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HomeMy WebLinkAbout96-00122 " o. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN A. SLOANE, Plaintiff . CIVIL ACTION - LAW . v. IN CUSTODY WILLIAM M. SLOANE, NO. 96- Oefendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULO 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. Court Administrator Fourth Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 NOTICIA Le han demandado a usted en la corte. si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted de be presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin ~ previo aviso 0 notificacion y por pedido en la peticion de demanda. sus propiendades 0 otros derechos cualguier queja 0 alivio que Usted puede perder dinero 0 importantes para usted. es LLEVE ESTA OEMANDAA UN ABOGAOO IMMEOIATAMENTE. SI NO TIENE ABOGAOO 0 SI NO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONAL 0 LLAME POR TELEFONO A LA OFICINA CUYA OIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR OONOE SE PUEOE CONSEGUIR ASISTENCIA LEGAL. Court Administrator Fourth Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 M chael J. nft,' Esqu re Attorney 10 No. 57976 11 West Pomfret Street, Suite 2 Carlisle, PA 17013 (717)249-5373 Attorney for Plaintiff 3. The Plaintiff seeks primary custody and visitation of the following child: ~ Present Residence &m 5 Sara M. Sloane 705 Wilson Street Carlisle, PA 17013 Date Of Birth of Child: June 8, 1990 The child was not born out of wedlock. The child is presently in the primary physical and legal custody of Plaintiff. In addition to the child's present address, during the past five years, the child has resided with either Plaintiff or Defendant at the following addresses: 104 Walnut Street, Boiling Springs, Cumberland County, Pennsylvania; and 26 Shepherd Road, Newville, Cumberland County, Pennsylvania. The mother of the child is the Plaintiff, who resides at 705 Wilson Street, Carlisle, Cumberland County, Pennsylvania. She is currently married to the Oefendant, but has filed for divorce from him. The father of the child is Oefendant, who resides at 26 Shepherd Road, Newville, Cumberland County, Pennsylvania. He is currently married to the Plaintiff, but she has filed for divorce from him. 4. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the child. 5. The relationship of the Defendant to the child is that of father. The Defendant currently reDideD alone. 6. Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this or any other court. The Plaintiff has no information of a cuotody proceeding concerning the custody of the child in this or any other court. The Plaintiff does not know or a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interests and permanent welfare of the child will be served best by granting the relief requested because: a) The Plaintiff has had primary or shared physical and legal custody of the child and hac beon the child's primary care giver since the child's birth; b) The Plaintiff provides the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; c) The Plaintiff is, and haD always been, willing to accept custody of the child; d) The Plaintiff continues to exercise primary parental duties and responsibilities and enjoys the love and affection of the child; <t. i~~ u 0 IL Ji ~. l' >- V:l ~ 0~O (~ I" -:J- .' t.-! 1IIt~: .. ;-k VI 0 (~ j r"fl - CJ("; r- r- IF,t: ......:: '-':.( :J If) {if rn ~~' !', ~j ':t' ,., ,( .!J": C> ". I.. ~ 1 1=1 '" ;-; ". ~ <(, u:.l" .- l ,u! i~J I.' . " l'!U~ <J -, ,,, If) ~j () (Jl lJ '. -, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN A. SLOANE, Plaintiff CIVIL ACTION - LAW v. IN CUSTOOY WILLIAM M. SLOANE, . NO. 96-122 . Defendant CBRTIFICATB OF BBRVICB AND NOW, this 25th day of January, 1996, I, Michael J. Hanft, Esquire, hereby certify that the following person was served with a True and Correct copy of the custody Complaint filed in the above-referenced matter. The Custody Complaint was mailed on January 17, 1996, but actual service took place on January 19, 1996 by Oefendant signing for a copy of the custody Complaint which was mailed in the United States Mail, Certified Mail--Return Receipt Requested, Restricted Oelivery, Postage Prepaid, addressed as follows: William M. Sloane 26 Shepard Road Newville, PA 17241 C'Mll<<-'t'lfllOY'&Ln"'14'CJ'Jlt>>av ~ A copy of the signed Oomestic Return Receipt is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof. Respectfully submitted, HANFT & VOHS M~ 2~tt~SqUire Attorney 10 No. 57976 11 West Pomfret street, Suite 2 Carlisle, PA 17013 (717) 249-5373 , C\WnrC\.!ll1IOYIILO.Ur/t\l'tlUIJ.V ..... co '0' f:; ." 1-; j;; .. :--j - fLlr! - (.I::: t~)i:- I ;'.J.1, ff;,' -.' ". ,.o::i ~:I f() ~;~;; "f' , C'l l.'....~ :'-';"111 . , L' It lJ t-L.. ~ ''::111. f-' '" I', VI !.j C- (., (.) i , , f. " .\ ... .. ,- co r:; [r; In i~~ :., UJ~~~ tr) ..#001. I L_; L2-- ,,) .,~ l'-~.' u... - :...:~ 114#"'.' ..:~:~ at:. ," 6r . '0 .';",' .:1~:. 10- i:'.':" li:' C:l , I.lil.) r.:; 1.J.i i'JC- ( u.. 1.1. I.J) ::.; U l,il (J " .. '" IN THE COURT OF COMMON PLEAS OF CUMBERLANO COUNTY, PENNSYLVANIA SUSAN A. SLOANE, Plaintiff CIVIL ACTION - LAW v. IN CUSTOO'l WILLIAM M. SLOANE, NO. 96-122 Defendant AGREEMENT THIS AGREEMENT, made this 7f&.. day of March 1996, by and between William M. Sloane, of North Newton Township, Cumberland County, Pennsylvania, party of the first part, hereinafter referred to as "Husband," and Susan A. Sloane, of the Borough of Carlisle, Cumberland County, Pennsylvania, party of the second part, hereinafter referred to as "Wife," or collectively referred to as "the Parties." WHEREAS, Husband and Wife desire to provide for the custody and support of their one child, Sara Marie Sloane, born in Carlisle, Cumberland County, Pennsylvania, on the 8th of June 1990, t,'lreinafter referred to as "Sara"; NOW, THEREFORE, the Parties, in consideration of the mutually made and to be kept promises set forth herein and for other good and valuable consideration, intending to Le legally bound and to legally bind their heirs, successors, assigns, and personal repreeentatives, do hereby covenant, promise and agree as follows: 1.1W11l.uc:IYM\Io"'III'hWII1~M '1'11"1l~ ...,,, 1 ... .. "" 1. The Parties agree to shared legal and physical custody of Sara. Except as provided hereinbelow, and unless otherwise agreed by the Parties, Wife shall have primary physical custody of Sara, subject to Husband's periods of custody and visitation. Neither Party shall move his or her residence from Cumberland County, PennsYlvania, without first giving sixty (60) days' notice to the other Party. At that time, either Party can petition the Court of Common Pleas of Cumberland County, Pennsylvania for modification of custody, if necessary. Each Party shall be ~esponsible for the day-to-day decisions while he or she has custody of Sara. Neither Party has the right to make a unilateral decision regarding medical treatment (other than emergency treatment). It is agreed between the Parties that any decisions regarding medical treatment (other than emergency treatment) to be rendered to Sara will be made jointly. Unless and until Wife objects, it is agreed Husband may take Sara once a month for a chiropractic examination, and if indicated an adjustment, at his own expense; Husband shall be entitled to receive any full or pattial reimbursements therefore from hl.s or Wife's insurance carrier. 