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JAMES C. GALBRAITH,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 16 5;) If i,J~,...
IN CUSTODY
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NICOLE SUSANNE REDINGTON.
Defendant
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ORDER OF COURT
AND NOW. S( fJ f .;;:, 199t., upon consideration of the attached complaint. it is
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hereby directed that the parties and their respective counsel appear before
P...- ') s...,J..../. Esquire. the conciliator. at 3'i Lv I"),......st. ""'",4..... ..i-?
. Pennsylvania. on (....J"I the / 7/'1 day of (Jre fp\'xr; 199. at
~ o'clock~.m.. for a Pre-Hearing Custody Conference. At such conference. an
effort wiD be made to resolve the issues in dispute; or if this cannot be accomplished. to
define and narrow the issues to be heard by the court. and to enter into a temporary order.
Either party may bring the child who is the subject of this custody action to the conference,
but the children', attendance is not mandatory. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
FOR THE COURT.
By
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRA TOA
COURTHOUSE. 4TH FLOOR
CARLISlE. PA 1 70' 3
1717124~6200
JAMES C. GALBRAITH.
Plaintiff
vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NICOLE SUSANNE REDINGTON,
Defendant
NO.
IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW comes the Plaintiff, JAMES C. GALBRAITH. by his attorney. Samuel L.
Andes. and makes the following Complaint for Custody:
,. The Plaintiff is JAMES C. GALBRAITH, an adult individual who is a resident of
Carlisle. Cumberland County, Pennsylvania. but his current mailing address. while on active
duty in the military service, is HQ USAREUR. CMR 420. Box 2187. APO 09063.
2. The Defendant is NICOLE SUSANNE REDINGTON. an adult individual whose
current mailing address, while on active duty in the U.S. Army, is HO USAREUR. CMR
420. Box 1621, APO 09063.
3. The Plaintiff and Defendant are husband and wife. having been married on 31
July 1992.
4. The Plaintiff and o.fenclant are the nature! parents of one minot child.
Aluandra Nicole Galbfaith. born 24 July 1993.
5. Ptalntiff and Defend.." ere both on Ktive du'y m the U.S. Army end ere
stationed ".er H4tdelburg. Gefmlll'lY Tht$ Court hu JUtlsdtc:hon in thts maller bKMJSe the
father', home of I'KOfd. end t~fOte. hts ~wful ,esidence. IS c.tisle. PennsvfvIll1la.
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II which was his home at the time he enlisted in the Army. As a result of Pennsylvania being
Ij his lawful residence, it is the domicile and residence of the child for purposes of custody
jurisdiction. Moreover, Pennsylvania is the only jurisdiction which has any meaningful
contact or connection with the parties or the child because the parties and the child have
returned to Carlisle. Pennsylvania, repeatedly during vacations and periods of leave and
because the only family members with whom the child has any relationship. other than the
Plaintiff and Defendant. are the Plaintiff's mother and sisters who reside in Pennsylvania.
6. Plaintiff seeks primary physical custody of the minor child. ALEXANDRA
NICOLE GALBRAITH.
7. The child was not born out of wedlock and is presently in the joint custody of
the Plaintiff end Defendant.
8. Since her birth, the minor child has lived at the following locations with the
following persons:
July. 1993.
to October, 1993
Columbia. Maryland
Plaintiff end
Defendant
October. 1993.
to May. 1995
u.s. Army
Landstuhl. Germany
Plaintiff and
Defendant
May. 1995.
to Pf8Mnt
u.s. Army
"leppemeim, Genneny
PlM\tiff and
Defendant
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I married to the Defendant. Plaintiff currently resides in a house in Heppenheim, Germany.
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9.
The father of the child is the Plaintiff whose address is set out above. He is
with the child and with the Defendant.
10.
The mother of the child is the Defendant whose address is set out above. She
is married to the Plaintiff. Defendant currently resides in a house in Heppenheim.
Ii Germany. with the child and the Plaintiff.
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11. The Plaintiff has not participated as a party or in any other way in any
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!i litigation concerning the custody of the child in this or any other CClurt.
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The Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this or any other jurisdiction.
Plaintiff knows of no other person not a party to this action already who has physical
custody of or claims to have custody or visitation rights with the said child.
12. The best interest and permanent welfare of thfJ child will be served by grlnting
the ra/ief requested by Plaintiff for the following reasons:
A. Plaintiff has provided more of the care for the child over tha past
two year. then has the Defendant.
