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HomeMy WebLinkAbout00-00447 '"^_ ,,_o,n" ,. _' J ~ ' \' -"_' _'i-",", ""',, "'ii NICOLE R. DICKINSON, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLA VNIA v. ; NO. db-Ol) ~.. '-1'-17 ~ JOSEPH S. DICKINSON, DEFENDANT : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before, \'\ l.(' hCt:.c J Dr j in cp (5(6 , Esquire, the Conciliator, on the (:~\tl>day of j1\(t/\ ct 2000, at 3dL SOlLtr\ \0J' SiJu.ti ,Cc~n~ll~l1;~OIA ,.. . f;): fl'J Q..M., at the 4th Flnor, C:lqj1h"r1Hnd ~~v.ania, for a Pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five or older may also be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. Notification to the Defendant by the Prothonotary's Office is waived. For the Court, Date of Order: I \2112 \ b6 By: i.L h,(u.l ustody Conciliator -oj YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 (". -)1- . Fii~9~2~Tl;?~lTJ' .,,, ." ,,-..-'jF;hf O.~ Ie I" ,<,\j....-, .... ..),'tr-~ ...;:! PH ? ~(... . q ~~. t.,'J CU'r.... , l\flt..\::h'i t.\in '.'(" , PENilJ'~"~'i ;;-;I^~~I)Ui{fY '- Utll\lA /,;2),00 &vl ~ /J~ -d4 ~If J';2/.0CJ ~~ /#~ z,~, _ l'd;,OtJ t?? ~ -- /41. /3~ # I, .' '." ~"', ~", r' - ,- .. _ ,,,^ ,.,-~ '!' ~,~" ,.'- . '''' ,~ ~~" - , ~ . ',.-- NICOLE R DICKINSON, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLA VNIA v. : NO. JOSEPH S. DICKINSON, DEFENDANT : CML ACTION - LAW : IN CUSTODY ORDER OF COURT You, Joseph S. Dickinson, Defendant, have been sued in Court to obtain custody, partial custody or visitation of the child: Taylor A. B. Dickinson. You are ordered to appear in person at the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania, on the day of , 2000, at o'clock .m. You are further ordered to bring with you the child: Taylor A.B. Dickinson. If you fail to appear as provided by this Order or to bring the child, an Order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2Liberty Avenue Carlisle, P A 17013 (717) 249-3166 BY THE COURT: 1. .'; . I "-"'. NICOLE R. DICKINSON, PLAINTIFF v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLA VNIA ; NO. ;ltrVV - </"17 C4:J .~ JOSEPH S. DICKINSON, DEFENDANT : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Nicole R. Dickinson, residing at 3552 Oscars Road, Brogue, York County, Pennsylvania 17309 2. The Defendant is Joseph S. Dickinson, residing at 2203 Brigade Road, Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff seeks (primary/partial) custody of the following child/children: NAME PRESENT RESIDENCE D.O.B. Taylor A. B. Dickinson 3552 Oscars Road Brogue, Pennsylvania 05/17/94 The child was not born out of wedlock. The child is presently in the custody of Nicole R. Dickinson who resides at 3552 Oscars Road, Brogue, Pennsylvania During the past five years, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATE Nicole R. Dickinson (mother) 19804 Tenth Ave. Ct. E Joseph S. Dickinson (father) Spanaway, Washington 05/94 - 12/94 L'_ ~ >~, H, i ,,'.' , I '~ I NAME RESIDENCE DATE Nicole R. Dickinson 1114 E. Powder Horn Road Joseph S. Dickinson Mechanicsburg, Pennsylvania Mr. & Mrs. William Dickinson (paterna! Grandparents) and their children: Don, Evan and Courtney 12/94 - 08/96 Nicole R. Dickinson Joseph S. Dickinson 126 Briarpatch Drive Carlisle, Pennsylvania 08/96 - 01/97 Shared Custody: Nicole R. Dickinson 4516B Warrington Avenue Mechanicsburg, Pennsylvania 01/97 - 08/99 Joseph S. Dickinson 126 Briarpatch Drive Carlisle, Pennsylvania 01/97 - Unlmown Joseph S. Dickinson Mechanicsburg, Pennsylvania Unlmown - 02/99 Nicole R. Dickinson Kevin Wishard (Boyfriend) 3552 Oscars Road Brogue, Pennsylvania 08/99 - Present Joseph S. Dickinson Maria Taramelli (Girlfriend) 2203 Brigade Road Enola, Pennsylvania 02/99 - Unlmown The mother of the child is Nicole R. Dickinson, currently residing at 3552 Oscars Road, Brogue, Pennsylvania. She is divorced. The father of the child is Joseph S. Dickinson, currently residing at 2203 Brigade Road, Enola, Pennsylvania He is divorced. 4. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently . ~ ,L" resides with the following person/persons: NAME RELATIONSIDP Taylor A. B. Dickinson Son Kevin Wishard Boyfriend 5. The relationship of Defendant to the child is that off ather. The Defendant currently resides with the following person/persons: NAME Taylor A. B. Dickinson Maria Taramelli RELATIONSIDP Son Girlfriend 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff does not know of 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 interest and permanent welfare of the child will be served by granting the relief requested. