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HomeMy WebLinkAbout00-02037 ,.d~""'-""'"",O'_'~7,_'._' _ .,.O,.~- ,___"__,,n ~ . .... ,~". ,- ,-,'J' -~,~~ ,,,' :.:;.--,;'"_,,, ""-' -",,,-;~ :;'., -J~ - .:. ",'~.;f,,'_~__';"..i_"-'._, -..--,~," -,::.~,,-~= ___i'.-__~'"'~~;'_, -ci GOLDBERG, KATZMAN & SHIPMAN, P.C. Paul J. Esposito, Esquire Supreme Court 10 #25454- 320 Market Street, P.O. Box 1268 Harrisburg, PA ]7108-1266 Attorneys for PlaIntiff SHARON D. SCHWARTZ, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLANDCOUNTY,PENNSYLVAN~ NO. m-;2D3) ~ CMLACTlON - LAW CUSTODYMSITATION RALPH H. SCHWARTZ, Defendant ORDER OF COURT AND NOW, this ,f~t. day of ~,2000, upon consideration of the within ~~plaint, it is hereby directed that the parties and their respective ounsel appear before ~N '5". 'SJrJf)A'1.. f ~1 ' the conciliator, at 3 . ItlN . J-.,tsburtlj fA on the a3rd day ot '(Y\o.~. , 2000, at I: 00 p.M., for a Pre-Hearing Custody (f Conference. At such Conferen e, 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. Either party may bring the child who is the subject of this custody action to the Conference, but the child/children's 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 Administrator Cumberland County Courthouse Fourth Floor Carlisle, PA 17013 (717) 240-6200 cc: Howard B. Krug, Esq. Paul J. Esposito, Esq. 4- to -00 If,t? -C/tJ If- V .~tJ I~--~ h .'~ I . or- ,--I n-, --,t:::i:!(~j: t-'! l"'i !-l" I 1'-,1.. ,~..l~ ",- '" ,<y',,;Oli\RY l'f1 /, PI7 --I~ Pr\ 3: l, I J~' r-u' .., ..-.."-' '".-- ['Y,II'I!'," CU'\"'-"[-'--'! :-\'-1'1 '-.....IV\{ I ~'ili'_.;,...J t,-, '''~ -.....- PENt~SYl:,jf\NI!\ W~~.~$-4~ ~,~~4~ ~~~ ~~~~ .\"....4,_" " _ ,_" _",~"", _ '>"""_~"'_~_=_~' _0' _""""",", "'~_~ - - " ~ -,.. " -. ',"-ri_' .d__ _""_L'~ o~_'~_" -,.._ ,~,,'~--, ~"o' __"__,," : "'---;-"",,,. _" "\"4';,,",,"'" 0"",,,,'""~- ~H--"~" __"."';' SHARON D. SCHWARTZ, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLANDCOUNTY,PENNSYLVAN~ NO. (JO. ,2b 3'7 Co:n:rTv-- RALPH H. SCHWARTZ, Defendant CMLACTlON - LAW CUSTODYMSITATION COMPLAINT FOR CUSTODY 1. Plaintiff is SHARON D. SCHWARTZ, who currently resides at 548 North Enola Drive, Enola, Cumberland County, Pennsylvania. 2. Defendant is RALPH H. SCHWARTZ, who is currently residing at 1845 Hunter Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff seeks primary physical custody and shared legal custody of: Name: Nicholas Oliver Schwartz, DOB: 12/13/91 Present Residence: 548 North Enola Drive, EnoIa, Cumberland County, Pennsylvania The child was not born out of wedlock. 4. The child presently resides with Sharon D. Schwartz, Plaintiff herein, at 548 North Enola Drive, EnoIa, Cumberland County, Pennsylvania. For the past fwe years, the child has lived with the following persons and at the following addresses: 1995 - 6111199 1845 Hunter Drive, Mechanicsburg, Cumberland County, Pennsylvania Plaintiff and Defendant ~--- - -- , -:~ . . ~.. , .' ,;!~--- ~, '-,,' --", ~~- '" _",,~J"-", - - -'-"C-_O"~,;;>'-d,--_;"_; ".." "...c;d..C..>....j'-.. -",-- 6111199 - 1 0/99 1845 Hunter Drive, Mechanicsburg, Cumberland County, Pennsylvania Plaintiff 10/99 - 3/28/00 1845 Hunter Drive, Mechanicsburg, Cumberland County, Pennsylvania Plaintiff and Defendant 3/28/00 - Present 548 North Enola Drive, EnoIa, Cumberland County, Pennsylvania Plaintiff The mother of the child is SHARON D. SCHWARTZ, Plaintiff herein, who is currently residing at 548 North Enola Drive, Enola, Cumberland County, Pennsylvania. She is married to the Defendant. The father of the child is RALPH H. SCHWARTZ, Defendant herein, who is currently residing at 1845 Hunter Drive, Mechanicsburg, Cumberland County, Pennsylvania. He is married to the Plaintiff. 