2. Each party agrees to keep the other apprised of any and all matters relating to Sara's health, education, welfare, and activities. It is agreed by the Parties that if Sara is removed from Cumberland County, Pennsylvania for more than seven (7) l".wJ",...IItIl.YIAWI,""Il)~'.IIlJl""";."'I"lllJl'''''i.II 2 ... ., v consecutive days, the Party removing Sara shall provide the non- removing Party with a telephone number at which Sara can be called for emergency purposes only. The Parties agree that Sara shall be raised in the Trinitarian form of the Christian religion. Moreover, the Parties agree that as long as Sara so desires, either Party may have Sara confirmed at the church of which they are a member. If the Parties can not agree as to where Sara shall attend school, either Party may petition the Court to so detArmine. With regard to Sara's schooling, from kindergarten through twelfth grade, inclusive, mandatory school expenses such as registration fees, supplies, tuition and uniforms shall be shared equally by the Parties. 3. Unless otherwise agreed to by the Parties, the following custody/visitation schedule for Sara shall apply: a. W..kends. On alternating weekends, Husband shall have custody of Sara from Saturday at 10:00 a.m. until Sunday at 8:00 p.m. b. W..kday Ev.nings. Husband shall have custody or Sara two (2) week day evenings each week. A week day evening is defined to be Monday evening, Tuesday evening, Wednesday evening, and Thursday evening. Said custody shall begin at 5:00 p.m. and shall end at 8:00 p.m. Once a day is selected, it shall continue until otherwise agreed to by the Parties, If the Parties are ~''J.Ulfl.uctL'I.4V.'t' IIllUt'.lIlIAUI'n""lIl1t "H. 3 I. ..' ., ..; unable to agree as to which day or days, then the day or days shall be the first two weekday evenings that Husband is not teaching. c. Summer vacations. At Husband's sole discretion, Husband shall have custody of Sara for a maximum of three (3) noncontinuous weeks during Sara's summer vacation from school. Husband and Wife shall discuss and agree, by May 1 of each calendar year, as to which week or weeks Husband shall have custody of Sara. At Wife's sole discretion, Wife shall have custody of Sara for a maximum of three (3) noncontinuous weeks during Sara's summer vacation from school. Husband and Wife shall discuss and agree, by May 1 of each calendar year, as to which week or weeks Wife shall have custody of Sara. d. Holidays. i. Thanksgiving--The Parties agree to alternate custody of Sara on an annual basis for Thanksgiving. Husband shall have custody of Sara beginning at 6:00 p.m. on the Wednesday before Thanksgiving Oay, 1997 through 3:00 p.m. on Thanksgiving Oay, 1997 (hereinafter "Thanksgiving") and on Thanksgiving every odd year thereafter. Wife shall have custody of Sara on Thanksgiving, '1996 and on Thanksgiving every even year thereafter. ii. Christmas--The Parties agree to alternate custody of Sara on an annual basis for Christmas. Wife shall have custody of Sara from 6:00 p,m. Christmas Eve, 1997 through I '~Uo\.~' 1"'.."'h.Ill'JlU"M'Il"U'..lIl"";. 4 ", " " ,I 3:00 p.m. on Christmas Day, 1997 (hereinaftor "Christmas") and on Christmas every odd year thereafter. Husband shall have custody of Sara on Christmas, 1996 and on Christmas every even year thereafter. iii. other holidaY8. -The Parties agree to alternate custody of Sara on an annual basis for the fOllowing other holidays each year: New Year's Day, Martin Luther King Oay, Presidents' Oay, Easter, Memorial Oay, Sara's birthday, Independence Day, Labor Oay, Columbus Oay and Veterans' Day; with respect to this clause, a "Monday holiday" (holiday "observed") if any, is referred to, if it differs from the traditional date, and, in the case of a Friday or Monday holiday on which Sara does not have school, and which immediately precedes or immediately follows a weekend on which said Party has custody, then the Friday holiday shall include the night between Friday and the weekend, and the Monday holiday shall include the night between the weekend and Monday. Once a schedule is established for any particular holiday, custody of Sara shall alternate between Husband and Wife every year according to that same schedule. iv. Mi8oellan8ou8 holidaY8. a. The Parties hereto agree that they will cooperate and be as flexible as possible with regard to custody of Sara for any holiday or extended vacation period. In the event that any holiday discussed in this section or these Agreement falls on a weekend or evening visitation of the Party not having primary C\l.V1UAAlll'rIA.....'.''''llr..IIlMll.I.'II.UVAI.. 5 ~ " '. physical custody of sara, then the holiday schedule will take precedence over the normal custody schedule. b. Wife shall have custody of the Sara on every Mother's Oay from 8:00 p.m. the day before Mother's Day until 8:00 p.m. Mother's Day. Husband shall have custody of Sara on every Father's Oay from 8:00 p.m. the day before Father's Day until 8:00 p.m. Father's Day. The non-custodial parent shall have the right to spend up to two (2) hours of visitation with Sara on Sara's birthday, June 8th. Should the Parties not be able to reach an agreement as to what time, then it shall be from 6:00 p.m. until 8:00 p.m. c. Husband and Wife shall discuss and agree on a custody schedule for Sara at least two (2) weeks prior to any holiday not specifically mentioned in the Agreement. Once a schedule is established for any particular holiday not specifically discussed in this agreement, custody of Sara shall alternate between Husband and Wife every year according to that same schedule. d. It is the intent of the Parties that transportation of Sara between parents for all purposes, but especially custody purposes, shall be as flexible and accommodating as possible. For these purposes, the Parties agree to meet as close to half way as possible to accommodate the custody schedule. It is recognized that transportation will obviously be dependent upon each party's personal circumstances and employment. 