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. ~ , ~ , I WHEREFORE, the Plaintiff, Nicole R. Dickinson, requests the court to grant primary physical custody of the minor child, Taylor A. B. Dickinson, to her. JAMES, SMITH, DURKIN & CONNELLY LLP Date: 1- /q -OD - VERIFICATION I verify that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date:~r1(1.1 A aJu~ I~ 20W (Jfu~ J~ OAlAeU1(26Vt Nicole R. Dickinson, Plaintiff ",. . ' .'", ,_ '/.. ili..' ~ ~ ",-,",~,.~:,'" ~ ,,' o. , ">";.".","H,'", w~ ?--- (' ~ i u... -r ?--> ~\ -- ~ FJ ~ ~IO~ ~ 1 ~ .~" . .','" "",."-- ~ (") C"'11 0 c: c; ?:'~" --;-\ -Q [1 ~i; rn 1" .,--,.. ;"F Z :j) ,~ L-___ ::0:; '" I~,\~~, en .e -' ~ ~Cj -0 ~L ',~~ ~O :.!\~ '~(;') ~,C) ...' c,: ~? C'.J, rn z'. :.-'1 :< '.",) 55 -< - NICOLE R. DICKINSON, Plaintiff v. JOSEPH S. DICKINSON, Defendant ,H : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000447 CIVIL : CIVIL ACTION - LAW : IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF DAUPHIN AND NOW, this )It-A- day of (~.//~ ' 2000, personally appeared before me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly sworn according to law, deposes and says that a copy of the Complaint in Custody .,'P, ,'(, was served~li the Defendant, Joseph S. Dickinson, on February 1, 2000 by certified mail number Z 448 660 653, addressee only, return receipt requested, as evidenced by the return receipt card attached hereto and made a part hereof. :;::~e~~SUbr~ day of Notarial Seal SlephanJe L ~ Notarv Public Huminelstown Boro; Dauphfn County My CommIssIon Expires Sapt 26. 2002 Member. Pennsylvania Association of Notaries "1-".,' --- L _ . ~ ~,- . "'--S-ENDER: ~:J=--COmplete items 1 and/or 2 for additional services. ~~Cl> 4- Complete items 3, and 4a & b. _ ,_,_ ~- . Print your name and address on the reverse of this form so that we can . Of return this card to you. J"'j- __e_ Attach this form to the front of the mailpiece, or on the back if space '" ~ does not permit, ~..,.!=,. Write "Return Receipt Requested" on the mailpiece below the article number, 2. Jv( Restricted Delivery i .... . The Return Receipt will show to whom the article was delivered and the date ~ .'- -~ _delivered. _~__ __r_ Consult Ro~trnast~J _f(:)I:' j~e. ,~ ,_. ~ 3. Article Addressed to: 4a. Article Number a f%%; 1;::t~~ ~ b??dz/ m /7,:;;.25' ~=-~ ''''G:l ~ ~l 5. Signature ,(Addresse~I,C'~ I~~ j;:~ i~ r also following fee): 1. 0 Addressee's Address wish to receive the services {for an extra :z 1"//J? deO d53 4b. Service Type o Registered JRf Certified o 7. Date of D -~. " o ... _~..fLdE~s~lf'~,Addr~~_(onJy if requested.:.:: and fee is paidt :; .<= .... *U.S, GPO: 1993---352.714 DOMESTIC RETURN RECEIPT ---J " ,; .2 ~ " '" ~ 0. ';; " " '" E " ~ " a: co " ';; " ~ .l: ~lIiHilriilMitaitjl~!;l""!I!~~;cl;i"-~__I~~iIl~Mi~,jl!l!lWJ>t,\li<"'Jffi'il"~'ilW--"j",,.J!lm,",,J~l-"lllij.j'K..L.1iw1lllk_ii~I""IlliilIlIIlti<~~Mili~~~_~-."-- . () 0 ( C 0 "' -" -nIT f"1 [T1(n CD z: :}) I zr ~~r c:> r:: CJ ""t) <-.. do"C'. ~- ;2; C' t:? Pc.: Z :.,.) =< ()"\ ,. , ~.. ","" , -,I , _"',',~" """-,,,,',' - ',,,"'''"'1..,".- '7,' .~'.'o' ,",,', - '-".""-"-dV-c;,,".,.. - _ ~.o', ',_y='-.'l~""-,.".,-,-,,,,~;..,J,i;..;::_.' ;''';".'';j,,,i"~ 1>"-,f' _m ""'~''''';';~-;--"' ","~""''''', '-,',:,j-"t;",-\> ";"""',,.,ii '""-',C,, .' I, " ' ";1 NICOLE R. DICKINSON, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . . NO. 2000-447 CIVIL . . . JOSEPH S. DICKINSON, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . NOTICE TO PLEAD TO: NICOLE R. DICKINSON You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. LAW OFFICES OF CRAIG A. DIEHL Clotfelter, E torney I.D. No. 7296 64 Trindle Road Camp Hill, PA 17011 (717) 763-7613 Attorney for Defendant "" ,'"~",,"--,, - ~~,c~ "~' , ,", ~, ' ~". ",,,'~'-', - ",_' ,,-\>,', 'i~~' 'V".' "._,,! -0,"'" " '__0,;.,__" ' '-"i NICOLE R. DICKINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-447 CIVIL JOSEPH S. DICKINSON, Defendant CIVIL ACTION - LAW IN CUSTODY ANSWER WITH NEW MATTER COUNTERCLAIM AND NOW, comes Defendant, Joseph S. DiCkinson, by and through his counsel, Law Offices of Craig A. Diehl, and files this Answer with New Matter Counterclaim as follows: 1. Admitted. 2. Admitted. 