B. Because of the Defendant's continuing employment in the U.S.
Armv. she is not able to provide deity cer. for the chitd.
C. The Defendant is liIlely to be auigned to military dutia wtlieh
witI ~ her from havlnQ the thiId with her for long periOdt of timt.
)
COMMONWEALTH OF PENNSYLVANIA I
( 55.:
COUNTY OF CUMBERLAND I
JAMES C. GALBRAITH. being duly sworn according to law. deposes and says that
the facti set forth in the foregoing Complaint for Custody are true and correct to the best
of his knowledge. information. and belief.
Sworn to end subscribed
before me this II ~ dey
of ~r.Jt, . 1996.
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Not Public
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LYIN EllllEllftUl. ......, ....
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IN RE: THE MARRIAGE OF:
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
CASB MO. "-5218 CIVIL TBRK
1M CUSTODY
JAJOlI C. GALBRAI'l'B, JR.,
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Plaintiff/Husband,
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and
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IIICOLII .. UDIMcrroM,
Defendant/Wife.
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DBPlHDAHr'I ~ICI BY BPaCIAL APpaARAHCI IN PRO la
OP UHAVAILABLI'fY POR RJlARIlIG PURSUAHr TO BOLDUR
BAILOR IUlLUP AC'l' AlfD ~ICa OP l'EIIDIMO MA'l"l'J:R8 1M
TJlB 8'I'A'fB OP PLOalDA
COMES NOW the Defendant/Wife, NICOLE S. REDINGTON, in Pro Se
ancl Notice. the court and all concerned a. follow.:
1. Defendant/Wife, NICOLE S. REDINGTON, i. ukinq a .pecial
appearance in Pro S. and aver. to the court and it. conciliator
that .he has never been properly .erved with any docuaentation in
thia cau...
Defencl.ntjWife did receive by regul.r United St.t.. certified
..n at her anltary APe Box . Complaint for cuatody, AII.ignaent to
COncili.tor, .ncI Order of Court directinq . Hearing before
concili.tor for Tuesday, December 17, 1'96 .t ':00 A.M.
.
Defend.ntjVif. did not receive thi. certified ..n notific.tion
until the week of Oec9aber 2, 19'6.
2. Defe~ntjW1fe ....rt. th.t ahe baa not been properly
..rveel nor notiCed pursuant to the Rule. of Procedure and the
l8C\Iring ot Jurisdiction pursuant to tM "nNIylv.ni. code. .nd
..k.. thi. 1IJMtC1.1 .ppearance 80181y for the purpos. of ....rting
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same to the court.
3. As is evidenced in the pleadinq filed by the
Plaintiff/Husband with this court Defendant/Wife is a Captain in
the United states Army who is on active duty and who is stationed
at: HQ USAREUR, CMR 420, BOX 1620, APO 09063 (Heidelberq, Germany).
The Defendant/Wite, NICOLE S. REDINGTON, is currently on
active duty with the United States Army and is unavailable and
unable to attend the Hearinq to be conducted on Tuesday, December
17, 1996 at 9:00 A.M. before the conciliator, Dawn S. Sunday.
The Defendant/Wife is protected from such appearance and is
protected pursuant to the Soldier Sailor Relief Act. The
Defendant/Wite asserts the Soldi.r Sailor Relief Act and inability
to attend the proceedinq due to beinq on active duty in the United
States Aray on Oecaabar 17, 1996.
4. That there is currently pendinq before the State Court of
Florida in the 11th Judicial Circuit in and for Dade County Florida
bearinq Cas. No. 96-23356 FC 29 a Dissolution of Marriaq.
proceedinq styled NICOLE S. REDINGTON, Petition.r/WU., v. JAMES C.
GALBIlAITH, JR., R.spond.nt/Husband and sa.. va. duly served upon
the R..pondent/Husband on the 11th day of October, 1996. (COpy
attached aarked exhibit -A-)
Th. court of the Stat. of Florida thus bay. acquired clv11
jurilldlotlon over the Husband, JAMES C. GALBRAITH, JR., a. _11 ..