1.\J04IlU.u.tUYI......ql!I'~I\."'lJi"-...I.I''!II''lIy...'.. 6 .' ~ e. The Parties may agree to modify this schedule without the necessity of a Court Order. It is specifically agreed between the Parties that visitation shall be as reasonable, liberal and frequent as possible. The periods outlined above are to take effect if the Parties can not agree as to a particular custody schedule. 4. Husband and Wife acknowledge their joint and individual obligation to contribute to the support of Sara. a. The Party not exercising primary physical custody of Sara shall pay child support for Sara pursuant to the child support guidelines (Pa.R.Civ.Pro. No. 1910.16-1, et sea., as amended) of the Commonwealth of Pennsylvania. The provisions of this Agreement concerning child support shall not be entered as a support order in any court unless and until the Obligor defaults in his or her obligation; then and only then may the provisions of this Agreement concerning child support be entered as a support order in the Court of Common Pleas of Cumberland County or other appropriate court. It is specifically agreed between the Parties that if they can not agree upon an amount of child support pursuant to the guidelines, either Party can submit the determination of a child support amount to the Domestic Relations Office for recalculation. Until the Parties 1995 Federal income taxes are calculated, for calendar year 1996, Husband shall pay child support to Wife in the amount of $633.15. No later than April 30th of each t"\MllU'AWllYIA""l..l'''lill\"J.W,\,.'W.'\I''I1YAI;Jl 7 ~ " J , year, the Parties wi 11 exchange income information (including copies of their respective W-2 or 1099 forms) so that they may be able to compute the appropriate child support payments that would be due (for the ensuing twelve month period) based upon the Child Support Guidelines then in place for the Commonwealth of Pennsylvania. In addition to the basic child support, the amount paid by Ob1.igor shall be increased 130 as to account for the Obligor's share of child-care expenses and mandatory school expenses paid during the month, and unreimbursed medical expenses which the insurance carrier has declined to cover during the month, which share shall be in addition to the basic child support amount. If the Parties can not agree upon the figures to be used in re-calculating an amount or the amount to be paid by Obligor, either Party may petition the Oomestic Relations Office for a calculation of the appropriate child support amount. b. Child support shall continue for Sara until she reaches eighteen (18) years of age or continues to be actively enrolled in high school, whichever occurs later. c. The Party not exercising primary physical custody of Sara (the Obligor) agrees to transmit to the Party exercising primary physical custody of Sara any and all support payments by the fifth (5th) day of each month. For purposes of this Agreement, payments shall be deemed transmitted if they are personally delivered or placed in the United States Mail, first class mail, postage prepaid, on or before the fifth (5th) day of each month. ~"NlHI,,-..ItU I~".. nh'h\'~I"JI!.1 "'1I"llt ~1;1I B .. .... d. The Parties hereby agree that as long as there is no cost involved, both Husband and Wife shall carry Sara on their respective health insurance coverage as long as Sara is eligible for said coverage. If and when health insurance becomes an out of pocket expense for either Party, the Parties will equally share the costs of providing Sara with the same coverage as the Commonwealth of Pennsylvania provides to its employees. e. The Parties agree that they will equally share in any unreimbursed medical expenses incurred for the care of Sara pursuant to subsection (d) above. f. The Parties agree to equally share all costs of' child care paid for by the Party exercising primary custody of Sara for purposes of maintaining his or her employment. As of the date of this Agreement, any babysitter, governess or nanny, who may by law be deemed to be an "employee" shall be solely the employee of the Party having primary physical custody, notwithstanding the fact that the other Party may contribute to his or her compensation. 5. If and when the Parties begin filing separate income tax returns, it is agreed that the Party having primary physical custody for a majority of a particular calendar year may claim Sara as his or her dependent for that particular income tax year. !'MJl/ I -'\Ill, IA~.~''1lf1llr''l ''''''''''"_WU'r All' 9 . . . J IN WITNESS WHEREOF, the Parties have set their hands and seals the day and year first above written. WITNESSEO BY: 4w tj/7{f~AJfiuv,td lMJVJL ikrt ~"~/! h{~/\~n~AL) W 11 am M ./ Sloane - ". !/~ 'lU.Al...AA\- . '.u.+JL C;usan A. Slo (SEAL) l'\MIlr..oOlItYI,U,".n:nnU\'.llflAAI'Cnll41"At" 10 01: 7} F!LED'{)FFlC" ~'. . ,'" ,r. l'~t'r C . " . ''.'. 'T!n)' Qo~ .""',, .. '" '" II ['" A . - ,', j' /.' '. ., ./ CUA.,.:!~j ~L. '. .,,'" f'~NNs)i\~~'';;;'" '. IY . I -JJ~ '1/d/!'/ l:>> fiI.(. Otl @/j'IJ/~'~':!' "':'vt.f:t-tr.l/ r ,:}.I' rt- /ltI-t~_ /H:l.~t:I'-&' a;J. Ij,~ 11' .)1.) '1b~ ~}Py piJ"t:/',~" :4 ..xj[{.~r i11.h Court, signed by Hess, J., on May 14, 1996, and indexed to No. 96-122. A copy of said Order is attached hereto, and marked Exhibit "A". 7. Subsequent to the entry of said Order, Respondent for the first time asked Petitioner to ~ign an Affidavit of Consent relative to the no-fault divorce that she is seeking, and Petitioner refused to do so. 8. Since Respondent has learned that Petitioner does not consent to a no-fault divorce, Respondent has refused to allow Petitioner to exercise his periods of custody and visitation as provided for in the Custody Order. Specifically, she has not allowed him to exercise his overnight visitation (Order, page 3, paragraph 3.a.); she has not allowed him to take the child on summer vacation (Order, page 4, Paragraph 3,c.); and she has denied him "reasonable, liberal and frequent" visitation (Order, page 7, paragraph 3.e.). This is particularly frustrating for Petitioner in that Respondeont has nonetheless allowed the child to be kept overnight in the care of third parties, including unrelated babysitters and the maternal grandparents, all to the exclusion of Petitioner, the natural father. 