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HomeMy WebLinkAbout01-5610 STIPULATION FOR CUSTODY AND CHILD SUPPORT AND NOW, to wit, this ~-'7~q day of ~n/~ ,2001, it is Stipulated by and between JAMES PATRICK RICHARDS ("Father") and RENEER. RIDOLFI ("Mother'3 that the parties to this Stipulation desire that their minor child, MICHAEL JAMES RIDOLFI, bom March 5, 2001 maintain a positive relationship with both of their parents, and to further this goal, and intending to be bound thereby, the parties agree as follows:: CUSTODY 1. Mother and Father shall share joint legal custody of their minor child. Mother and Father shall have an affirmative obligation to consult with one another on major decisions affecting the Child agreeing that the Child's best interest shall be their paramount concern. It is understood that joint legal custody includes the tight of each parent to have aecess to all the Child's medical, dental and educational records and participate actively in the Child's life events. 2. Mother shall have primary physical custody and Father shall have partial physical custody of the child according to the following schedule: a. Alternate weekends from Friday at 6:00 p.m. until Sunday at 4:00. b. In odd numbered years, Mother shall have the child from New Years Eve at noon through New Years Day at noon, Easter, Fourth of July, Thanksgiving, and Christmas Day at noon through December 26~h at noon. In odd numbered years, Father shall have the child Presidents Day weekend, Memorial Day weekend, Labor Day weekend and Christmas Eve at noon through Christmas Day at noon. The scheduled would be m~versed during even numbered years. The holiday weekends shall be defmod at Friday at 6:00 p.m. through Monday at 4:00 p.m. Arrangements for holiday times not defined herein shall be by agreement of the parties at least twenty-four (24) hours m advance. Father shall have the child on Father's birthday and Father's Day; Mother shall have the child on Mother's bWahday and Mother's Day. Father and Mother shall caeh have quality time with the child on the child's birthday. Times for partial custody on Mother's Day, Father's Day and birthdays shall be arranged by agreement of the parties at least twenty-four (24) hours m advance. If no agreement is reached in advance, the default holiday times, not otherwise defined herein, shall be from 9:00 a.m. to 7:00 p.m. Beginning when the child starts school, the parents will split the Christmas and spring school vacations with caeh parent having that portion of the school vacation that coincides most closely with the Christmas Day and Easter holidays as described herein. Both parents shall have up to four (4) weeks of custody time with the child during each calendar year with a maximum of two (2) weeks being consecutive. Notice of such times shall be communicated to the other parent at least thirty (30) days in advance. Unused vacation time shall not be carried over into the next calendar year. Other periods of partial custody may be arranged by agreement of the parties at least twenty-four (24) hours in advance. Pick up and drop off of the child for transfer of custody shall be at either the Shrewsbury exit on Route 1-83 orthe Reading exit (Exit 21) on the Pennsylvania Turnpike, the exact location to be communicated to Mother at least twenty-four (24) hours in advance. -2- As appropriate to the age of the child, each parent shall have liberal and reasonable mail and phone access to thc child while in the custody of the other parent. Otherwise, telephone contact between the parents concerning the child shall be reasonable and, except in emergencies, confined to the hours of 9:00 a.m. to 9:30 p.m. Each parent will keep the other advised at all times of their current address and phone number. Both parents shall provide an itinerary of any planned vacation with the child, including specific destinations, phone numbers, means of travel, departure and arrival times, to the other parent at least two (2) weeks prior to said vacation. Notice of any planned relocation out of the county of each parent's current residence shall be provided to the other parent at least sixty (60) days prior to the anticipated move, in writing by certified mail, to the other parent. The parents agree to cooperate with each other