NICOLI C. ItIDJIICTOII, the "Ue and the .ubject: aatter of tMlr
aani... Inclulve of the is.,", of custody of the partl.. .inor
dlUd. ALEXAInlItA NICOLI GALUAITH. D.O.'. July 24. 1991 (AfIe thne
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5. As the State of Florida has properly qained personal
jurisdiction over the subject matter pursuant to the Uniform Child
CUstody Jurisdiction Act as adopted by both the State of Florida
and the State of Pennsylvania, the State of florida ouqht have the
appropriate jurisdiction over the issue of custody of the parties
ainor child.
The State of Florida has already scheduled proceedings in
this Stae and a full evidentiary hearing on Temporary CUstody and
other Tamporary Relief, to wit: child support. This will take place
at 11:30 A.M. on Wednesday, January 22, 1997.
6. The State of Pennsylvania ought properly decline
jurisdiction over this cause due to ongoinq proceedings in a sister
State.
7. Further, as of oecellber 13, 1996 by stealth, deceit, and
in coaplete contravention with the purpose and intention of the
Uniform Child CUstody Jurisdiction Act the Father did WITHOUT
NOTICE TO THE MOTHER take the child froa the Mother's residence and
abscounded with her to the State of Pennsylvania.
The father has acted in this diereputable aanner solely for
the purpose of aUemptihCJ to place the child in the juriacUcUon of
the State l.If Pennsylvania for the purpose of attempting to further
his attempts to qain custody jurlad1ction 1n the Stat. of
Pennaylvania.
The Uniform Child CUstody Jurisdiction Act. atat.. that ... U
Us "UU...r fo.l' lalU.1 eune Ua noatMl, 'akaa \~. nue
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froa another stata or has enqaqed .imilar reprahen.ible conduct,
the court may decline to exerci.a jurisdiction if this i. ju.t and
proper under the circWII.tance. ... The Uniform child CUstody
Jurisdiction Act further states that ... in .ppropriat. c..a., .
court dismissinq a petition under this .ection may charq. the
p.titioner vith ne.ce..ary trav.l and oth.r .xpan..., includinq
.ttorn.y'. fa.., incurr.d by oth.r parti.. or th.ir vitn........ In
addition to the above language of the Uniform Child CUstody
Jurisdiction Act as adopted by the State of Pennsylvania the
Uniform Child CUstody Jurisdiction Act also states that ... a court
of this st.. .h.ll not .xercis. its juri.diction under this Act if,
at the tiae the patition is fil.d, proceadiDq conc.rninq the
ou.tod, of the child v.. pendin9 in the court of another stat.
..arci.inq juri.diction .ub.tantiall, in coaforait, vith this Act,
unle.. tha proceadinq i. .t.,ed by the court ot the other stat.
becau.e this state i. a aore appropriate forull or tor other
r...On.... As the Defendant/Wife herein was never properly ..rved
or noticed of any of the proceedings within the State of
Penn.ylvania the state of Pennsylvania does not properly have or
acquir. jurisdiction. The State of Florida has in tact acquired
jurbcUction by qainir\9 penonal .ervice over the Plaintiff/Hu.band
and ha. in tact .cheduled proceedir\9s in that state.
I. The Defendant/llife uk.. this Notice by Special
Appearance a. ahe ....rt. that aha 1\&. not been properly ..rved nor
h.. the State of Pennaylvania acquired juriediction over her and
aha chooa.. to retain that poatUNt and v111 not vai"... any .ervice
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JAMES C. GALBRIATH. JR.,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY.
PENNSYLVANIA
VI.
CIVIL ACTION - LAW
NICOLE S. REDINGTON.
Defendant
CASE NO. 96-5218 CIVIL TERM
IN CUSTODY
AFFIDAVIT OF SERVICE BY CERTIFIED MAIL
Amy M. RoteIIi. being duly sworn according to law. deposes and 11)'1 U follows:
1. That she is an cmpIoyee of Samuel L Andes. attorney for the Plaintiff herein.
2. That OIl, [)e(:cmber 3, 1996. she delivered to the U.S. PosW Service in Lemoyne, Pennsylvania.
u certified mail (Receipl No P 311 120 468). return receipt requested. addreued to the Defendant herein. a
true and correct copy of the Complaint in Divorce filed in the above-captiolled action duly endoIsed with a
Notice to Defend and Claim Rishts in the divorce action.