5. The relationship of Plaintiff to the children is that of mother. Plaintiff currently resides with the child. 6. The relationship of Defendant to the child is that of father. Defendant currently resides alone. 7. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the child. 8. The best interests and permanent welfare of the child will be served by the relief ~ -.; '-' , -- ,_'-,.-;_ _' "--;.,,,'_ ._"~ --- - """~,;:;":.;.,;-_o~,}.,:,;;-.::"",;,;"~:-:"--:;,,,-,..,,,"-,,,,, ',:--'i.;j,c":'--i;\'dd.:':;:-,o;';-':j2;:.": ",",""- requested. 9. Plaintiff has not participated as a party, witness or in another capacity or in other litigation concerning the custody of the child in this or another Court. 10. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as a party to this action. WHEREFORE, Plaintiff respectfully requests that the court grant the parties shared legal custody and that primary physical custody of NICHOLAS OLIVER SCHWARTZ be awarded to her. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. By Paul J. po to, Esquire 320 Market treet Post Office Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Plaintiff 41818.1 '<, -<, ",'c. . .'. ,--," -~''--''-~'~'=....'"- , <,' -,,~- > ;'~ " " '~~ ,,- ,-"'" <0"~""'~;":;;'''!.0",id';;';''";,'-;ta;.;;,;;.,,,,-':' "";':"i-W"",ij,';;...-'i"'""", ~;';-'Kv.-k",,"'J:~,"" .c;"'l~~ ' ~, I VERIFICATION I verify that the statements contained in the foregoing COMPLAINT FOR CUSTODY are true and correct to the best of my knowledge, information and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa.C. S. Section 4904 relating to unsworn falsification to authorities. Date: 3/;19/00 ( I ,/,MM)'f 0, j~ SiIAROND. SCHwARTZ ~~.. -~ ~ --' """" . . -',> "i.i'" ~ ."""" -'-~~,< ":-" ~~ ~ ~ v ~ ~ ~ ~ I ___~ -, ,,~ '",.; . -- ~>.' ',..'. ""-;';-,,",~',: ~ 6 ~~ \ \ ~ ~ ~ ~ ~ ~ , ,,~ " , .-~ ^ ,,"'.'- '^' o C :;?~ ~[r; s~~~ r;:~c5 ~s c :z -< -< C> o ~ -~J 'cJ I C..'l , ,-~:! , ,~~. ',-' : ~';C) :~ -(, .: _~ ~ ,_1 tSf.fi ,-4 ::.;>, ::D -< .,- s.? .-J ~ 'I I I I SHARON D. SCHWARTZ, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-2037-Civil RALPH H. SCHWARTZ, Defendant CIVIL ACTION - LAW CUSTODY/VISITATION NOTICE TO PLEAD TO: SHARON D. SCHWARTZ, PLAINTIFF AND PAUL J. ESPOSITO, ESQUIRE, HER ATTORNEY POST OFFICE BOX 1268 HARRISBURG, PA 17018-1268 YOU ARE HEREBY NOTIFIED to file a written response to the attached Counterclaim within twenty (20) days from service hereof or judgment may be entered against you. Respectfully submitted, -....-'" BY: ~ra B. K ug, 19 North F Harrisburg, PA (717)234-4178 1.0. No. 16826 Attorney for Defendant Esquire eet 17102 Date: <f- ;l--;t; ~ Cf) <- y - ~--'.- ", ~ "1 I I SHARON D. SCHWARTZ, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-2037-Civil RALPH H. SCHWARTZ, Defendant CIVIL ACTION - LAW CUSTODY/VISITATION ANSWER AND COUNTERCLAIM TO COMPLAINT FOR CUSTODY 1. Admitted. 2. Admitted. However, Sharon D. Schwartz, left the marital residence with the parties' son without the consent of Ralph H. Schwartz. 3. Denied. The statement speaks for itself, except the residence of the child is not 548 North Enola Drive, but rather 1845 Hunter Drive, Mechanicsburg, Pennsylvania. 