9. It is respectfully averred that the minor child would benefit from spending additional periods of time with the father, including overnight and summer vacation periOds, as provided for in the Custody Order, 10, It is averred that the Respondent is acting in bad faith, in retaliation for Petitionor's refusal to sign an Affidavit of consent, and in an effort to coerce him to do so. It is respectfully submitted that Respondent is acting in a vindictive and vengeful manner, in accordance with her selfish and narrow self-interests, as opposed to the best interests of the subject minor child, WHEREFORE, Petitioner respectfully requests this Honorable Court schedule a hearing relative to the contempt of the Respondent, and thereafter award him enforcement of the rights of custody and visitation as provided for in the Custody Order. Mark T. Silliker, Esquire Attorney for Petitioner PA Supreme Court 1.0. No.33671 204 state street Harrisburg, PA 17101 (717) 233-1000 / IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN A. SLOANE, . . Plaintiff . . . CIVIL ACTION - LAW . v. : IN CUSTODY . . WILLIAM M. SLOANE, NO. 96-122 Oefendant . . ORDER AND NOW, this ,)J/. 1'1' day of May, 1996, upon agreement of the Parties, the Custody Agreement dated March 29, ~996, a copy of which is attached hereto as Exhibit "A", is hereby incorporated as a custody Order. BY THE COURT, /s/ J61.4-:~ t/, c#..:1<? J. " r , f. , .' 0" , . , ,,, '0' e....,."AWLY-LA~..'fJONl..IWroTnlDl...Wftl . . ..) I 0.. ._ ., " :.;1 :'~I : :;1 " I ';,.q I ", ---.. -, II ,I,.. 1. The Parties agree to shared legal and ~Iysical custody of Sara. Except as provided hereinbelow, and unless otherwise agreed by the Parties, IHfe shall have primary physical custody of Sara, subject to Husband's periods of custody and visitation. Neither Party shall move his or her residence from "1; I Cumberland County, Pennsylvania, without first giving sixty (60) days" notice to the other Party. At that time, either Party can petition the Court of Common Pleas of Cumberland County, Pennsylvania for modification of custody, if necessary. Each Party shall be responsible for the day-to-day decisions while he or she has custody of Sara. Neither Party has the right to make a unilateral decision regarding medical treatment (other than emergency treatment). It is agreed between the Parties that any decisions regarding medical treatment (other than emergency treatment) to be rendered to Sara ~lill be made jointly. Unless and until Wife objects, it is agreed Husband may take Sara once a month for a chiropractic examination, and if indicated an adjustment, at his own expense; Husband shall be entitled to receive any full or pa~tial reimbuzsements therefore from h~s or Wif~s insurance carrier. ;. 10, " 2. Each party agrees to keep the other apprised of any and all matters relating to Sara's health, education, welfare, and activities. It is agreed by the Parties that if Sara is removed ,/ ., from Cumberland County, Pennsylvania for more than seven (7) I, h f: r\Wlf',,"Il. IA.......'.1111n"'III"'....II.\IUI" ".." 2 1,1 . " I , I consecutive dayo, the Party removing Sara nha lJ. provide the non- removing Party with a telephone Ilumbm- ilt \~hich Sara call be called for emergency purposes only. 'l'he Parties agree that Sara shall be raiDud in the Trinitarian form of the Christian religion, Moreover, the Parties agree that as long as Sara so deoires, either Party may have Sara confirmed at the church of \oIhich they are a member. If the Parties can not agree as to where Sara shall attend school, either Party may petition the Court to 00 determine. With regard to Sara's schooling, from kindergarten through twelfth grade, inclusive, mandatory school expenses such as registration fees, supplies, tuition and uniforms shall be shared equally by the Parties. 3. Unless otherwise agreed to by the Parties, the follo\dng custody/visitation schedule for Sara shall apply: a. Weekends. On alternating weekends, Husband shall have custody of Sara from Saturday at 10:00 a.m. until Sunday at 8:00 p.m. b. Weekday Ev~nings. Husband shall have custody or Sara two (2) week' day evenings each week. A week day evening is def ined to be Monday evening, Tuesday evening, \~ednesday evening, and Thursday evening. Said custody shall begin at 5:00 p.m. and shall end at 8:00 p.m. Once a day is selected, it shall continue until otherwise agreed to by the Parties, If the Parties are (""'*1lfluaa."LA"''IE'1'lom.~IO,,"''I'tl:'lllll'''''I.. 3 ,/ unable to agree as to which day or days, then tho day or daYG shall be the first two weekday evenings that HUliband ili not teaching. c. summer vacations. At Husband's sole discretion, Husband shall have custody of Sara for a maximum of three (3) noncontinuous weeks during Sara's summer vacation from school. Husband and IHfe shall discuss and agree, by Hay 1 of each calendar year, as to which week or weeks Husband shall have custody of Sara. At Wife's sole discretion, Wife shall have custody of Sara for a maximum of three (3) noncontinuouG ~lCeks during Sara's summer vacation from school. Husband and IHfe shall discuss and agree, by May 1 of each calendar year, as to which week or weeks Wife shall have custody of Sara. d. Holidays. i. Thanksqiving--The Parties agree to alternate custody of Sara on an annual basis for Thanksgiving. Husband shall have custody of Sara beginning at 6:00 p.m. on the Wednesday before Thanksgiving Oay, 1997 through 3:00 p.m. on Thanksgiving Oay, 1997 (hereinafter "Thanksgiving") and on Thanksgiving every odd y~ar thereafter. Wife shall have custody of Sara on 'l'hanksgiving,' 1996 and on 'l'hanksgiving every even year thereafter. ii. Christmas--The Parties agree to alternate custody of Sara on an annual basis for Christmas. I~ife shall have custody of Sara from 6:00 p.m. Christmas Eve, 1997 through CIloUl""\&A.YU...."IllllIUCI"'lllA.Nl..."'IOO'..I;. -l .,/ 3:00 p.m. on Christmas Day, 1997 (hereinafter "Christmas") and on Christmas every odd year thereafter. Husband shall have custody of Sara on Christmas, 1996 and on Christmas every even year thereafter. iii. other holidays. -The Parties agree to alt:ernate custody of Sara on an annual basis for the following other holidays each year: New Year's Oay, Hartin Luther King Day, Presidents' Day, Easter, Memorial Day, Sara's birthday, Independence Day, Labor Oay, Columbus Oay and Veterans' Oay; with respect to this clause, a "Monday holiday" (holiday "observed") if any, is referred to, if it differs from the traditional date, and, in the case of a Friday or Monday holiday on which Sara does not have school, and which immediately precedes or immediately follows a weekend on which said Party has custody, then the Friday holiday shall include the night between Friday and the weekend, and the Monday holiday shall include the night between the weekend and Monday. Once a schedule is established for any particular holiday, custody of Sara shall alternate between Husband and Wife every year according to that same schedule. iv. Miscellaneous holidays. a. ,~he Parties hereto agree that they will cooperate and be as flexible as possible with regard to custody of Sara for any holiday or extended vacation period. In the event that any holiday discussed in this section or these Agreement falls on a weekend or evening visitation of the Party not having primary C UoUlr,,,,\Q." LA.........'