3. Said I'tIUm receipt card is attached hereto u &hibit A showina a date of delivery to the
Defendant of Dec.....t.er II. 1996.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
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CIVIL ACTION - LAW
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n NICOLE S. REDINGTON,
i' Defendant
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CASE NO. 96-5218 CIVIL TERM
IN CUSTODY
AFFIDAVIT OF SERVICE BY CERTIFIED MAIL
Amy M. Roselli, being duly sworn according to law. deposes and says u foUows:
I. That she is an employee of SamucI L. Andes. attorney for the Plaintiff'herein.
2. That on. J:M...,~ 3. 1996, she delivered to the U.S. Postal Senice in Lemoyne. Peonsy1vania.
u certified I'IIIiI (Receipt No P 311 120 468). mum receipt requested, addressed to the Defendant herein, a
true and corret1 c:opy of the Complaint in Divorce filed in the above-captioned action duly eodoned with a
Notice to Defend and Claim Rips in the divorce action.
3. Said mum receipt card is attldled hereto u Exhibit A sbowing . date of delivery to the
Defendant of IW-lJer ll, 1996.
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JAMES C. GALBRAITH, . IN THE CXlURT OF CXX1I1ON PLEAS OF
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Plaintiff . CUMBERLAND CXXlNTY, PENNSYLVANIA
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vs. : NO. 96-5218 CIVIL TERM
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NIOOLE SUSANNE REDINGTON, . CIVIL ACTIOO
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Defendant . IN CUSTODY
.
aulBR OF CDRl'
(,. ({ Pt. idv
Conciliation Report,
AM) tOI, this ....' (I 0; day of
consideration of the attached CUstody
and directed as follows:
1. A Hearing is 1IChedu1ed in'l Court Room ~ Lf , of the
Cl.lJDerland COUnty Court House on the -.2!d.. day of.~ <'i, l~ ' 1997,
at '1: 3() o'cloclt..!1.,.m., at which time testimony will be takerr"'with regard
to tii8""'Objections raised by Defendant on the jurisdictional issue. At this
Hearing, the Mother, Nicole SUsanne Redington, shall be deemed to be the
lIlOVing party and shall p'oc.-l initially with testimony. Counsel for the
parties, or the parties pro se, shall file with the Court and opposing
counsel a Mea1xa.ncbn listing the ",,(\<sed stipulated facts that each
respective party will bring before the OJurt on the jurisdictional issue.
nus Mea1xandID shall be filed at least five (5) days prior to the Hearing
date.
, 199<:', upon
i t is-ordered
2. Pending further Order of this Court, the Mother, Nicole SUsanne
Redington, and the rather, J_ C. Galbraith, shall have shared legal
custody of Alexandra Nicole Galbraith, born July 24, 1993. Also pending
the Hearin; in this matter, the Father shall haw pdmary physical custody
of the Olild 81.t:Iject to the Mother I s right to liberal periods of partial
custody of the O\ild in PfilMylvania at any time the Mother is pr...nt in
the O--w_a1th. n. Mother ahlll1 not rIID:Mt the Olild frail Pemsylvania
petdirq further Order of this Court or &gAl Ilot of the parties.
BY THE CXl.R1',
",.J.,
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Iticol. J. Redington. Pro 51
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JAMES C. GALBRAITH, . IN THE COORT OF CX>>lMON PLEAS OF
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Plaintiff : CUMBERLAND CXXJNTY, PENNSYLVANIA
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vs. . NO. 96-5218 CIVIL TERM
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NIOOLE SUSANNE REDING'l'OO, . CIVIL ACTION - LAW
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Defendant . IN CUS'roOy
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QJSTaJl( <XH:ILIA1'ICB SlJIIIARY RI!PCRl'
IN AaXIlDANCB WI'l'H <1IlIlI!RLAND a:umc RlU OF CIVIL PIl(. ..... RB
1915.3-8, the undersigned CUstody Conciliator submits the followin; report:
1. 'DIe pertinent information concerning the Child who is the subject
of this litigation is as follows:
IWIB BIRlBlM'B
aJlRJ!N'1'LY IN ~~~ OF
Alexandra Nicole Galbraith July 24, 1993
Plaintiff/Father
2. A Conciliation Conference was held on Dec:eatler 17, 1996, with the
followin; individuals in attendance: the Father, James C. Galbraith, with
his ccunae1, Salluel L. Andes, Esquire. 'DIe Mother, Nicole SUsanne
Redington, is on active duty in the military in Germany and was not able to
l!l~r at the Conference. 'DIe Mother has not retained counsel in
Pennsylvania but submitted to the Conciliator a 'NOtice by Special
AwMrance In Pro Se of lklavailability for Hearing Pursuant to SOldier
SailOl:' Relief Act and Notice of Pending Matters in the state of Florida"
(oopy attached). The Mother also contacted the Conciliator by telephone
iaaediately Pl'ec6ding the Conference to advise that she was not able to
attend the Conference, did not receive lIMAopc:iate notice of the Conference
and ViIS challenging juriadiction by the Pemaylvania 0Jurta in this matter.