4. Denied. Sharon D. Schwartz removed the parties' son without right or Defendant's permission to the residence of Sharon's Mother on North Enola Drive. At all times the child was in the joint custody of both parties until March 28, 2000. In addition, it is denied that Sharon D. Schwartz currently resides at 548 North Enola Drive. 5. Admitted. However, the child resides with Mother only because Father does not want to tear the child away from her, placing the child in between the parties. Mother removed the child knowing this. --',-,' ~~:7:'1 6. Admitted. 7. Admitted. 8 . Denied as a mixed conclusion of law and fact. Since Father has been the nurturer of the subject child throughout the child's life, the child's best interests would be to have Father declared the custodial parent to raise Nicholas with visitation rights for Mother. 9. Admitted. 10. Admitted. WHEREFORE, Defendant requests that this Court grant him primary physical and legal custody of Nicholas O. Schwartz and dismiss Plaintiff's Complaint. COUNTERCLAIM 11. Defendants answers set forth in Paragraphs One through Ten hereof are incorporated herein by reference thereto. 12. Father has, since Nicholas' birth always been very close to his son. 13. Throughout the child's life, there has been a nurturing relationship between Father and son. 14. It is in the best interest of Nicholas to have Father raise and continue to nurture his son. 2 ,- - ",,"-,~','-,> '"-'Y - =', ~ ~f WHEREFORE, Defendant requests this Honorable Court to grant him exclusive legal and physical custody of Nicholas with liberal visitation rights of Mother. Respectfully ront Street urg, PA 17102-2392 Telephone No. (717) 234-4178 1. D. No. 16826 Attorney for Defendant 3 "cc' ,'~ , "' ,;.-" _k,l"",-" d- , ,.'.'- "' ----d_'__',~__." 1 VERIFICATION I, RALPH H. SCHWARTZ , hereby verify that the facts contained in the foregoing ANSWER & COUNTERCLAIM are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 6(~itt~.~ DATE: 9- 2$-00 , --~--" " , ~-,,-,-~ 1"''';.<" ""^""-<__ .'",,' ~'-,,',,_ :i>_:'"o'- ,- '--; SHARON D. SCHWARTZ, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-2037-Civil RALPH H. SCHWARTZ, Defendant CIVIL ACTION - LAW CUSTODY/VISITATION CERTIFICATE OF SERVICE I, ANGELA S. EATON, an employee of the law firm of Purcell, Krug & Haller, counsel for Defendant, hereby certify that service of the attached ANSWER & COUNTERCLAIM was made upon the following by placing a copy of same in the United States Mail, first class mail, postage prepaid, Dauphin County, Pennsylvania, on Paul J. Eposito, Esquire 320 Market Street PO Box 1268 Harrisburg, PA 17108-1268 LktL~Li. S~~ON - - ,," - ":~, GOLDBERG, KA'1'ZMAN & SHIPMAN, P.C. Paul J. Esposito - I.D. #25454 Attorneys for Plaintiff 320E Market Street Strawberry square P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 SHARON D. SCHWARTZ, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RALPH H. SCHWARTZ, Defendant NO. 00-2037 civil CUSTODY/VISITATION ACCEPTANCE OF SERVICE I, Howard B. Krug, Esquire, hereby accept service of the Complaint for Custody in behalf of Ralph H. Schwartz, Defendant in the above-captioned action, and acknowledge , ESQUIRE do so. Date: 4-/"/00 llillm_i'"'~ ,~ -....:...;;.1-,. ~d "..."~,,,,-,,,,,"--,,,~-,,,,,,,,,,,~~ ~-- ~ -do ,,,__.. od,-" ".,'i"". <'",'~,""', ~ ,'" - 'ff', ,...,,_~", ,-, . ,- ~ - ,~ c: ----;: " n-\' ~i':, (~I:: :-- \~,f ,~ .~2~ F ." ~.. ! ~-_\ n ,_,__ <"'.",~c- ~-, -,- >^- ".."