..1UIlNUM....'T(lI1fIIUY...c.a 5 I I i physical custody of Sara, then the holiday Gchedule Idll take precedence over the normal CUGtody schedule. b. Wife shall have custody of the Sara 011 every Mother's Day from 8:00 p.m. tho day before Mother's lJay until 8:00 p.m. Mother's Oay. Husband shall have custody of Sara on every Father's Oay from 8:00 p.m. the day before Father's Day until 8: 00 p. m. Father's lJay. 'rhe non-custodial parent shall have the right to spend up to two (2) hours of visitation with Sara on Sara's birthday, June 8th. Should the Parties not be able to reach an agreement as to what time, then it shall be from 6:00 p.m. until 8:00 p.m. c. Husband and Wife shall discuss and agree on a custody schedule for Sara at least two (2) weeks prior to any holiday not specifically mentioned in the Agreement. Once a schedule is established f9r any particular holiday not specifically discussed in this agreement, custody of Sara shall alternate between Husband and Wife every year according to that same schedule. d. It is the intent of the Parties that transportation of Sara between parents for all purposes, but especially custody pUrposes, shall be as flexible and accommodating as possible. For these purposes, the Parties agree to meet as close to half way as possible to accommodate the custody schedule. It is recognized that transportation will obviously be dependent upon each party's personal circumstances and employment. t>M."~ "1...1t'I"hlll\"IlUl.\.~..''lIIOU' ,Mol 6 /:' :~ . , ,I e. 'l'he Parties may agree to modify thin nchedule without the necessity of a Court Order. It in specifically " agreed between the Parties that visitation shall be as reasonable, liberal and frequent as possible. The periods outlined nbove are to take effect if the Parties can not agree as to a particular custody schedule, 4. Husband and Wife acknowledge their joint and individual obligation to contribute to the support of Sara. a. The Party not exercising primary physical custody of Sara shall pay child support for Sara pursuant to the child support guidelines (Pa.R.Civ.Pro. No. 1910.16-1, et sea., as amended) of the Commonwealth of Pennsylvania. The provisions of this Agreement concerning child support shall not be entered as a support order in any court unless and until the Obligor defaults in his or her obligation; then and only then may the provisions of this Agreement concerning child support be entered as a support order in the Court of Common Pleas of Cumberland County or other appropriate court. It is specifically agreed between the Parties that if they can not agree upon an amount of child support pursuant to the guidelines, either Party can submit the determination of a child support amount to the Domestic Relations Office for recalculation. Until the Parties 1995 Federal income taxes are calculated, for calendar year 1996, Husband shall pay child support to Wife in the amount of $633.15. No later than April 30th of each C \\UlrlA.\Cl.., IA"''''l.lIIlIlCn-.allM.\r.."l,.INI'I',v", 7 / / , year, the Parties will exchange incollle in(ol'luation (Jncluding copies of their respective W-2 or 1099 [orms) so that: they may be able to COlllpute the appropriate child support payments that would be due (for the ensuing twelve month period) based upon the Child Support Guidelines then in place for the Comlllonwealth of Pennsylvania. In addition to the basic child support, the amount paid by Obligor shall be increased so as to account: for the Obligor's share of child-care expenses and mandatory school expenses p<;lid during the month, and unreimbursed medical expenses which the insurance carrier has declined to cover during the month, which share shall be in addition to the basic child support amount. If the Parties can not agree upon the figures to be used in re-calculating an amount or the amount to be paid by Obligor, either Party may petition the Domestic Relations Office for a calculation of the appropriate child support amount. b. Child support shall continue for Sara until she reaches eighteen (18) years of age or continues to be actively enrolled in high school, whichever occurs later. c. The Party not exercising primary physical custody of Sara (the Obligor) agrees to transmit to the Party exercising primary physical custody of Sara any and all support payments by the fifth (5th) day of each month. For purposes of this Agreement, payments shall be deemed transmitted if they are personally delivered or placed in the United states Mail, first class mail, postage prepaid, on or before the fifth (5th) day of each month. C'~':I\,\G,"lAW\C\"1I1111\l1w.:'LIl.V11utl'l\n.. B "' ... -.. I d. The Parties hereby agree that ao long as there is no cost involved, both Husband and Wife shall carry Sara on their respective health insurance coverage as long as Sara is eligible for said coverage. If and when health insurance becomes an out of pocket expense for either Party, the Parties will equally share the costs of providing Sara with the same coverage as the Commonwealth of Pennsylvania provides to its employees. e. The Parties agree that they will equally share in any unreimbursed medical expenses incurred for the care of Sara pursuant to subsection (d) above. f. The Parties agree to equally share all costs of child care paid for by the Party exercising primary custody of Sara for purposes of maintaining his or her employment. As of the date of this Agreement, any babysitter, governess or nanny , who may by law be deemed to be an "employee" shall be solely the employee of the Party having primary physical custody, notwithstanding the fact that the other Party may contribute to his or her compensation. 5. If and when the Parties begin filing separate income tax returns, it is agreed that the Party having primary physical custody for a majority of a particular calendar year may claim Sara as his or her dependent for that particular income tax year. C'IoIIH"IC.'IA\I'Illll1Jll'l"AIIIAJoI"""ILlII'l'''li. 9 DC 1 1 U i996 .