3. Admitted in part and denied in part. It is admitted only that the Plaintiff seeks custody of the named child, that the child was not born out of wedlock and that the identity, marital status and residence of the mother and father are as alleged. However, it is specifically denied by Defendant that the child is presently in the custody of Plaintiff and that the child's residences, households and dates thereof as alleged are accurate. To the contrary, the child is presently in the custody of Defendant, Joseph S. Dickinson to the extent that the parties have a truly shared custody arrangement that has been the status quo for more than three (3) years. In further answer hereof the child has resided with the following persons and at the following addressed for the past five years: Date Name Address Plaintiff and Defendant 19804 Tenth Ave. ct. E. Spanaway, WA 5/94 - 12/94 Plaintiff, Defendant, Paternal Grandparents and their children: Don, Evan and Courtney 1114 E. Powder Horn Road Mechanicsburg, PA 12/94 - 8/95 Plaintiff and Defendant 126 Briarpatch Drive Carlisle, PA 8/95 - 1/97 Shared Custodv from 1/97 throuqh the oresent as follows: Plaintiff 4516 B Warrington Ave. 1/97 - 8/99 Camp Hill, PA Defendant 126 Briarpatch Drive 1/97 - 4/97 Carlisle, PA Defendant 4172 Antelope Court 4/97 - 4/98 Mechanicsburg, PA Plaintiff and 3552 Oscars Road 8/99 - Present boyfriend Brogue, PA Defendant and 2203 Brigade Road 4/98 - Present girlfriend Enola, PA 4. Admitted in part and denied in part. It is admitted that Plaintiff is the child's mother and that Plaintiff resides with her boyfriend. However, Defendant denies any implication in this paragraph the child resides primarily with Plaintiff and her boyfriend. To the contrary, the parties have a truly shared custody arrangement pursuant to their the terms of their Marital Settlement Agreement incorporated into their Divorce Decree issued on September 1, 1998. 5. Admitted. 6. Admitted. 7. Denied. Defendant specifically denies that the permanent welfare of the child will be served by granting Plaintiff's request for primary custody. To the contrary, it is in the best interest and permanent welfare of the child to award Defendant primary physical custody such that the strong bond that he shares with Defendant, his father, can be nurtured. In further answer hereof, the child presently spends fifty (50%) of his time with Defendant, and any decrease in that amount of time or excluding Defendant from the child's life would only serve to cause serious damage to the child's emotional, developmental and spiritual well-being. See further discussion of child's well-being in paragraph 9, infra. 8. Admitted. WHEREFORE, Defendant, Joseph S. Dickinson, respectfully requests that plaintiff's Complaint seeking primary physical custody of the child, Taylor A.B. Dickinson be denied, and primary physical custody be awarded to Defendant with partial custody rights in Plaintiff as agreed upon by the parties. NEW MATTER COUNTERCLAIM 9. Defendant's responses to paragraphs 1 through 8 of Plaintiff's Complaint are incorporated herein as if fully set forth. By way of further Answer and New Matter to Plaintiff's written request for custody, is hereby averred that it would be in the best interest and permanent welfare of the child for the Court to enter an Order granting the parties shared legal custody with primary physical custody of the child to Defendant and partial custody to Plaintiff for the following reasons inter alia: .>' ~ '" - ""',,~ '"n,,' :,':",'\":'"''"-,""",'O,_','-''J 'Y- -, 'r, ,: :',:::, :;::;t!'~{'" ,,'-,"~;' ,-,',-, _n".""',, ,'." a. Defendant has been and continues to be the primary caretaker of the child despite the fact that the parties have shared custody. More specifically, it was Defendant who potty trained the child when Plaintiff voluntarily moved to California for her employer. During the six (6) months that Plaintiff remained in California, Plaintiff refused a number of her employer's offers to visit pennsylvania and consequently, saw the child for only one weekend per month during that time period. In addition, Defendant has also been active in the child's school activities, consistently appearing to participate in same while Plaintiff does not; b. Defendant is able to provide a stable home environment for the child where the child has his own bedroom, bathroom, and family pets to which he is greatly attached. However, while in Plaintiff's care, the child has slept in the same bedroom as Plaintiff and her boyfriend, upon information and belief; c. The child has a one-half sibling who also resides in Defendant's household and the child's relationship with his sibling is critical to the healthy development of both children; d. Awarding Defendant primary physical custody would permit the child to retain the strong ties to the community in which he. has been raised. More specifically, the child has been enrolled.in'Defendant's school district, plays on a local soccer team'and has developed a number of friendships within Defendant's community such that a change in same may be devastating to the child; and e. Defendant has consistently acted in the child's best interest by taking the child to sessions with psychologists and/or psychotherapists. More specifically, the parties and the child have voluntarily been treated by three (3) professionals on a regular basis. Despite Defendant's