- ,..;-, '",'",;C- ,-",", c( -.,--", ,,,;,~-,--,, "","'.~_"'"""" ';c---",''- ~ .,0.", ,c'( s' f GOWBERG, KATZMAN & SHIPMAN, P.CO Paul J. Esposito, Esquire Supreme Court lD #25454 320 Market Street, P.O. Box 1268 Harrisburg, PA 17108.1268 Attorneys for Plaintiff SHARON D. SCHWARTZ, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN~ v. NO.00-2037-CMl RALPH H. SCHWARTZ, Defendant CMLACTION - LAW CUSTODYMSITATION REPLY TO COUNTERCLAIM AND NOW, comes Plaintiff, Sharon D. Schwartz, by and through her attorneys, Goldberg, Katzman & Shipman, P.c., and Paul J. Esposito, Esquire, who responds to the Defendant's Counterclaim as follows: 11. Requires no response. 12. Admitted. 13. Admitted; however, Plaintiff has been the primary nurturing parent since Nicholas' birth. 14. It is admitted that Defendant should be involved in the raising of Nicholas. However, given the fact that the parties and Nicholas will no longer be residing in the common household, Plaintiff believes that Nicholas' best interests will be served by remaining in Plaintiffs primary custody. WHEREFORE, Plaintiff reiterates her request that she be granted primary ,-- '-,h i<,-"""~<,, ,'x",,",", c. ,v, " 'l, -_ . _- .. _>! ,,_ -", , ,-, _,~'O_,,~' , ,"',.." ~~,"k3, -,,',,~-,~, "i,,-~,,;;;.~~.i^~,;':;,;,6',; ",_,;,--:-c;" "--"''':1 physical custody and Defendant be granted temporary physical custody of Nicholas. Respectfully submitted, GOLDBERG, KATZMAN &- SHIPMAN, P.c. By P~CHllRE 320 Market Street Post Office Box 1268 Harrisburg, PA 17108-1268 Supreme Court 10 #25454 Attorneys for Plaintiff ~. _ _ ~"H ",',,"-,-' .. ,,"'__ - "'"' ~:."b,"O_~"~>-<__,, ~,;",;.,:; '-~ ~"~- _~ _'~"__ "'''i~,",'C'';,"--'~- -L., .,ice '~" ,'"," , , VERIFICATION I verifY that the statements contained in theforegoingREPL Y TO COUNTERCLAIM are true and correct to the best of my knowledge, information and belief I understand that false statements contained herein are made subject to the penalties of18 Pa.C.S, Section 4904 relating to unsworn falsification to authorities. Date: 51/1/0Q , Altm --rnJ 9J. x:b1J.l Ja i:~r SHARON D, SCHWARTZ - ' '" <,-, ,~- , --,,-,', ;)~-, 'c. ',"_''', '10' '-'>__ -',,--' " "';, --, ,'",-, .;,;'-" ~,t:'k.~'-'.;:.i..::.",,:-:",/,, ~. "":'~"::-ci,::"~,..,;,,,,;;;- ':.- ;~,' '::o~::;: , -- ~~~-~-- , , CERTIFICATE OF SERVICE On this 17th day of May, 2000, I certify that a copy of the foregoing REPLY TO COUNTERCLAIM was served upon the following counsel of record for Defendant by placing the same in the United States mail, first class, postage prepaid, addressed as follows: Howard B. Krug, Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 GOLDBERG, KATZMAN & SHIPMAN, P.c. ~~'Rf 320 Market Street Post Office Box 1268 Harrisburg, PA 17108-1268 Supreme Court 10 #25454 Attorneys for Plaintiff ~-' Ji'~ ~ ; - ~ '" , ,Iti*'-'" " -~""-"" _li~~- ~"~,. , ~'.-;- ,-0.0-, ,," ~- ",__', ~_rl 0 C-::Y C) s: C) n :", U CU ::;"= Q} f.'i:-: -< ~-; ~-- :"f1 (:~:: Co i-:J ~,..~ --, r ',..> , -c <oJ ..'OJ ,. ~ i 5; (-.) -- .. ':-) ):; () ~~\.) "'1"1 ~;~; -~~. ::=1 ;:- ~T."" ~Q -< (-.) -<. _1 - c ,., c "," . SHARON D. SCHWARTZ, : Plaintiff . . . . vs. . . . . : RALPH H. SCHWARTZ, . . Defendant . . IN THE roURT OF roMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-2037 CIVIL TERM CIVIL ACTION - LAW CUSTODY 8 s: -om mrn ~:1:! ~~ :< CJ -u ~o :::ll: 200or~n~',' is or ed; o o :JI: :>'0 -< W ~ ~-: aIDER OF <XXlRT AND lDl, this 3\-;'.