~,r-' SUSAN A. SLOANE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 96 - 122 CIVIL TERM CIVIL ACTION - CUSTODY v. WILLIAN M. SLOANE, Defendant COURT ORDER AND NOW, this II. day of Oc.h ~ consideration of the attached Custody Conciliation ordered and directed as follows: , 1996, upon Report, it is 1. This Court's prior Order of May 14, 1996 which incorporated a Custody Agreement between the parties, is modified as follows: A. Father's periods of alternating weekend temporary custody as set forth in Paragraph 3.a. of the Custody Agreement shall be modified such that Father shall return the minor child to the Mother's custody on Sunday evening at 7:00 p.m. instead of 8:00 p.m. 2. Upon agreement of the Father, Father's Petition for Contempt is withdrawn. 3. This Order is entered pursuant to an agreement reached by the parties at a custody conciliation conference. In the event either party desires to modify the existing Court Order, that party may petition the Court to have the case again scheduled for a conference with the Custody Conciliator. By the Court, cc: Mark T. William . A,jJ. Hess, J. Silliker, Esquire , , C. Vohs, Esquire ~ 1~ IOIIY/f' -..~ . . r, . ! '. , . , (", I, i.l<. "~, , .. L; I, '\" ";:1 L.', I.\!i ,i I - SUSAN A. SLOANE, Plaintiff : : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW . . v. . . WILLIAH M. SLOANE, Defendant : : : : CIVIL ACTION - CUSTODY NO. 96 - 122 CIVIL TERM PRIOR JUDGE: HONORABLE KEVIN A. HESS CONCILIATION CONFERENCE SUMMARY REPOBX. IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(bj, the undersigned Custody Conciliator submits the following report: 1. The information pertaining to the child who is subject of this litigation is as follows: Sara Harie Sloane, born June 8, 1990 2. A Conciliation Conference was held on October 3, 1996. Present were the Mother, Susan A. Sloane, with her counsel, William A. Vohs, Esquire, and the Father, William H. Sloane, with his counsel, Mark Silliker, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. loWqv Date SUSAN A. SI,OANE, Pelltlonu : IN ......: COUR'" OF COMMON PU:AS OF : CUMD.:RLANU COUN"'Y, P.:NNS\'I, VANIA v. CIVil, ACTION -I,AW WIU.lMI M. SLOANE, Respondent NO. 96 122 CIVil, "'ERM IN CUS"'OJ)Y ORUER m:: eOlIRT ANIl NOW, this \ S' dllY uf -.'l LJ \~_, 1997, upun cunsidemtiou of the auaehed pelition. it is herehy directed Ihat the purties Ilnd their respective counsel appear before DAWN S, ,UNDA Y, Esquire, Ihe concilialor, at 39 WEST MAIN ST, MECIIANICSBURG, on the ..a... day of I "\~ , 1997, lIt1.L:lli:i\. M. 1l1r 1I Pre.ltearing Custody CunfefCnce, AI such cunlcrence, an effurt will be made tu resulve the issues in dispute; or if this cannol he accomplished. to deline and narrow the issucs 10 bc hCllrd by Ihc Court and 10 calcr inlo a Icmpumry ordcr, All childrcallgc live or older may also be prcscnt althc eonlcrencc, Failurc 10 appcar allhis conlcrcace may provide grounds lilr entry of a tcmpumry ur pennaacnt urder, By thc Cuurt. By: YOU SIIOULU TAKE TillS PAPER TO YOUR I.A WYER AT ONn:. IF YOU UO NOT IIAVE A LAWYER OR CANNOT A....ORIl ONE, GO TO OR n:U:PIION.: ...IIE Of'...C.: S.:T .'OR1'1I DEI,OW ...0 "'NU OU'I' W"':RE YOU CAN m:T U:GAI. IIEI.P, Court Administmlor Cumbcrland Cuunly Courthousc I Courthuuse Squure, 4th Floor Carlisle, Pcnnsylvania 17013 (717) 240-6200 AI\Jf;RICANS WI'I'III)ISADlUTlES ACTO.' 1990 The Cuurt of Common Pleas uf Cnlllberland Cuunty is required by law 10 comply wilh thc Americans with Disabilitics Act of 1990, For inlilrtnatiun abuul uccessiblc facililies und reusonuhle aeeomlllodlllions nvailable tu disabled individullls having business befilre Ihe CUUrt, plcase contuctour uflice, AllalTllngclllcnls IIlUsl be Illllde lit lellst 72 hours priur to any hcaring or busincss before the cuurt. You IIlUS! atlcnd thc schedulcd conlcfCnce or hellring, or: i: ,~LfJ?-ofFICE , ,)" <'\\IJT/:Ry 97.//1/. , 7 PH 3: 3~ CUI.Fi-" , P- .......\" ' "'1\' ENN~J'rL(:\\~("TY '1 /}. ~? cj-,,-I'- drf//,;,AY0_ ,;>~, ~~..6~1 .l~Z Aa;~ ..:.... /-;'7 ''I;> /~~. ~M'jf!/:t ~4 ~c~,,~ t. /'1/ .97 ~,PI -'ma..t!/ ~t. d..c:{,~.".e' / IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN A. SLOANE, . . Plaintiff . . CIVIL ACTION - LAW v. IN CUSTOOY . . WILLIAM M. SLOANE, NO. 96-122 Oefendant ORDER ANO NOW, this /t/I'day of May, 1996, upon agreement of the Parties, the custody Agreement dated March 29, 1996, a copy of which is attached hereto as Exhibit "A", is hereby incorporated as a custody Order. BY THE COURT, /5/ ~/A.:~ (/. '74'-..u? J. I, , , ", -, I, ',. . ..~ I .' I . :1 " . ~,;J ....., : :;? ""-'1 ';nl .' '. ". ',. :-. r .. " . ." '. " , Co, ., c:...........'.u.wa.nm~wro 1/ ,. " .' 1. The Parties agree to shared legal and physical custody of Sara. Except as provided hereinbelow, and unless otherwise agreed by the Parties, Wife shall have primary physical custody of Sara, subject to Husband's periods of custody and visitation. Neither Party shall move his or her residence from Cumberland County, Pennsylvania, without first giving sixty (60) days" notice to the other Party. At that time, either Party can p'etition the Court of Common Pleas of Cumberland County, Pennsylvania for modification of custody, if necessary. Each Party shall be responsible for the day-to-day decisions while he or she has custody of Sara. Neither Party has the right to make a unilateral decision regarding medical treatment (other than emergency treatment). It is agreed between the Parties that any decisions regarding medical treatment (other than emergency treatment) to be rendered to Sara will be made jointly. Unless and until Wife objects, it is agreed Husband may take Sara once a month for a chiropractic examination, and if indicated an adjustment, at his' own expense; Husband shall be entitled to receive any full or pat,tial reimbuIsements therefore from hl.s or ..... Wife's insurance carrier. 2. Each party agrees to keep the other apprised of any and all matters relating to Sara's health, education, welfare, and activities. It is agreed by the Parties that if Sara is removed from Cumberland County, Pennsylvania for more than seven (7) C' ."....,,"'.....' .",..-a ""n'....~II'O':;.."U.,uu, AUII 2 I / , . consecutive days, the Party removing Sara shall provide the non- removing Party with a telephone number at which Sara can be called for emergency purposes only. The Parties agree that Sara shall be raised in the Trinitarian form of the Christian religion. Moreover, the Parties agree that as long as Sara so desires, either Party may have Sara confirmed at the church of which they are a member. If the Parties can not agree as to where Sara shall attend school, either Party may petition the Court to so determine. with regard to Sara's schooling, from kindergarten through twelfth grade, inclusive, mandatory school expenses such as registration fees, supplies, tuition and uniforms shall be shared equally by the Parties. 