10, 1983, and Jessica L. Bell, born May 7, 1986, shall be shared by both parties. 2. Primary physical custody of the children shall be in the Mother, but the children shall reside with Father from August 13, 1999 through 2 days following the end of Church Camp in July 2000. Temporary or partial physical custody of the children shall be in the Mother for the 1999/2000 school year at the following times: A. Thnnklia1v1nv: For 1999, Mother shall have partial custody during the Thanksgiving school holiday from Thanksgiving Day until the following Monday evening. The parties shall share travel expenses for airline tickets or share physically the driving to transporlthe children for Mother's partial custody. Travel expenses include the cost of rental cars, fuel, and two nights hotel accommodations during the tmvel. ALEO-ot=FICE OF TH~ PPOTPONOTARV 99SEP21 AHII152 CUMI.lERLN>JQ COUNIY PENNSYLVA/lrA t B. Summer nratlon: For Summer 2000, Mother shall have partial custody beginning two (2) days following the children attending the Church of God Youth Camp, (last week of June/first week of July) which exact dates shall be supplied to Mother sixty (60) days in advance, through school year 2000/2001 where the children shall attend school in the district in which Mother resides. C. Srhool Year 200012001 Varatlon: Father shall have partial custody of the children for Christmas and summer 2001 as per the June 21, 1996 Order. Transportation expenses shall be shared by the parties. Nothing herein is intended to prohibit the parties from making armngements different from those provided for herein by mutual agreement. 3. Any major modilications to this Stipulation shall be in writing. Minor modifications or adjustments may be done orally by the parties. 4. Pennsylvania shall retain legal jurisdiction of this matter for purposes of any petitions to modifY, either for an emergency or otherwise. 5. Mother shall be entitled to claim both children as dependents for fedemltax year 1999 and Father shall be entitled to claim both children as dependents for federal tax year 2000 and shaU execute the necessary IRS forms. 6. Mothcr shall pay thc sum ofS200.00 pcr month in two (2) monthly payments to Fathcr effectivc August 13, 1999 and Father's support obligation to Mother shall be terminated cffective August 13, 1999 while the children reside with Father. 7. Mothcr shall continue to cover thc children on her medical covemgc while the children residc with thcir Father. BY THE COURT: q-otcf-f{ ~ L~ ~L q-..:lC/-CCi J6k ,',", RANDY L. BELL, Plaintiff : IN THE COURT OF COMMON PLEAS OF. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 95-6656 CIVIL TERM : CIVIL ACTION - LAW vs. CHRISTINE M. BELL, Defendant : CUSTODY STIPIJLA nON TO MOD1FV CUSTODY AND NOW, come the above-named parties and their attomeys and hereby stipulate and agree to the following provisions for custody of their minor children, Stephen M. Bell, born September 10,1983, and Jessica L. Bell, born May 7,1986, pending further proceedings in this matter and any subsequent order of court: 1. Legal custody ofthe children shall be shared by both parties. 2. Primary physical custody of the children shall be in the Mother, but the children shall reside with Father from August 13, 1999 through 2 days following the end ofChurc;h Camp in July 2000. Temporary or partial physical custody of the children shall be in the Mother for the 1999/2000 school year at the following times: A. Thnnksllivinv: For 1999, Mother shall have partial custody during the Thanksgiving school holiday from Thanksgiving Day until the following Monday evening. The parties shall share travel expenses for airline tickets or share physically the driving to transport the children for Mother's partial j:.,,j cu.tody. Travel expenses Include the cost of rental cars, fuel, and two night. hotel accommodations during the trr.vel. B. Summer vaeatlon: For Summer 2000, Mother shall have partial custody beginning two (2) days following the children attending the Church of God Youth Camp, Qast week of Juneffirst week of July) which exact dates shall be supplied to Mother sixty (60) days in advance, through school year 2000/2001 where the children shall attend school in the district in which Mother resides. C. Sehool Year 200012001 Vaeation: Father shall have partial custody of the children for Christmas and summer 2001 as per the June 21, 1996 Order. Transportation expenses shall be shared by the parties. Nothing herein is intended to prohibit the parties from making arrangements different from those provided for herein by mutual agreement. 3. Any major modifications to this Stipulation shall be in writing. Minor modifications or adjustments may be done omlly by the parties. 4. The parties agree to the entry of a Court Order in accordance with the terms and .. provisions of this Stipulation by the Court of Common Pleas of Cumberland County and further agree that Pennsylvania shall retain legal jurisdiction of this matter for purposes of any petitions to modifY, either for an emergency or otherwise. .2.~.....:.6,..;";{O":'''~'''....t<''',;;F''.- F""". "~"':':-'..'" .'w.,,..,,',.-.;-..,_ _"",_~...,.,.","__,...~.",,,.~,,_ . '. 5. The parties agree that Mothcr shall be entitled to claim both children as dcpcndents for federal tax year 1999 and Father shall be entitled to claim both children as depcndents for federal tax year 2000 and shall execute the necessary IRS forms. 6. Mother shall pay the sum of $200.00 per month in two (2) monthly paymcnts to Father cffective August 13, 1999 and Father's support obligation to Mother shall be terminated effective August 13, 1999 while the children reside with Father. 7. Mother shall continue to cover the children on her medical covemge while the children reside with their Father. IN WITNESS WHEREOF, the parties and their counsel have set their hands and seals this ~ day of A.....h999. WITNESSES: 10 . Serratelli, Esquire At omey for Plaintiff I Christine M. Bell ~'i ;'" J'., ,-,~., ""4:' ,- j"" ,~,:::; if,,:,., S~ ' :,,;....., -. '~\,' ~y :.'; U', , .... rr .;: ~.. 1.!Jr.,! 0". r.:t ~ ',' ,I. t~l)~;~ ~,<:. t::, -- u\" F IJ. U ~~ ?; :,... ~... .~ ~)"" .~- ,)=<: 0.:: ~ 9~ L~~ ~ lJ:). ~ W "J C1\ 0" .. . _""..' 'CHlI,.,,.".,., 1M nil.. Ot~ O)."...,..,u,....,.. . . ~-".' ,.. . ~ z ~ ~ oll JI~: ji_1i::::. B 0 -" !J~i J~~~~ I -- ...... -- I . . . ..... Chi." S.IUTIUI. SCHlrrMAN. 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