in the fullest in the upbringing of their child, and fuFdier agree to foster a good relationship between the child and the other parent and that parent's extended family. Mother and Father shall neither alienate nor attempt to alienate or destroy the affection of the Child for each other or any other person to whom the Child is related by blood or marriage, but shall instead exert every reasonable effort to foster a feeling of affection between the Child and each other or any other related person. The parents hereby confmn their intent and desire that m the event one of the parents dies before the child reaches his majority, the other parent shall have full guardianship of the child. In the event both parents die before the child reaches his majority, the parents hereby designate the maternal grandparents as guardians of the child, and, if they are unable or unwilling to -3- assume said guardianship, the parents hereby designate the paternal grandparents as guardians of the child. It is understood and agreed that the Cus~xly provisions of this Stipulation shall be presented by Mother to the Cumberland County Court of Common Pleas to be confirmed by Order of Court. CHILD SUPPORT 8. Father shall pay the sum of $400.00 per month for child support plus $500.00/month to reimburse Mother for child care costs mcan'ed during her hours of employment. /~ ....................... o .... Mother will prowde to Father recetpts for th,~ ohltd 10. Mother will provide medical and dental insurance for the childA Unrcimbursed medical and dental expenses, after the first $250.00 per calendar year to he borne by Mother, shall be divided between the parties, Father paying 80% and Mother paying 20% thereo£ It ~s understood and agreed that ~f Father fails to make child support payments as agreed berem, Mother may seek enforcement of tiffs agreement through her county's Domestic Relations J~S PA/TRICK RICI[IARDS, Father 8worn lo m',d ~ubs~b~d bef~e me hhis ..ff=..~ day ~ ~ ~t. ~o~ REN~E R. RIDOLFI, Mother NOTARIZED: ~ SEP 8'20D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY COURT DIVISION RENEER. RIDOLFI JAMES PATRICK RICHARDS IN CUSTODY ORDER AND NOW, to wit, this /~- dayof ~.~r b-v~ Stipulatio~ of the Parties, it is hereby ORDERED and DECREED as follows:: 1. ,2001, based upon the Mother and Father shall share~ioint legal custody of their minor child. Michael James Rid~i. Mother and Father shall have an affirmative obligation to consult with one another on major decisions affecting thc Child agreeing that the Child's best interest shall be their paramount concern. It is understood that joint legal custody includes the right of each parent to have access to all the Child's medical, dental and educational records and participate actively in the Child's life Mother shall have primary physical custody and Father shall have partial physical custody of the child according to the following schedule: a. Alternate weekends from Friday at 6:00 p.m. unti! Sunday at 4:00. b. In odd numbered years, Mother ~hall have the child from New Years Eve at noon through New Years Day at noon, Easter, Fourth of July, Thanksgiving~ and Christmas Day at noon through December 26~ at noon. In odd numbered years, Father shall have the child Presidents Day weekend, Memorial Day weckend, Labor Day weekend and Christmas Eve at noon through Christmas Day at noon. The scheduled would be reversed during ~ven numbered years. The holiday weekends shall be defined at Friday at 6:00 p.m. through Menday at 4:00 p.m. Anm~gements for holiday times not defined herein shall he by agreement of the parties at least twenty-four (24) hours in advance. c. Father shall have the child on Father's birthday and Father's Day; Mother shall have the child on Mother's birthday and Mother's Day. Father and Mother shall each have quality time with the child on the child's birthday. Times for pa~ial custody on Mother's Day, Father's Day and bi~hdays shall bo alTallged by agreement of the parties at least twenty- four (24) hours in advance. d. fine agreement is reached in advance, the default holiday times, not otherwise defined herein, shall be from 9:00 a.m. to 7:00 p.m. ¢. Bo~4~'nnitlg when tho child starts school, the parents will split the Christmas and spring school vacations with each parent having