3. Unless otherwise agreed to by the Parties, the following custody/visitation schedule for Sara shall apply: a. Weekends. On alternating weekends, Husband shall have custody of Sara from Saturday at 10:00 a.m. until Sunday at 8:00 p.m. b. Weekday Ev~nings. Husband shall have custody' or Sara two (2) week' day evenings each week. A week day evening is defined to be Monday evening, Tuesday evening, Wednesday evening, and Thursday evening. Said custody shall begin at 5:00 p.m. and shall end at 8:00 p.m. Once a day is selected, it shall continue until otherwise agreed to by the Parties. If the Parties are C' .......'rA.l4.'I' LAIIl'a "OO"'LO.-.'rC:\.:\IOUY"'ca 3 ./ unable to agree as to which day or days, then the ~ay or days shall be the first two weekday evenings that Husband is not teaching. c. Bummer vacations. At Husband's sole discretion, Husband shall have custody of Sara for a maximum of three (3) noncontinuous weeks during Sara's summer vacation from school. Husband and Wife shall discuss and agree, by May 1 of each calendar year, as to which week or weeks Husband shall have custody of Sara. At Wife's sole discretion, Wife shall have custody of Sara for a maximum of three (3) noncontinuous weeks during Sara's summer vacation from school. Husband and Wife shall discuss and agree, by May 1 of each calendar year, as to which week or weeks Wife shall have custody of Sara. d. Holidays. i. Thanksgiving--The Parties agree to alternate custody of Sara on an annual basis for Thanksgiving. Husband shall have custody of Sara beginning at 6:00 p.m. on the Wednesday before Thanksgiving Oay, 1997 through 3:00 p.m. on Thanksgiving Day, 1997 (hereinafter "Thanksgiving") and on Thanksgiving every odd y~ar thereafter. Wife shall have custody of Sara on Thanksgiving, '1996 and on Thanksgiving every even year thereafter. ii. Christmas--The Parties agree to alternate custody of Sara on an annual basis for Christmas. Wife shall have custody of Sara from 6:00 p.m. Christmas Eve, 1997 through C' \NIIf'....~., LA..~'..IODrUr\ANL..-U\IODY "'1;. 4 / " 3:00 p.m. on Christmas Day, 1997 (hereinafter "Christmas") and on Christmas every odd year thereafter. Husband shall have custody of Sara on Christmas, 1996 and on Christmas every even year thereafter. iii. other holidays. -The Parties agree to alternate custody of Sara on an annual oasis for the following other holidays each year: New Year's Oay, Martin Luther King Oay, Pre,sidents' Day, Easter, Memorial Oay, Sara's birthday, Independence Day, Labor Day, Columbus Day and Veterans' Oay; with respect to this clause, a "Monday holiday" (holiday "observed") if any, is referred to, if it differs from the traditional date, and, in the case of a Friday or Monday holiday on which Sara does not have school, and which immediately precedes or immediately follows a weekend on which said Party has custody, then the Friday holiday shall include the night between Friday and the weekend, and the Monday holiday shall include the night between the weekend and Monday. Once a schedule is established for any particular holiday, custody of Sara shall alternate between Husband and Wife every year according to that same schedule. iv. ,Miscellaneous holidays. a. ,~he Parties hereto agree that they will cooperate and be as flexible as possible with regard to custody of Sara for any holiday or extended vacation period. In the event that any holiday discussed in this section or these Agreement falls on a weekend or evening visitation of the Party not having primary c \IoUIu.uc. 'I' "'-'lC\'11nu1'\llO.\MVV,,"ur "'loA 5 '/:Y5'C'1 " I custody of Sara, then the holiday schedule will' taka precedence over the normal custody schedule. b. Wife shall have custody of the Sara on every Mother's Oay from 8:00 p.m. the day before Mother's Day until 8:00 p.m. Mother's Oay. Husband shall have custody of Sara on every Father's Day from 8:00 p,m. the day before Father's Day until 8:00 p.m. Father's Day. The non-custodial parent shall have the right to spend up to two (2) hours of visitation with Sara on Sara's birthday, June 8th. Should the Parties not be able to reach an agreement as to what time, then it shall be from 6:00 p.m. until 8:00 p.m. c. Husband and Wife shall discuss and agree on a custody schedule for Sara at least two (2) weeks prior to any holiday not specifically mentioned in the Agreement. Once a schedule is established fpr any particular holiday not specifically discussed in this agreement, custody of Sara shall alternate between Husband and Wife every year according to that same schedule. d. It is the intent of the Parties that transportation of Sara between parents for all purposes, but especially custody purposes, shall be as flexible and accommodating as possible. For these purposes, the Parties agree to meet as close to half way as possible to accommodate the custody schedule. It is recognized that transportation will obviously be dependent upon each party's personal circumstances and employment. C \MIll ,.wa.y 'All't'\ 1hMlrwuM.__"n_ fOUY ~l" 6 .-' '\ /", .\ , { :1 e. The Parties may agree to modify this schedule without the necessity of a Court Order. It is specifically agreed between the Parties that visitation shall be as reasonable, liberal and frequent as possible. The periods outlined above are to take effect if the Parties can not agree as to a particular custody schedule. 4. Husband and Wife acknowledge their joint and individual obligation to contribute to the support of Sara. a. The Party not exercising primary physical custody of Sara shall pay child support for Sara pursuant to the child support guidelines (Pa.R.Civ.Pro. No. 1910.16-1, et sea., as amended) of the Commonwealth of Pennsylvania. The provisions of this Agreement concerning child support shall not be entered as a support order in any court unless and until the Obligor defaults in his or her obligation; then and only then may the provisions of this Agreement concerning child support be entered as a support order in the Court of Common Pleas of Cumberland County, or other appropriate court. It is specifically agreed between the Parties that if they can not agree upon an amount of child support pursuant to the guidelines, either Party can submit the determination of a child support amount to the Domestic Relations Office for recalculation. Until the Parties 1995 Federal income taxes are calculated, for calendar year 1996, Husband shall pay child support to Wife in the amount of $633.15. No later than April 30th of each C WIIr, A.