3. The Mother's position on custody is as follows: Durin; her
telephcue call to the Conciliator, the Mother advised that shI is on actiw
duty in the military and is stationed in Germany at the Pl'lnnt tu.. The
Mother stated that the partie separated in early Septe\t)er and that the
Child had primarily resided with her since that time. The I'lOther .tated
that she filed a ~1aint for Divorce and CUstody in the state of Florida
in early October and a Hearin; ie acheduled thereon for January 22, 1997.
The Mother adviMd that she was not Mned with a Notie. of the
Conciliation Conference ooti1 Ill.<........r 11, 1996. The MotIle\" atated that
the Fathel' 11ft Germany in 1LIi~_t- and brought the Child to the lnttld
statee without her prior c:x:n.nt or knowledge. The fl\:lther bel1_ IIhe hu
be<<l the Child's primary ca~taIl,er W MeU pdNrY physical cuetody of
the Child. The Mother ClbjecU to )urbdicticn of the IWlnlIylqnia QlurU
in this .tter W bel1_ that Florida i. the pt:~ fONll to hMr the
custody i__.
<t. The faUlK'. poeiUon on CUstody 18 .. (ollawa: 'l1w Fathel' atated
that he (iled hie CUstody ~ail'lt in the o.tcleRi ColX'\ty CI:lurt of
0-.-_, Pl_ at Sept-*'K ;20, 1996, priOl' to the flU") of the MothK'.
~lon in 'lOl:'ida. n. r.thIr' S\iblliltld ~ U.......MpId bV the
l'TotMnot,uy lndle.U~ thot flllnq det. _I the (~ _lqnl") thlt
Conciliator is dated Septentler 23, 1996. This matter was not scheduled for
Conciliation until Noventler, however, in light of the fact that the Father
was separating from the military in mid Decentler and would not be available
until that time. The Father indicated that the Mother had received copies
of the ~laint and assignment for Conciliation. The Father acknowledged
that he removed the Child from Germany without the Mother's consent.
According to the Father, the parties had been unable to reach an agreement
on the Father's request that the O\ild spend the Christmas holiday with the
Father and his family meai:lers in Pennsylvania. The Father believes that,
as he is no longer in the military, he will be more available than the
Mother to spend time with the O\ild. The Father's mother, father and
sister reside in Carlisle and the Father believes that this gives the Child
a stronger connection to the O:lu...onwealth of Pennsylvania than to the state
of Florida in which none of the Mother's relatives reside. The Father
indicated that the Mother has had substantial telephone contact with the
Child since his IIlOVe to pennsylvania and proposed that the Mother would
have liberal custody of the Child if she were to take leave and travel to
Pennsylvania pending resolution of the custody issues. The Father seeks
pdmary physical custody of the O\ild.
5. In the Conciliator's opinion, the Father's conduct in removing the
Olild from Germany without the Mother's consent or knowledge is
repcoac:hab1e and should not be revarded in the custody pcooee.dings. The
attached .,Lvroeed Order reflects the Conciliator's atteapt to pc'IVent the
Child from being shuttled back and forth betwen the tw countries until
the custody issue has been resolved in either Pennsylvania or Florida. In
light of the cirCUlllStances under which the Child was IIlOVed to Pennsylvani.
and the fact that custody ~oe+..dings are also currently pending in
Florida, an expedited Hearin; is requested on the jurisdictional issue
wherein t~ary custody arr~ta could be ~~-HMd by the Court.
6. The Conciliator nc....._'1da an Order in the fOtlll as attached. To
expedite notice to the PIother in these ",,~in;8, the Father agreed to
fax a CCIpy of the Order entered by the Court to the Mother upon receipt.
j),e,,-~ " 19911 -1.(1.'_- ,J,J.. _..JII-v
Date . Dawn S. ~ I
CUatody Conciliator