that portion of the school vacation that coincides most closely with the Christmas Day and Easter holidays ns described heroin. f. Both parents shall have up to four (4) weeks of custody time with the child during each calendar year with a maximum of two (2) weeks being consecutive. Notice of such times shall be communicated to the other parent at least thirty (30) days in advance. Unused v~ c~fion time shall not be carried over into the next calendar year. g. Other periods of paxtial custody may be alTange~d by agreement of the parties at least twenty-four (24) hours in advance. h. Pick up and drop off of the child for transfer of custody shall be at either the Shrewsbury exit on Route 1-83 or the Reading exit (Exit 21) on the Pennsylvania Turnpike, the exact location to be commumcated to Mother at least twenty-four (24) hours in advance. As approl~riate to the age of the child, each pment shall have liberal and reasonable mail and phone access to thc child while in the custody of the other parent. Otherwise, telephone ennta~t between the panmts concemin,~ the child shall be reasonable and, except in emergencies, co~ to thc hours of 9:00 a.m. to 9:30 p.m. Each parent will keep the other advised at all times of their c~ address and phone number. Both parents shall provide an itinerary of any planned vacation ~ the child, including specific destinations, phone numbers, means of travel, departure and arrival times, to the other parent at least two (2) weeks prior to said vacation. Notice of any planned relocation out of the county of each parent's entreat residence shall be provided to the other parent at least sixty (60) days prior to tho anticipated move, in writing by certified mail, to the other parent. The parents agree to cooperate with each other in the fullest in the upbringing of their child, and further agree to foster a good relationship between the child and the other parent and that parent's extended family. Mother and Father shall neither alien~t_e nor attempt to alienate or destroy the affection of the Child for each other or any other person to whom the Child is related by blood or marriage, but shall instead exert every reasonable effort to foster a feeling of affection between tho Child and each other or any other related person. In the event one of the parents dies before the child reaches his majority, the other parent shall have full guardianship of the child. In the event both parents die before the child reaches his majority, the parents have designated tho child's maternal grandparents as guardians of the child, and, ff they are unable or unwilling to assume said guardianship, the parents have desJ~nmt_,xl the child's paternal gra~ as guar, ti~,s of the child. BY THE COURT: STIPULATION FOR CUSTODY AND CHILD SUPPORT AND NOW, to wit, this ~"7/,/ day of ~ ~,-~ ,2001, it is Stipulated by and between JAMES PATRICK RICHARDS ("Father") and RENEER. RIDOLFI "Mother'~) that the parties to this Stipulation desir~ that their minor child, MICHAEL JAMES UDOLFI, bom March J, 2001 maintain a positive relationship with both of their parents, and to further this goal, and intending to be bound thereby, tbe parties agr~ az follows:: CUSTODY 1. Mother and Fath~ shall share joint legal custody of their minor child. Mother and Fath~ shall have an affirmative obligation to consult with one another on major decisions affecting the Child agreeing that the Child's best interest shall be their paramount concern. It is understood that joint legal custody includes the right of each parent to have access to all thc Child's medical, dental and ~ducational records and participate actively in tbe Child's ~ events. 2. Mother shall have prinuay physical custody and Father shall have partial physical custody of thc child accor&n~ to thc following scbedulc: a. Alternat~ wcc, kends from Friday at 6:00 p.m. until Sunday at 4:00. b.