\,Cl.Y 1.AW'L,11 lIlCU".ato.l.'r'"\'llOUY NOI 7 year, the Parties will exchange income information (including copies of their respective W-2 or 1099 forms) so that they may be able to compute the appropriate child support payments that would be due (for the ensuing twelve month period) based upon the Child Support Guidelines then in place for the Commonwealth of Pennsylvania. In addition to the basic child support, the amount paid by Obligor shall be increased 50 as to account for the Obligor's share of child-care expenses and mandatory school expenses p~id during the month, and unreimbursed medical expenses which the insurance carrier has declined to cover during the month, which share shall be in addition to the basic child support amount. If the Parties can not agree upon the figures to be used in re-calculating an amount or the amount to be paid by Obligor, either Party may petition the Domestic Relations Office for a calculation of the appropriate child support amount. b. Child support shall continue for Sara until she reaches eighteen (18) years of age or continues to be actively enrolled in high school, whichever occurs later. c. The Party not exercising primary physical custody of Sara (the Obligor) agrees to transmit to the Party exercising primary physical custody of Sara any and all support payments by the fifth (5th) day of each month. For purposes of this Agreement, payments shall be deemed transmitted if they are personally delivered or placed in the United States Mail, first class mail, postage prepaid, on or before the fifth (5th) day of each month. C' M.'~I.~ r 1.AW(l"tlno"...O'C......vt1UtlT ",roll 8 d. The Parties hereby agree that as long as there is no cost involved, both Husband and Wife shall carry Sara on their respective health insurance coverage as long as Sara is flligible for said coverage. If and when health insurance becomes an out of pocket expense for either Party, the Parties will equally share the costs of providing Sara with the same coverage as the Commonwealth of Pennsylvania provides to its employees. e. The Parties agree that they will equally share in any unreimbursed medical expenses incurred for the care of Sara pursuant to subsection (d) above. f. The Parties agree to equally share all costs of child care paid for by the Party exercising primary custody of Sara for purposes of maintaining his or her employment. As of the date of this Agreement, any babysitter, governess or nanny, who may by law be deemed to be an "employee" shall be solely the employee of the Party having primary physical custody, notwithstanding the fact that the other Party may contribute to his or her compensation. 5. If and when the Parties begin filing separate income tax returns, it is agreed that the Party having primary physical custody for a majority of a particular calendar year may claim Sara as his or her dependent for that particular income tax year. C'MIH',C' 1.A"'4'\n~f\llJlNoI"v.IUIJ'AI" 9 "" , , " I " f: , ':1 .':1 .._- .. t . ".' 1'.. \-.- .J l) ,1" (,) ~,; IJ i ;{ I~ ~ Ii! '" i ~ r'l iij I ~~ ... ... en ! e ~~ ' ~fid .... .1 i ~ I i ill ... !o f~ !! :: ;::! o i :~ H~~~ e~ ! 'J I q [[ . . . ill ""t;: 041 I> ~ ... ! I 'l rg ~ .. .. , . .. LAW OFFICES ~..... .g<;r:;~ &. dt;~ ~UL 0 7 1997 SUSAN A. SLOANE, : IN THE COURT OF ca-lMON PLEAS OF Petitioner : CUMBERLAND COUNTY, PENNSYLV~IA . . vs. . NO. 96-122 CIVIL TERM . WILLIAM M. SLOANE, . CIVIL ACTION - LAW . Respondent IN CUSTODY amm OF CXXlRT AND tOf, this ~ . day of --<1~;.~ , 1997, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated May 14, 1996, incorporating the provisions of a Custody Agreement entered into by the parties on March 29, 1996, shall continue in effect with the following additions and modifications: A. With regard to scheduling vacations under paragraph 3 c, the parties shall notify each other of his or her selection of vacation weeks by April 1 and shall finalize the vacation schedule by May 1 of each year. B. Both parties shall provide the Child with a clean and healthful living environment at their respective residences. C. Both parties shall take all reasonable steps in order to avoid exposure of the Child to cigarette smoke. Neither party shall smoke in his or her residence or in the presence of the Child during periods of custody. D. The parties shall participate jointly in a course of counseling to be conducted by a professional selected by agreement of the parties and counsel. The purpose of the counseling shall be to improve and/or develop cOl11l1unication between the parties in order to serve the best interests of the Child. The counseling sessions shall be scheduled to begin as soon as possible after the Custody Conciliaiton Conference. If, after determining the anticipated costs of counseling (with deductions for any insurance coverages), the parties are unable to agree on responsibility for payment, counsel for the parties may contact the Conciliator to schedule a telephone conference in an effort to resolve any dispute over counseling costs. 2. The Father agrees that the Mother may come to view the living conditions at his residence at a prearranged time with the specific arrangements to be established through counseling. SUSAN A. SLOANE, Petitioner : IN THE COURT OF COOMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA \'5. : NO. 96-122 CIVIL TERM WILLIAM M. SLOANE, Respondent . . CIVIL ACTION - LAW IN CUSTODY PRIm JlDGB: Kevin A. HeII8 ammr CXK:ILIATIaf SlRIARY RIlPlRl' IN AO:XIUW<<Z WI'l'H CUIBBRLAND aumc RllLB OF CIVIL P9::'~'lRB 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: !!!!! DATB OF BIRTII aJlRJ!B1'Ly IN amaJlC OF Sara Marie Sloane June 8, 1990 Petitioner/Mother 2. A Conciliation Conference was held on Septentler 2, 1997, with the following individuals in attendance: the Mother, Susan A. Sloane, with her cOllllBel, Rebecca R. Hughes, Esquire, and the Father, William M. Sloane, with his counsel, Mark T. Silliker, Esquire. 3. This Court previously entered an Order on May 14, 1996, incorporating the terms of a CUstody Agreement between the parties. The Mother filed this Petiton for Modification. ~"kn1h,A :3, /9'17 Oat:""" . 4. The parties agreed to entry of an Order in the form as attached. ~~ Oawn S. ::;un y, Esqu re custody Conciliator iim ~ !h:1 ... ~ ,I "' '" 8 I 9~ jj.2'.li~:!l ~ .;l t!:: .. II !l :: :: I W'I-< @J! ~ . ',j . ~& II '/I .it, Ii ,~": !& ~ r./'Jie:::iti ~ ~~~ . g ~ il III ~L~~l . ~P,';; ~ d~ . ~ ::0 0( ~ ! ..:l ..:l ~ ~ 0 8 1997