* consideration of the attached and directed as follows: day of 2 , CUstody COncili tJ.on Report, it 1. The Mother, Sharon D. Schwartz, and the Father, Ralph H. Schwartz, shall have shared legal custody of Nicholas Oliver Schwartz, born December 13, 1991. 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. 2. The parties shall have physical custody of the Child in accordance with the following schedule: A. During the school year, the Father shall have custody of the Child on alternating weekends, beginning June 26, 2000, fran Friday at 5:30 p.m. through Monday morning when the Father shall take the Child to school or return the Child to the Mother's residence if the Child does not have school. During weeks following the Father' s weekend period of custody, the Father shall have custody of the Child from Thursday at 5:30 p.m. through Friday morning when the Father shall transport the Child to school or to the Mother' s residence if the Child does not have school. During weeks following the Mother's weekend period of custody, the Father shall have custody of the Child fran Monday at 5:30 p.m. through Tuesday morning when the Father shall transport the Child to school or to the Mother's residence if the Child does not have school. The Father shall also have custody of the Child during each bi-weekly period for 1 additional evening fran 5:00 p.m. until 8:00 p.m. upon providing at least 3 hours advance notice to the Mother, with the specific evenings and times to be arranged by agreement of the parties. The Father may have custody of the Child at any other times agreed upon by the parties. The Mother shall have custody of the Child during the school year at all times not otherwise specified for the Father under this provision. . The school year custody schedule shall begin each Fall with the Father having custody of the Child on the first weekend after the school year begins. B. During the Summer school break each year/ each party shall have physical custody of the Child on an alternating weekly basis, with the exchange of custody to take place every Sunday evening at 6:00 p.m. The Mother shall also have custody of the Child during the Sununer school break during the Father's custody weeks when the Father is working. The Summer schedule shall begin with the Father having custody of the Child beginning on the first Sunday after the termination of the school year. The Summer custody schedule shall end on the last Sunday/ with at least one week remaining before the start of the new school year. The school year custody schedule shall resume with the Father having custody of the Child on the first weekend after the school year begins. 3. The parties shall share or alternate having custody of the Child on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A/ which shall run fran Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon/ and Segment B/ which shall run fran Christmas Day at 12:00 noon through December 26 at 12:00 noon. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. The Father shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. The parties shall equally share having custody of the Child for the remainder of the Christmas school break, with the Father selecting his preferred half of the school break in even numbered years and the Mother selecting her preferred half of the school break in odd numbered years. B. THANKSGIVING: The Thanksgiving holiday shall be divided into Segment A/ which shall run from the Wednesday before Thanksgiving after