- In odd number~ y~ars, Mother shall have thc child from New Years Eve at noon through New Years Day at noon, Easter, Fourth of July, Thanksgiving, and Chri~t:~es Day at noon through Dec~nber 26~ at noon. In odd numbered years, Father shall have the child Presidents Day weck~nd, M~morial Day wcckond, Labor Day weekend and · Christmas Eve at noon through Christmns Day at noon. Thc scheduled would be reversed during ~ven numbs'ed years. ~ holiday wecke~is shall be defined at Friday at 6:00 p.m. through Monday at 4:00 p.m. Arrangements for holiday times not defined herein shall be by agreement ofth¢ parties at least twenty-four (24) hours in advance. Father shall have the child on Father's birthday and Father's Day; Mother shall have the child on Mother's birthday aad Mother's Day. Father and Mother shall each have quality time with the child on the child's birthday. Times for partial custody on Mother's Day, Father's Day and birthdays shall be arranged by agreement of the patties at least twenty-four (24) hours in advance. ffno agreement is reached in advance, the default holiday times, not otherwise defined herein, shall be from 9:00 a.m. to 7:00 p.m. Begirmln~ when the child starts school, the parents will split the Christm~* and spring school vacations with each parent having that portion of the school vacation that coincides most closely with the Christmas Day and Easter holidays as d~cribed herein. Both parents shall have up to four (4) weeks of custody time with the child during each calendar year with a maximum of two (2) weeks being consecutive. Notice of such times shall be con~nunicatod to the other parent at least thirty (30) days in advance. Unused vacation time shall not be carried over into the next calendar year. Other periods of partial custody may be arranged by agreement of the parties at least twenty-four (24) hours in advance. Pick up and drop off of the child for transfer of custody shall be at either the Shrewsbury exit on Route 1-83 ortho Reading exit (Exit 21) on the Ponnsylvania Turnpike, th~ ~,-act location to be communicated to Moff~r at least twenty-four (24) hours in advance. -2- o As appropriate to the age of th~ child, each parent shall have liberal and reasonable mail and phone access to the child while in the custody of the other parent. Otherwise, telephone contact between the parents gOOcerning the child shall be reasonable and, except in emergencies, confined to thc hours of 9:00 a.m. to 9:30 p.m. Each parent will k~?p thc other advised at all times of their cubic, al address and phone number. Both parents shall provide an itinerary of any planned vacation with the child, including specific destinations, phone numbers, means of travel, departure and amvai times, to the otber pan,~nt at least two (2) weeks prior to said vacation. Notice of any planned relocation out of the county of each parent's current residence shall be provided to the other parent at least sixty (60) days prior to the anticipated move, in writing by certified ma£1, to the otber parent. Thc parents agree to cooperate with each other in thc fullest in thc upbringing of their child, and further agree to foster a good relationship betwec~ the child and the other parent and that parent's ex-ten~ family. Mother and Father shall neither alienate nor attea~t to alienate or destroy the affection of the Child for each other or any other person to whom the Child is related by blood or marriage, but shall instead exert every reasonable effort to foster a feeling of affection between the Child and each other or any other related person. The parents hereby confirm their intent and desire that in the event one of the parents dies before the child reaches his majority, the other parent shall have full guardianship of the child. In the event both parents die before thc child reaches his majority, thc parents hereby designate the mutcmal grandparems ns guar~a,~ of the child, and, if they are unable or unwilling to -3- assume said guardianship, the parents hereby dc~iguatc thc paternal grandparents as guardians of the child. 7. It is unde~to~ and agreed th~ the Custody provisions of this Stipulation shall he present~l by Mother to the Cumberland County Cou~ of Common Pleas to he coufmned by Order of Court. CHILD SUPPORT Father shall pay the sum of $400.00 per month for child support plus $500.00/month to reimburse Mother for child care costs incurred during her hours of employment. ~,~/x ~ I0. Mother will provide medical and dental insurance for the childA Unreimborscd medical and ~ II. dental expenses, afl~r the first $250.00 per eaiendar year to he borne by Mo~,her, .