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Home My WebLink About95-06677 !'( ~ . ...... ~ '"'.... ~~... ,..., ~~~~ ~ G:c-"-'-c ....:co> '" 0..-:-1 IO....~ t ac::..J;c: ~ LLlc...c;GZ ::::h4l~w . t...::oxp. ~ ....:> EU t<I >< ~ Q ;; Cl 0 r:: .~ E-< ~ ~ ~ Ii .. III rJt/) ~ ~ HB ~~ ~ -II r.:l Cl 8 'b I li!1 :;:J H r.:l H ~ ~ . at/) III ..:l E-<>< > a :J:: E-<11I ~ ~>< 0 H ~~ fa ~ t/) :E:H O~ 0111 ;... 0 II: , . -. ~~. ...-.-.---.----.... '. t-lov..-2 8 i~95 tjJ . . '" , 'J :'j95 i'JV " . .' . ~ ~, · .~ !,l a __>1 ~jr~.', " ~ <, .... S =i' ':,' i5 'l:I. to''.'': iSi! ' ;,~; '" ",.;. (;) ,', ~ ~,- .' MAY ... 6 19~ VERIFICATION I verify that the statements made in the foregoing Petition To Modify Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S, ~ 4904, relating to unsworn falsification to authorities, ~L-~,J/ L --:~ Michae ,Bretz DATED: 3/td/9f/ I I ,- co ; - f:: !;:-: {.....' , - I' e...: ) ...- , - . , . , )' . .~.:J , , l~ . "'7\ '..:'~ ,.....: " , , ~ ,j =- , ;'1- ; I , r:. :.j , 0) U " ; - - , - I '1 ,,' ,0' -- .-.. , ,0 ,- r.' ,~ ~, '(I tg ~ ~ During such illness or medical emergency, both parties shall have the right to visit the child as often as he or she desires consistent with the proper medical care of the child, 8, Neither parent shall do anything which may estrange the child from the other party, or injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love or affection for the other party, 9, Any modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and only if executed with the same formality as this Stipulation and Agreement. 10, The parties desire that this Stipulation and Agreement be made an Order of Court to the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact have jurisdiction over the issue of custody of the parties' minor child and shall retain such jurisdiction should circumstances change and either party desire or require modification of said Order. 11, The parties agree that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other, 12, The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence, ,. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein mentioned. w 1>> A M1~ rn. 4aJ.i!J.Cl Serena Marie Farling 0 Dc;f;J- ...9.2/7'1'y ,~<< DATE: ~ff~ 1 '/?' # ~~ f/ ':-4y#' Michael Eugene Bretz (..21.91 ~- (., - :-''; ,'- r,. /: I...~ (~.~ , ) :-; .}: ,', 1 'j t '...! ,'-' 1 --.'; " !-,iJ 0 d:l. I' 0:-' ~'J '-.' \,...'\ U '. ,. SERENA MARIE FARLING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 95-6677 CIVIL : CIVIL ACTION - CUSTODY v, MICHAEL EUGENE BRETZ, Defendant ORDER OF COURT AND NOW. this Co day of \-\c\ ( \\ , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before \--\\c\,u~ \ \ , P.,.v,,:\"J , Esq" the Conciliator, at " '" \1l\V\ \.. ,""'\. ) Iv--. ' \ 3~ ,),\\ '\"I;"CI.T'\\.) i-\\ \ \ , \ r- on the \<, day of f Y'...... 2000, at \ \' \)() ~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. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: 'W~\6~\{)'Q\L~ .1''().1'{\,~\ G.\\, . Custody Conciliator ( l ',<,:>,) The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 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, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 A SERENA MARIE FARLING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 95-6677 CIVIL : CIVIL ACTION - CUSTODY v, MICHAEL EUGENE BRETZ, Defendant PETITION FOR MODIFICATION OF CUSTODY 1, Petitioner/Defendant, Michael Eugene Bretz. and Plaintiff/Respondent, Serena Marie Farling, are the natural parents of Tasha Marie Bretz born July 8, 1991 hereinafter referred to as child, 2, On July 6, 1999 a Custody Stipulation and Agreement was made an Order of the Court signed by the Honorable Edgar B, Bayley, a copy of said Order and Stipulation is attached hereto and incorporated herein as Exhibit A, 3, Since the signing of that Agreement the Petitioner's work schedule has changed, 4, Petitioner would like shared legal custody and temporary physical custody of the child, 5, Petitioner proposes that the mother would have primary physical custody subject to following periods of temporary custody with the Respondent: a, Alternating weekends from 9:00 a,m, Saturday until 9:00 a,m, Monday; b, Summer school vacation from the first Monday after school closes until the last Friday the week before school re-opens; Mother is to have two consecutive weeks during this summer period, Mother is further to have alternating weekends from 9:00 a,m, on Saturday until 9:00 a,m, Monday during the summer school vacation, c, Alternating holidays, said holidays being New Year's Day. Memorial Day, Labor Day, Independence Day, and Thanksgiving, On even numbered years the father shall the child from 12:00 p,m, on December 24th until 12:00 p,m, on ~ ,(' " v: , , cO l... " ( ~, '. .' . . . " ~ ',', g',}~" . · a 1 r~5i'i:i lilt , i! , . , APP. " 0 '"~ I) On alternating weekends from Saturday morning at 10:00 a.m. at which time Mother will bring the child to Father's residence, until Saturday afternoon at 3:30 p.m. at which time FlIther shall be responsible to ensure that the child is transported back to Mother's residence, and again on Sunday at 10:00 lI,m. at which time Mother shall bring the child to Father's residence until Sunday afternoon at 3:30 p,m, at which time Father shall be responsible to return the child to Mother's residence, II) Every Monday afternoon at 3:00 p,m, at which time Father shall pick the child up from the daycare provider until Wednesday morning at 8:00 a,m, at which time Father shall return the child to the daycare provider, 4. Both parties shall be entitled to one uninterrupted week of vacation time with the child over the summer months, The parties shall provide each other with thirty (30) days advance notice as to when they intend to exercise this period of exclusive custody, 5, The parties shall alternate the major holidays, those holidays being defined as Easter, Memorial Day. Fourth of July. Labor Day, and Thanksgiving, Father shall have Easter in 2000 and the schedule shall alternate thereafter, These periods of partial custody shall be from 8:00 a,m, until 6:00 p,m.. and the parties shall share the transportation for these periods of partial custody, SERENA MARIE FARLING, Plaintiff ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO, 95-6677 CIVIL TERM MICHAEL EUGENE BRETZ, Defendant CIVIL ACTION - LAW JUDGE PREVIOUSLY ASSIGNED: The Honorable Edgar B. Baytey CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: I, The pertinent information concerning the child(ren) who is(are) the subject of this litigation is as follows: CURRENTLY IN CUSTODY OF NAME B1RTHDA TE Tasha Marie Bretz July 8, 1991 2, A Conciliation Conference was held on April 13,2000, and the following individuals were present: the Plaintiff and her attorney, Diane M, Rupieh, Esquire; the Defendant and his attorney, Robert J, Mulderig, Esquire, 3. Items resotved by agreement: See attached Order, 4. Issues yet to be resolved: See attached Order, 5, The Plaintiffs position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7, Need for separate counsel to represent child(ren): Neither party requested.