school through Friday at 7:00 p.m. and Segment B/ which shall run fran the Friday after Thanksgiving at 7:00 p.m. through the following Monday at 7:00 p.m. The Father shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. The Mother shall have custody of the Child during Segment A in odd numbered years and during Segment in even numbered years. C. EASTER: The Easter holiday shall be divided into Segment A/ which shall run fran the Saturday before Easter at 12:00 noon through Easter Sunday at 12:00 noon/ and Segment B/which shall run from Easter Sunday at 12:00 noon through the following Monday at 12:00 noon. The Mother shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. The Father shall have ~ ~, ~~ " "~ '. .' custody of the Child duJ;"ing Segment A in even numbered years and during Segment B in odd numbered years. D. MEMCIUAL DAY/LABOR DAY: In even numbered years, the Father shall have custody of the Child on Memorial Day and the Mother shall have custody on Labor Day. In odd numbered years, the Mother shall have custody of the Child on Memorial Day and the Father shall have custody on Labor Day. The periods of custody under this provision shall run from 10:00 a.m. through 7:00 p.m. on the holiday. E. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year or! Mother's Day from 10:00 a.m. until 7:00 p.m. and the Father shall have custody of the Child every year on Father's Day from 10:00 a.m. until 7:00 p.m. F. In the event a holiday custody period falls immediately before or following a party's regular period of custody, the period of regularjholiday custody shall run continuously. G. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 4. Unless otherwise agreed by the parties, the Father shall be responsible to provide transportation for all exchanges of custody. 5. In the event either party is unavailable to provide care for the Child during his or her periods of custody under this Order for an overnight period or longer, that party shall first contact the other party to offer that party the opportunity to provide the care before contacting third party caregivers. 6. 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, iL{ o ~ &-/-0 R}{S J. cc: Paul J. Esposito, Esquire - Counsel for Mother Howard B. Krug, Esquire - Counsel for Father '. ~ "~ ~ " _ '__ ,_J, ~ ,~ '" i"".--+ - "~-'_.l. "", SHARON D. SCHWARTZ, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . NO. 00-2037 CIVIL TERM . . . : CIVIL ACTION - LAW RALPH H. SCHWARTZ, : Defendant . CUSTODY . CUSTODY <niICILIATIOO SUMMARY REPCRr IN Acccm>ANCE WITH CUMBERLAND CXXlNTY 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 Nicholas Oliver Schwartz December 13, 1991 Mother 2. A Conciliation Conference was held on May 23, 2000, with the following individuals in attendance: The Mother, Sharon D. Schwartz, with her counsel, Paul J. Esposito, Esquire, and the Father, Ralph H. Schwartz, with his counsel, Howard B. Krug, Esquire. 3. To their credit, the parties were able to reach an agreement at the Conference as to ongoing custody arrangements. The Mother acknowledged at the Conference that she was planning to rove to Boiling Springs around the end of the school year and, after much discussion, the Father confirmed that he would not challenge the Mother I s rove or enrollment of the Child in the Boiling Springs School District. 4. The parties agreed to entry of an Order in the form as attached. Dat~ ,;) ~ ,;).coO Da'1~~ CUstody Conciliator