~hall be divided between the parties, Father paying 80% and Mother paying 20% thereof. It is understood and agreed that if Father fails to make child support payments as agreed herein, Mother may seek cnforeemcnt of this agreement through her county's Domestic Relations ]A~rS PATRICK RIC~S, Father NOTARIZED: ~ NOTARIZED: O~rk E. flerry, Notary Public ~_~arrisbar g,Dauphin County RENEER. RIDOLFI, Plaintiff/Respondent JAMES PATRICK RICHARDS, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5610 - CiVIL ACTION - LAW IN CUSTODY PETITION OF JAMES PATRICK RICHARDS TO MODIFY CUSTODY AND NOW, comes the Defendant, James Patrick Richards, by and through his attorneys, MARTSON DEARDORFF WILLIAMS & OTTO and files this Petition as follows: 1. Defendant, James Patrick Richards (herinafter "Petitioner"), is an adult individual residing at 5752 Goldfinch Court, Ellicott City, MD 21043. 2. Plaintiff, Renee Ridolfi (hereinafter "Respondent"), is an adult individual residing at 32 Scansdale Drive, Camp Hill, PA 17011. 3. The parties are the parents of Michael James Ridolfi, (hereinafter "Michael") bom March 5, 2001. 4. On October 1, 2001, this Court entered an Order of Court granting shared legal custody of Michael between the parties, with Petitioner having partial physical custody, a copy of said Order is attached hereto and marked as Exhibit "A." 5. Petitioner has now become the primary custodian of Michael and is better able to raise Michael. WHEREFORE, Petitioner, James Patrick Richards, prays your Honorable Court to issue an Order amending the Order o f October 1,2001 wherein directing that he has primary physical custody of the child, Michael James Ridolfi, and Respondent, Renee Ridolfi, shall have partial physical custody as the parties may agree. The balance of the October 1,2001 Order would remain in effect. MARTSON DEARDORFF WILLIAMS & OTTO By '~~r~Es luV~ire~ t'''~'~' Thomas J. Willim{aJ q ' Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Defendant Date: April 29, 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, pF_,I~3 fLVANIA FAMILY COURT DIVISION /ENEE R. R1DOLFI : : : : AMES PATRICK RICHARDS : No. 0 t o 5'(,,/0 IN CUSTODY 5J ~ ,2001, based upcm the ow, Stipulation oftbe Paxties, it is he, ruby ORDEI~g,D and DECREED as follows:: 1. Moth~ and Fatber shall shar~ joint lethal custody of their minor child. Michael James Ridolfi. Mother and Fatlwr ahnll have an affirmative obligation to consult with one another on major decisimm affec~in_o lhe Child agresing that the Ckild's bestinterest shall be tbeir param°unt concern, it is underatood that joint legal custody iacludes the right of each parent to have access t° 2. Motber shah have primary physicul custody and Fatber shah have Pattiul physical custedY °f tbe child according to the following schedule: a. ~ weekends fxom Friday at 6:00 p.m..ntil Sullday at 4:00. In odd numbered years, Motber shall have the child frora New Years Eve at noon ~-ough New Years Day at noon, Easter, Fourth of July, Thanksgiving, and Cluistmas Day at noon Presidents Day weekend, Memorial Day weekend, Labor Day weelamd and Christmas Eve at noon thro-_oh Christmas Day at noon. The scheduled would be reversed during ~ven EXHIBIT "A" numbered years. Tho holiday weekends shall be defined at Friday at 6:00 P.m. Monday at 4:00 p.m. Amu~iiients for holiday times not deffaned herein shall be by agrcement ofthe parties at least tweaty-four (24) hours in advance. c. Fathor shall have the child on Fathor's birr_belay and Father's Day; Mother shall have the child on Mother's birthday and Mother's Day. Father and Mothor shall each have quality time with the child on the child's bitflvtay. Times for patlial custody on Mothor's Day, Father, s Day and birthdays shall be arranged by agreement of the partios at least twenty' four (24) hours in advance. d. if no agreement is reached in advonce, tl~ default holiday times, not otherwise defined hm~.