encouragement to continue with each treatment, Plaintiff refused to return to see the first psychologist, thereby requiring Defendant to proceed in the child's treatment without Plaintiff. Plaintiff now also has issues with the opinions of the second psychologist. The second psychologist was recommended by the child's pediatrician, Dr. Daly, and was Plaintiff' s choice for advisement and treatment. Upon meeting with both parties and the child, said psychologists have indicated that an award of primary custody as requested by Plaintiff would not be in the best interest of the child and the professionals have actually advised against such an arrangement. WHEREFORE, Defendant, Joseph S. Dickinson, respectfully requests that this Honorable Court award the parties shared legal custody of the child, Taylor A.B. Dickinson, with primary physical custody to Defendant and partial custody to Plaintiff at times agreed upon by the parties. Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL inda A. ttorney I.D. No. 729 464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 Attorney for Defendant , d. '_.-;,,;;, '~"~" ~' "__ Crie', '^ 00 , -,' , '. -~ " - "~., ~ -~". '" - ,.," '.'~~-"~',, ~,:,~~:~.:~;,:;;.;,'"~:::::,:'j~",, ~.O ,--1 '~: NICOLE R. DICKINSON, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : . NO. 2000-447 CIVIL . : JOSEPH S. DICKINSON, : CIVIL ACTION - LAW Defendant : IN CUSTODY VERIFICATION I, the undersigned, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. Date: Z.-ll.(~OD ~CKINSON' Defendant ,'-'-';,"---:.."~ -, ,-,,,,,; .,,",.', . ,.~'. ~. ~,.' e _ "....-__ - ~"''"-''.. ,--, .,,~ . ", . . ~-"'"',' I;; J.- ,,' :",,' ,:"k ,',S '. ..,~'-.~, .,-'", ,""-,en",,",;, :,.", ";,, >;;"';_c, ;'U,~ ,',~, ~,::..,.~'", .', -","': '"~,,,~ "'";{',, [',0 "''- . ;1 NICOLE R. DICKINSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2000-447 CIVIL . . JOSEPH S. DICKINSON, Defendant : CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on this date, a true and correct copy of the foregoing document was served upon the opposing party by way of United states First Class Mail, postage prepaid, addressed as follows: John J. Connelly, Jr., Esquire P.O. Box 650 Hershey, PA 17033 (Counsel for Plaintiff) Dawn S. Sunday, Esquire 39 W. Main Street Mechanicsburg, PA 17055 (Custody Conciliator) LAW OFFICES OF CRAIG A. DIEHL Date: c:l-/~/o-o . By: ~04Ui4mnv J /Steph nie A. oore, Legal Assistant 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 "'''''~'''''"'''''~_.'''"'''''"~'''''''''''''''~''' ,.=" ~ I 'H"~_""'''''''~~~d~_J-"," > , . ~ '" ... 3 ;:: ~ r- "tJ .... ~ :::J :J: :n Ol F Z r 0 0 '" r ~ :Il m ." - ~ ." ~ '" g (') . 0 m 3 CIl 0 :::J ." -J (j) (') '" "tJ '" '" do :n :Jl '" 3 z ;< )> ffi Cil :J: 15 :::J Cil > :n z .,. '" ~ ~ '" ~ JTl m C :n in ~ :Il (j) '" .... :z: - :n r- ~ m '" ':!l ~? n I;) ,- C.~ "1 "C) c ,,,... I: ., m ,_,:J .L N -''? /~ (..0 (.~; -"~ r:; )3:: C) , -, ~ Cj OC;.- co p C~ >~ ,',) ::< ( ,) :',"<>7 "~" ;':. '~;"~ ,,~,:,"')>'! ~.dl' . NICOLE R. DICKINSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. 00-447 CIVIL TERM . . JOSEPH S. DICKINSON, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF CXJURT . ",+L -I AND I!DIJ, thJ.s (:> day of A ilf ,.. r, . consideration of the attached Custody ConcHJ.ation and directed as follows: , 2000, upon Report, it is ordered 1. The parties shall submit themselves, their minor Child, and any other individuals deemed necessary by the evaluator, to a custody evaluation to be performed by a professional selected by agreement of the parties and counsel. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best serve the interests of the Child. The parties shall sign all authorizations deemed necessary by the evaluator in order to obtain additional psychological, medical, educational or other additional information concerning the Child. The parties shall equally share the cost of the evaluation. 2. Pending further order of Court or agreement of the parties, the parties agree to continue equally sharing physical custody of the Child under their current arrangement. 3. Upon completion of the custody evaluation, and in the event the parties are not at that time able to reach an agreement as to ongoing custody arrangments for the Child, counsel for either party may contact the Conciliator to schedule an additonal CUstody Conciliation Conference. BY THE COURT, () Q 1-') s-; e, -;~; -r; f~ ' =; ~ ~~;:: ~-J '"I I":~~ Z::, - :~'l::j (02..... '-._; -<" ,,- ,--, c;::: c'- ~~~ ....';,._n_, v ,,~,----;, J. 2~ ~~~ ........ ;. ("j 5~~r A ^# M (j ~ 4,14.0 10~~ . cc: John J. Connelly, Jr., Esquire - Counsel for Mother Linda A. Clotfelter, Esquire - Counsel for Father - . NICOLE R. DICKINSON/ : IN THE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY / PENNSYLVANIA . . . vs. . NO. 00-447 CIVIL TERM . . . JOSEPH S. DICKINSON/ : CIVIL ACTION - LAW Defendant . IN CUSTODY . CUSTODY CXJ!iICILIATICfi SUMMARY REPCRr IN Ae<mDANCE WITH CUMBERLAND COUNTY RIlLE 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 DATE OF BIRTH CURRElilTLY IN CUSTODY OF Taylor A. B. Dickinson May 17/ 1994 Mother/Father 2. A Conciliation Conference was held on March 30/ 2000/ with the following individuals in attendance: The Mother, Nicole R. Dickinson, with her counsel/John J. Conne11y, Jr./ Esquire, and the Father/ Joseph S. Dickinson, with his counse1, Linda A. Clotfelter/ Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date ~ , J .;Lon/") / ot~ Custody Conciliator .". ~- I,~~~ :.: NICOLE R. DICKINSON NIK/A NICOLE R. WISHARD PLAINTIFF V. JOSEPH S. DICKINSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-447 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, August 21, 2001 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Tuesday, September 18, 2001 at 11:00 A.M for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the 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: Isl Melissa P. Greevy. Esq. f;tJ 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 TOYOURATIORNEY AT ONCE, IF YOU DO NOT HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND our WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 '-'7~) FI! r::r)--('rF!::I(\C 0;:- T'-,;~ -T:",-\,-~~, ,;,~r~~.- , - 1- ",,',\JiARY (11 "I "III' ')R """ v "ler'" ....llj. II' - ,~" ~ hi ~ I v CU',a"':". '...-, j, ',:;,~,I:,!..r'i\'L.! COU\fT' PcNI'/SYLWNiA' Y ~Ol~t:Jl 1f'cJ;i-ol y- ()f'/J I - / M.C~~$47~ 'J1~ ~ ~ etlf ~ ~~ /Yl~ $ ~..5l6~ """~ """"""""""".-.-~f"'rr .>~ ,~~ .~ "~T'<'l"1ll'~!"~""_"''''='''''''''''''!'11'''''''''''l~'"lI~~l!IiII!i!I~~,_~~~ _';,',.',-" '~.'~~",^,o'" '~",Jc- ~',,; """ },"' ,""'""-"';'-,f/'.- ", . , ~ "".' """''''"','' , ;';",', . "-"h""<:--_ '.""w__ [: - NICOLE R. DICKINSON, now known as NICOLE R. WISHARD, PlaintifflPetitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLA VNIA v. : NO. 00-447 CIVIL TERM JOSEPH S. DICKINSON, DefendantJRespondent : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before, , Esquire, the ConciHator, on the _ day of 2001, at _.M., at , Pennsylvania, for a Pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five or older may also be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. Notification to the Defendant by the Prothonotary's Office is waived. For the Court, Date of Order: By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 -'0"0, 'I< :r :' NICOLE R. DICKINSON, now known as NICOLE R. WISHARD, PlaintifflPetitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLA VNIA l' I:: \ v. : NO. 00-447 CIVIL TERM JOSEPH S. DICKINSON, Defendant/Respondent : CIVIL ACTION - LAW : IN CUSTODY PETITION TO MODIFY EXISTING CUSTODY ORDER Ii , , Ji . AND COMES NOW, Petitioner, Nicole R. Wishard, by and through her attorneys, James, J: i: , 1. Your Petitioner is Nicole R. Wishard, who currently resides at 3552 Oscars Road, I I' , I I I I I I Smith, Durkin & Connelly, LLP by John J. Connelly, Jr., Esquire, and files the following Petition to Modify Existing Custody Order and in support thereof, respectfully represents as follows: Brogue, York County, Pennsylvania 17309 2. The Defendant is Joseph S. Dickinson, whose last known address is 2203 Brigade Road, Enola, Cumberland County, Pennsylvania 17025. 3. The parties are the parents of one minor child: Taylor A. B. Dickinson, date of birth May 17, 1994. 4. On April 13, 2000, an Order of Court in the above-captioned action. A copy of the Order is attached hereto and marked Exhibit "A". 5. The parties equally share physical custody ofthe minor child on an alternating week schedule. 6. It is the Petitioner's plan to leave her employment in order to be available as primary caretaker for the minor child. . "", ",'^ ~- . . ,'^ ^'~ ,- -""j 7 . Your Petitioner believes that it is in the best interest of the minor child for her to have primary physical custody of the minor child because she is in a position to act as a full time, stay at home parent. WHEREFORE, your Petitioner, Nicole R. Wishard, requests that the Court modify the Order of Court dated April 13, 2000, granting her primary physical custody of the minor child, Taylor A. B. Dickinson, during the school year. Respectfully submitted, JAMES, SMITH, DURKIN & CONNELLY LLP Date: ff-jL/-O/ " .~" ,-,,;, - ., , ~ ',," '~" ,I, I' ~ j VERIFICATION , i I verify that the statements made in this Pleading are true and correct. I understand that !1 It ;; i, ii false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date, ~./~) 1.rnt ~l~il_LQ.