~n, shall be from 9:00 a.m. to 7:00 P.m. school v~c~iens ~ oash panmt having that portion of fl~ school vacation that coinoid~ mo~t olos~ly with tho Chtialraas Day and East~ holidays as d~.a'ibed heroin. f. Both parents shall have up to four (4) w~e~ of oustody timo with tbe child dating esch calondat y~at with a maximum of two (2) w~ks b~g cons~ontiv~. Notice of such tim~ shall bo communicated to tho otl~r panmt at least flfirtY (30)days in advan~' Unused wcgien ~ shall not be carried over into tho ~ calendar year. g. Otbet pgrieds of partial custody may be an~n~d by agre~a~t of thc patties at least twenty-four (24) hours in advaace. h. Piok uP and dr°P°ff °fth~ ohild f°r transfer of enst°dy shall be at ~ifl~r tbe Slu~wsbuty ~it tm Rout~ 1-83 or tbe l~_~li~ ~ (Exit 21) on fl~ p~nylvaaia Turnpike, tbe gxa~t location to be corcmumicatod to Mothgr at lcest twenty-four (24) hours in advaa~. As apptoprint~ to tho age of the child, each paint shall have liberal and reasonable mail and phon~ acc, ess to thc child while in tho custody of thc other parent. Othcr~, telephone contact betwcea thc pareats coneaming thc child shall be reasonable and, excc~ in c~acrgc~ies, oonfined to the hours of 9:00 a.rm to 9:30 p.m. Each parent will keep tbe o~ advised at all tiraes of thoir gm'eat address and phone numbor. Both pareats shall provide an itinerary of any plaancd vacation with th~ child, including spocific destinatioas, phone numbers, means of travel, d~ and arrival times, to thc other parent at least two (2) weeks prior to said vacation. Notice of any planned relocation out of tho county of each paint's current residence shall be provided to tho other parent at least sixty (60) days prior to ~e anticipated move, in writin~ by ~-:~ed ~nnil~ to'ho ot]lor pan~t. Tho parents agrce to coopet~ ~ ~ ~ ~ ~ ~H~ in ~ u~°f~ child, ~ fut~d~er agrce to fostor a good rdation-~hip betweentbe chikl and tbe °thor parent and that parent's extended family. Mother and Father shall neither alienate nor attempt. ~o alionato or c~hoy tho affection of the Child for each othor or any other person to whom tho Child is relatecl bY bl°°d °r man~ge, but shall instoad exert every reasonable e~t'ort to fo.~r a feeling of aff~t~ botwee~ tho Child and each other or any other related person. In tho eveat one of tho parents dies before the child reaches his majority, tho other p~eat shall have full guardianship of the child. In th~ event both parents die before tho o~ild reacl~ his majority, the pareats have cl~ignated tho child's mammal ~andparents as gua~lians of l~e child, and, if ~ are unablo or unv~llin~ to assumo said ~uardianship, the parents have designated the child's pat 'nal grandpar as guantion oftl child. TRUE COPY FROM REC"'RD In Testimony whereof, I here un~o~:~t my henri BY THE COURT: STIPULATION FOR CUSTODY AND CHILI) SUPPORT AND NOW, to wit, this ;~-Z/~ dayof ~n,'g ,2001, it is Stipulated by and between JAMES PATRICK RICHARDS ("Father") and RENEER. RIDOLFI RIDOLFI, bom March 5, 2001 maintain a posi'dve relationship with bo~ of their parents, and to (~3JSTODY 1. Mol~r and Falh~ shall sha~ joint legal custody ~ their n6nor ct~ld. Mother and Fal~r shall that joint leffal custody includes the right of each parent to have access to all ~ Child's 2. Mother ~n have prln~y physical custody and Father shall have ~ physical custody of the child acco~in~ to ~c following schedule: a. -.~ tt,~at~ weekends fi-om Friday at 6:00 p.m. until S-nd~y at 4:00. ltu~ugh New Years Day at noon, ~asstc~, Fourl~ of July, Tl~mksgiving, and Christmas l~y at noon thrc~,~n December 26~ at noon. In odd numbmxl years, Father shall have the child Prcsicl~i~ Day weekend, Memorial Day weekend, Labor Day weekend and -1- at 6:00 pan. through Monday at 4:00 p.m. ~ for holiday times not tlefined herein shall be by agreemem ofthe partie~ at least twemy-four (24) honrs in advan~. Fatl~r shall have the child on Father's birthday and Father' s Day; Motho- sludl have fl~ c. hild on Mother's birthday ami Mothor's Day. Father and Mod~r shall each have quality time with the child on the child's bit.day. Times for pmfial custody co Mother's Day, Fathor's Day and bhthdays shall be arnmged by agreement of tho paaie~ at l~ast tw~y-~ (24) houri in advanco. he~in, shall I~ from 9:00 a.m. to 7:00 pan. Be~i~'nnln~ when the ckild starts school, tho parents will split the Christmas and spring coincides most closely with ~t~ Christmas Day and F. as~ holidays as d~scrib~d Both parrots ~ll have up to font (4) weeks of custody timo with tho child du_6ng each calcodar year with a maximum of two (2)woeks being consecutive. N6tico of such time~ shall bo commonica~d to ~t~ other parrot at l~ast thirty (30) days in advance. Other periods of partial costody may be arrangod by agroement of the parties at least twenty-four (24) hours in advance. Pick up and drop off of the child for trmsf~ of custody shall b~ at oi~h~r the Shrewsbury exit o~ Routo 1-83 or tho Reaa!n.~.~, ~,it (F. acit 21 ) on tha Pennsylvania Turnpike, the exact location to b~ communicated to Mother at least twenty-four (24) hours in advance. -2- between the penmts ~ the child shall be rca.sortable and, except in emerge~'ies, contrail to thc hours of 9:00 a.m. to 9:30 p.m. Each parent will 10rap thc other adviscd at all planned vacafico with the ,.~ld, incluai~2 specific destinations, phone numbers, means of tntvcl, dcpm-tm'c and an'i~ tim~, to tl~ ottacr lmrent at knst tw~ (2) weeks prior to said vacation. Notice of any planned relocation out of th~ county of each parent's current reaide~o shall bo provided to the olher paixat at least sixty (60) days p~ior to the an~icipa~l move, in writing by pamat ' s extended family. Moiler and Father shall neilher alienate nor 'n'~,p~ to alienate or rolated by blood or maniago, but shall instead e~xt every roascoablo effort to foster a feeling of affccgon between the Child at~d each o~-r or any other ~ person. -3- 7. It is understood ami agr~i ~ lhe Custody provisions of this Siipulation shsll b~ presented by CI1]LD SUPPORT Failer ~1~11 pay fl~ sum of $400.00 p~ momh ~r ~iid suppo~ plus $500.O0/mo~h to Mofl~a- may se~ eaforc~mmt of this agr~me~t through her county's ~C Relaticm NOTARIZF. D: ~ VERIFICATION The foregoing Modification of Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Petition to Modify was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: James K. Jones, Esquire 7 Irvine Row Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & ~OTTO ( ' n~-ncci'a;D. Eckenr'oad ' ~ East High Street Carlisle, PA 17013 (717) 243-3341 Dated: April 29, 2002 RENEER. RIDOLFI PLAINTIFF V. JAMES PATRICK RICHARDS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 01-5610 CIVIL ACTION LAW IN CUSTODY AND NOW, Wednesday, May 01, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, May 21, 2002 at 1:30 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 dc£me and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at thc conference 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/ ]acqueline M. Verney, Esq, ~ 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 ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATrORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 RENEER. RIDOLFI, Plaintiff/Respondent V. JAMES PATRICK RICHARDS, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-5610 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this ~.~' day of /,n/l~' ,2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated October 1,2001 shall remain in full force and effect except as modified as follows: 2. Paragraph 2 shall be replaced with the following: Father shall have primary physical custody and Mother shall have partial physical custody of the Child according to the following schedule. 3. Paragraph 6 is hereby deleted. 4. This Order of Court is entered pursuant to the agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc'~homas J. Williams, Esquire, Counsel fo~~er ~ss ? '~Ll'i~ ~~ ~ ~ . ~lames K. Jones, Esquire, Counsel for Mother c ~.o~,~0~ ~ II RENEER. RIDOLFI, Plaintiff/Respondent JAMES PATRICK RICHARDS, Defendant/Petitioner PRIOR JUDGE: Kevin A. Hess, J. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. : 2001-5610 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND 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: NAME Michael James Ridolfi DATE OF BIRTH CURRENTLY IN CUSTODY OF March 5, 2001 Father 2. A Conciliation Conference was held in this matter on May 21, 2002, with the following individuals in attendance: The Father, James Patrick Richards, with his counsel, Thomas J. Williams, Esquire and James K. Jones, Esquire for Mother who appeared following the conference. 3. A prior Order of Court, dated October 1,2001 was entered by the Honorable Kevin A. Hess, which provided for shared legal custody, Mother to have primary physical custody with Father having periods of partial physical custody on an alternating weekend schedule, holidays and vacations. 4. The parties agreed to the entry of an Order in the form as attached. Date ~eY, Esquirey~~ Custody Conciliator