~(n:l icole R. Wishard, Petitioner '" ,'~ ^"n.'~,,,~,,,,,__"~'~""" _~ "'_~ ~"'~__ ,'",- ,- EXHIBIT "A" , '__" ---S",",' "~'" ,'nC:"" ,_'," c', , ~'~.:..I ' .., ',_ ""< NICOLE R. DICKINSON, . IN THE. COURT OF COMMON. PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. : NO. 00-447 CIVIL TERM : JOSEPH S. DICKINSON, : CIVIL AcrION - LAW Defendant : IN CUSTODY OODER OF OOORT . AND NCM, this 13+1-) day of ~),'J consideration of the attached euistody Cone ation and directed as follows: , 2000, upon Report, it is ordered 1. The parties shall submit themselves, their minor Child, and any other individuals deemed neces$ary by the evaluator, to a custody evaluation to be performed by a professional selected by agreement of the parties and counsel. The p~je of the evaluation shall be to obtain independent professional rec ,endations concerning ongoing custody arrangements which will best serve! the interests of the Child. The parties shall sign all authorizations deem~d necessary by the evaluator in order to obtain additional psychological, medical, educational or other additional information concerning the Child. 'The parties shall equally share the cost of the evaluation. 2. Pending further Order of Court or agreement of the parties, the parties agree to continue equally sharing physical custody of the Child under their current arrangement. 3. Upon completion of the custody evaluation: arid in the event the parties are not at that time able to reach an agreement as to ongoing custody arrangments for the Child, ,counsel for either party may contact the Conciliator to schedule an additonal Custody Conciliation Conference. '"''''OM i:!ECQRD TllUl= COFY 1",,' ".,~. hand ,~ -, \ h~re umo S61 my In Testimony whe~eor, ' arlisle Pa. and t~~,7;;t,s:dt~rt at . -,'., .. (1~t-d othof.\otary ~ BY THE COURT, cc: John J. Connelly, Jr., Esquire - Counsel for Mother Linda A. Clotfelter, Esquire.., Counsel for Father - _I NICOLE R. DICKINSON, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-447 CIVIL TERM . . JOSEPH S. DICKINSON, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . CUSTODY CCtiCILIATIClII SUMMARY REPCilT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the u.~dersigned CUstody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Taylor A. B. Dickinson May 17, 1994 Mother/Father 2. A Conciliation Conference was held on March 30, 2000, with the following individuals in attendance: The Mother, Nicole R. Dickinson, with her counsel, John J. Connelly, Jr., Esquire, and the Father, Joseph S. Dickinson, with his counsel, Linda A. Clotfelter, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date ~ ,1' .J..oDt') , o:~ CUstody Conciliator .",,' '''0,;''; ~ ',.f. ~"'_, '''''''-~;,:'''- ',"..y';' -;' --,' . ;',',,',' , "J,--. ;i'e,,=<, u"'-" NICOLE R. DICKINSON, now known as NICOLE R. WISHARD, PlaintifflPetitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLA VNIA v. : NO. 00-447 CIVIL TERM JOSEPH S. DICKINSON, Defendant/Respondent : CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE I, John J. Connelly, Jr., Esquire, of James, Smith, Durkin & Connelly, LLP attorney for the Petitioner, Nicole R. Wishard, hereby certify that I have served a copy of the foregoing Petition to Modify Existing Custody Order on the following on the date and in the manner indicated below: U.S MAIL. FIRST CLASS. PRE-PAID Linda A. Clotfelter, Esquire 3464 Trindle Road Camp Hill, PA 17011 JAMES, SMITH, DURKIN & CONNELLY LLP DATE: g--jJ..}....OJ '. ~ I -","" ",."",t' _~ '-'I" - "'" ~, '" -. .,. ,. .M ~,,"";;',<I".'"";;;"'''.'' "" .". . ;c.: ..". '.'" .' ,."... ..' ~,',~, --'i ,~ -R ~ c--..... (') CJ "- CN ~ c ~~ ;:~' ~":::"I' "- vh~.~ ~... -..j' fTl;', 0\) U\ -"'-"7 -~ "--_ ,c, /,.' i ~ ~ (fJL.: .-J 6- r' <0 -0 ;) ~i(~ I;;'(~ c.) ~ :~ .,.. =< CO C) -i:-t ~ -~; :'-,) ;::"jj :~5 ~:~~ ;~i - - ~~jf,'i NICOLE R. DICKINSON N/KJA NICOLE R. WISHARD PLAINTIFF V. JOSEPH S. DICKINSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-447 CIVIL ACTION LAW IN CUSTODY AMENDED ORDER OF COUR AND NOW, 1l1ursday,August30,2001 , the Original Order of Court is amended as follows, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, September12, 2001 at 1:00 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 define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Isl Dawn S. Sunday. Esq.60 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 HA VB AN ATTORNEY 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 'Illl "d' ;~:: I'iJ :;:~ ;;;t {~:'~;2 ~,~ 1., " CUl\/i~):~~"\L'~-:" \j~:~..J>~TY c'-I '\,('\11 '\11,"'<1;1 t--'C\il\i<')IL;(\I',"\ 1-3/.cJ( twf.. C'~ ~;t, 4 ~~ ~:3/'cJ/ W. ~ ~ $ af t!.~ -r:3/'~r ~./?I~ $ 4~t7 ffl'!! .....,. ~,-, ~.~, . .....,~~ ~ "~_~I"'~~~"'~~WIlll!'llllil!l~~h.._~.."",~,~w" ~"""~~ ,,, - _I ~lo"~"", , NICOLE R. DICKINSON N/K/ A NICOLE R. WISHARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-447 CNIL ACTION LAW JOSEPH S. DICKINSON, Defendant IN CUSTODY ORDER OF COURT AND NOW, this '2 --? d- day of fJ ('J v f2 -., lov- , 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1, The parties shall submit themselves and their minor Child to an updated custody evaluation to be performed by Arnold Shienvold, PhD. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best serve the interests of the Child in light of recent developments. The parties shall sign all authorizations deemed necessary by Dr. Shienvold in order to obtain additional information pertaining to the parties or the Child. 2, Within 60 days of receipt of Dr. Shienvold's written recommendations, counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference, if necessary. BY THE COURT, cc: John J. Connelly, Jr., Esquire - Counsel for Mother Linda A. Clotfelter, Esquire - Counsel for Father ~ ~ J/- Ot,.Of Q-. -0 "'~ -J~<,.lit._ 'J1li11l1Uil1"""'.............~'..;i .~1IliIIiIIUJb~lil.~,~ 1!l<l"","",ii>;J .~ ,I -',," ~" 'v'\NVi\li-SNN3d t \ \'-Jr'\nf"',. Ci\\H--;':'-P~*\-"I" ~'t,.,-" ."" ;,,_,._,.,1,1"-" 1.0 :(j \{~ q.. ';\Vi" \ 1.1 ~, l.....l'-:l" 'j, . -~ ol>l,l'''. ~. ~~ - '" ,- '\;', . ~I NICOLE R. DICKINSON N/KI A NICOLE R. WISHARD, Plaintiff INTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA vs. 00-447 CIVIL ACTION LAW JOSEPH S. DICKINSON, Defendant IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. 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 DATE OF BIRTH CURRENTLY IN CUSTODY OF Taylor A. B. Dickinson May 17, 1994 MotherlFather 2. A Conciliation Conference was held on October 23, 2001, with the following individuals in attendance: The Mother, Nicole R. Wishard (formerly Dickinson), with her counsel, John J. Connelly, Jr., Esquire, and the Father, Joseph S. Dickinson, with his counsel, Linda A. Clotfelter, Esquire. Date 3. The parties agreed to entry of an Order in the form as attached. ~i Dawn S. Sunday, Esquire 9f:J Custody Conciliator o t Pv hvt. d--r/ ~o I _l_. NICOLE R. DICKINSON, NIKIANICOLER. WISHARD, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 00-447 CIVIL TERM JOSEPH S. DICKINSON, DEFENDANT : CIVIL ACTION - LAW : IN CUSTODY PRAECIPE FOR WITHDRAWAL OF APPEARANCE Please withdraw my appearance on behalf of the Defendant, Joseph S. Dickinson, Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Dated: ~/,)..7 /0-;' . . da A. Clotfelter, Esquire ALD. # 7-1- 'l {,_~ 3464 Trindle Road CampHi1lPA 17011-4436 (717) 763-7613 PRAECIPE FOR ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, Joseph S. Dickinson. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: b;Q';/o~ I Susan Kay C PAI.D.#6 98 5021 East . Suite 100 Mechanicsburg P A 17050 (717) 796-1930 . ~'. '~~~lIilI --~"""'''''''''~\lll''';'l..tm;~''"~~''' .' ,,~ " .. - , o C -IJ~ rptL ~ffj (f)): G~~ ~~: ~g ::-:::i _.~ '. <=> N ::-- ~ ;Z N 0:> o 'Tj ,:::1 ;:~l=n -~7m ~-'->O ~J~ sj :X:J ~< -.~ v :Jit c.".1 :::> rV L,~~ '-, NICOLE R. DICKINSON N/K/A, NICOLE R. WISHARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-447 CNIL ACTION LAW JOSEPH S. DICKINSON, Defendant IN CUSTODY ORDER OF COURT AND NOW, this \'2.t\ day of ~t'et ....Lt"r , 2002, upon consideration ofthe attached Custody Conciliation Report, it is 0 dered and directed as follows: 1. AUprior Custody Orders of this Court are vacated and replaced with this Order. 2. The parties shall obtain an updated school psychiatric evaluation of the Child to be performed by a professional selected by agreement of the parties. The Mother shall be responsible to pay all costs of the evaluation. Each party shall cooperate in ensuring that the Child attends any evaluation sessions schednled during his or her periods of custody. 3. The Mother, Nicole R. Wishard, and the Father, Joseph S. Dickinson, shall have shared legal custody of Taylor Dickinson, born May 17,1994. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Both parties shall have equal access to all records pertaining to the Child, including medical and school records. 4. Pending further Order of Court or agreement of the parties, the parties shall share having physical custody of the Child on an alternating weekly basis, with the exchange to take place on Mondays at school. In the event the Child does not have school on a Monday, the parties shall exchange custody at a time arranged by agreement. 5. The parties shall share having custody of the Child on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall nm from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall nm from Christmas Day at 12:00 noon through December 26 at 12:00 noon. In 2002, the Father shall select either Segment A or B as his period of holiday custody and ,.... c.. Jli"""'~ ~b.WM--"!!~I~&~~itl!i!lliWlw.,~~~~~--~~ \/iN\flilASf\lN3d ).. ! 1\1['("('-, '11; il, ,"II j""'-'^f(V'" ""- " "r-',~' .~' '._'\, "::-;::j:j~i\i lJ i I :Z Hd Z I d3S 20 IU\,'l('!",'"", ,', ^;,oI f, :""J'''''' ,.-- - , '.. ..~;.~ ' ;:,~~" /:L .: :.:!~)d..::u"~d,-i 1::/ jO ~ ~ ..... -, ,. ~~ -.- -~ ,"", . "" ~ the Mother shall have custody during the other segment. The parties shall alternate having custody during Segments A and B of the Christmas holiday on an ongoing basis thereafter. B. THANKSGIVING: The Thanksgiving holiday period of custody shall run from after school on the Wednesday before Thanksgiving through Friday at 6:00 p.m. The Mother shall have custody of the Child over Thanksgiving in even numbered years and the Father shall have custody in odd numbered years. C. NEW YEARS: The New Years holiday shall run from New Years Eve at 12:00 noon through the beginning of school after the holiday. For purposes of this provision, the entire New Years holiday shall be deemed to fall in the same year as New Years Eve. The Father shall have custody of the Child for the New Years holiday in even numbered years and the Mother shall have custody in odd numbered years, D. EASTER: The Easter period of holiday custody shall run from the Saturday before Easter at 6:00 p.m.: through the beginning of school after the holiday. The Father shall have custody of the Child over the Easter holiday in even numbered years and the Mother shall have custody in odd numbered years. E. MEMORIAL DAY: The Memorial Day holiday shall run from the Sunday before the holidayiat6:00 p.m. through the beginning of school after the holiday. The Mother shall have custody of the Child over the Memorial Day holiday in even numbered years and the Father shall have custody in odd numbered years. F. JULY 4TH: The Independence Day holiday shall run from July 4th at 9:00 a.m. through July sth at 6:00 p.m. The Father shall have custody of the Child over the Independence Day holiday in even numbered years and the Mother shall have custody in odd numbered years. G. LABOR DAY: The Labor Day holiday shall run from 6:00 p.m, on the Sunday before the holiday through the beginning of school after the holiday. The Mother shall have custody of the Child over the Labor Day holiday in even numbered years and the Father shall have custody in odd numbered years. H. MOTHER'S DAY/FATHER'S DAY: In every year, the Mother shall have custody of the Child over the Mother's Day weekend from Saturday at 6:00 p.m. through the next school day and the Father shall have custody of the Child over the Father's Day weekend from Saturday at 6:00 p.m. through Monday at 9:00 a.m. 1. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 6. Within 60 days of receipt of the results of the school psychiatric evaluation, counsel for either party may contact the Conciliator to schednle an additional Custody Conciliation Conference if necessary at that time. ~ ^ "J -~Wi'" 7. This Order is entered pursuant to an 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, 1. v J. cc: John J. Connelly, Jr., Esquire - Connsel for Mother - Susan K. Candiello, Esquire - Counsel for Father .~ ~ 9-/3.0"L. C).-,. ~".,.: . NICOLE R. DICKINSON N/K/A NICOLE R. WISHARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-447 CNIL ACTION LAW JOSEPH S. DICKINSON, Defendant IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. 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 DATE OF BIRTH CURRENTLY IN CUSTODY OF Taylor Dickinson May 17, 1994 Mother/Father 2. A Conciliation Conference was held on September 3, 2002, with the following individuals in attendance: The Mother, Nicole R. Wishard, formerly Dickinson, with her counsel, John J. Connelly, Jr., and the Father, Joseph Dickinson, with his counsel, Susan K. Candiello, Esquire. Date 3. The parties agreed to entry of an Order in the form as attached. ~-{Jk.-IuA S; ~o, (J..o ~4Jf.'''''~ Dawn S. Sunday, Esqwre Custody Conciliator ,~- ~ r Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NICOLE R. WISHARD (formerly Dickinson) Plaintiff v. NO. 00-447 Civil Term JOSEPH S. DICKINSON Defendant CIVIL ACTION - CUSTODY PRAECIPE TO THE PROTHONOTARY Please withdraw the appearance of Susan Kay Candiello, Esquire and enter the appearance ofTheresa Barrett Male, Esquire on behalf of Defendant. Date: December -5 ,2003 Date: December .3 ,2003 Theresa Barrett Male, Esquire ~.........._"..._~_'".~~ <-"J, .'~~' 'JI~~'lI"&li&1iillI~~-J.."".,.-.j , 'IT ~ , , ~- ~.'~ ~...; h" < '~ (") <;;:) !?? c: w -offi 0 ..; 52f':<:; rq r~:: ~. (") 63> , -,~b ~~; \.0 <~~~ :<:;c' ;t..~ )> ,=-T:::n 20 ::Jl: :1>0 '9, ~2~) . . c: c:)m 2 -. =< .:.;. ""'. en :Xl -<: .