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HomeMy WebLinkAbout00-02414 ,.... "~~ _u ~ .. [Um\ LISA CHRISTOPHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYJLV ANIA V. CIVIL ACTION - LAW J1J-o-v" ~4.r 4- ~ REBEKAH S. CHRISTOPHER,: NO. JOHN CHRISTOPHER, III, Defendants : IN CUSTODY ORDER OF COURT ofL I/. ' I AND NOW, this /1 day of ' ~' ,2000, upon consideration ofthe attached Custody Complaint, it IS hereby direyted that the parties and their respective counsel shall appear before I'IrJAl S. )v..d, ~ , the Conciliator, at 3q IV JV!Au) >1" " c 5 {JA.<.A on the 13th day of Jl.I!U... ,2000 at 3'.OD o'clockp. m., for a re-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 ~ COURT, BY: Y__J >. <2 ~- ~ Custody Conciliat~? ' {~ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 mU&t 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 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, P A 17013 (717) 249-3166 ,~^" "~ ~ --~ - "'~ ,-"_,,,_ .-~ ~, ,-..-. .1 ."""- '_, 8.;' , "-,,~ ,,',:;"~ ,"", ">;'~''''"'~-'I~C1''I'i'i''~ .,,"',~ "'-1"1"'11>11" iii"" -",ru. i'"":"'{;(""~" - ';;.!,',""c,'---, ",~_"i;,-':',)'''-,'\'..tc~.;c~I__'-' ;. ,.~ .~.... II ._1.__ _ OF :1 ---'J,-' .EJ'-CrT!~=:r: '~'~i!'!~~Tl\H,{ ~o -~"'"f'1; ,.., "'I " r"'" " L.' ';i 1\ (,(,.. p :.~; ""',": ? ~~ . .. ,~ '._v C1 j'-~l-"": -' - ',' - ("_,--'" _->-/ IUJViL'":,'''r 'L'~',"! : , !U'i !'\~ J \, '-- , " "'~-' '.~ wi.! PEf\lNSYL\0'\i\lI/\ tf'Jo,C}:J &d. e~ ~ ~ if ~ JI--dC),C):;) 7!~ ~ ~ ~ 4t-.;lZ) 'CJtJ ~ ~ ~ a1 ~~ ~ .......,"'...' . ,""..... __?_~,..lf]~ "''''t'>>'-'''. I ,-L,~1\Om~_!llhR'~f"'J'Jf'IID'ilW1lJ~~4f\1~m~!f!'il'lI!'l.'IIIl! 1" )1 Q,'____, ~~?; .- ~o~~w"'" ]t" LISA CHRISTOPHER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA V. REBEKAH S. CHRISTOPHER, JOHN CHRISTOPHER, III, Defendants : CIVIL ACTION - LAW : NO. 01;- ~ 'IN ~ I~ : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Lisa Christopher, by and through her attorney, Jacqueline M. Verney, Esquire and represents the following: 1. Plaintiff is Lisa Christopher, who resides at 430 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania, 17013. Plaintiff has standing to bring this complaint based on 23 Pa.C.S.A. S 5313 (b) (1), (2), and (3). Plaintiff has acted in loco parentis of the child for more than one year. 2. Defendants are Rebekah S. Christopher, natural mother, who resides at 2044 Green Street, Harrisburg, Dauphin County, Pennsylvania, 17..0 and John Christopher, III, natural father, whose address is 3649 A. Derry Street, Harrisburg, Dauphin County, Peunsylvania, 17111. 3. Plaintiff seeks custody of the following child: NAME PRESENT ADDRESS AGE Alleshia Christopher 430 S. Pitt St. Carlisle, P A 17013 DOB 2/12/92 Age 8 The child was born out of wedlock. The child is presently in the custody of Lisa Christopher, who resides at 430 S, Pitt Street, Carlisle, Cumberland County, Pennsylvania. - ". ~ ~"" i1L"-'" During the past five years, the child has resided with the following persons and at the following addresses: LIST ALL PERSONS Lisa Christopher, Jameson Christopher John Christopher, III, Rebekah Christopher, Alexandria Christopher, Adrienne Christopher, and John Christopher, IV Same as above Same as above John Christopher, III, Rebekah Christopher, Alexandria Christopher ADDRESSES 430 S. Pitt St Carlisle, P A 17013 Ronca St. Carlisle, PA 17013 Allen Drive Carlisle, PA 17013 North Carolina West & K. Streets Carlisle, PA 17013 DATES March 1999- Present 1998-3/1999 1998-1997 1997 1997-1995 The mother of the child is Rebekah Christopher, currently residing at 2044 Green St, Harrisburg, Pennsylvania. She is divorced. The father of the child is John Christopher, III, currently residing at 3649 A. Derry St, Harrisburg, Pennsylvania. He is divorced 4. The relationship of Plaintiff to the child is grandmother. The Plaintiff currently resides with: NAME Jameson Christopher Alleshia Christopher RELATIONSHIP son granddaughter - ~~ ".~ , ~Ik~-: 5. The relationship of the defendant, Rebekah Christopher, to the child is mother. The defendant, Rebekah Christopher, currently resides with: NAME RELATIONSHIP Alexandria Christopher AdrielU1e Christopher John Christopher, IV daughter daughter son The relationship of defendant, John Christopher, III to the child is Father. The Defendant, John Christopher, III, currently resides with: NAME RELATIONSHIP Jennifer Zulli JayolU1a Pope girlfriend girlfriend's daughter 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody ofthis rninor child in this or another court. Plaintiff has information of a custody proceeding concerning the child in the Court of Common Pleas of Cumberland County, PelU1sylvania at No. 99-2084. A copy of the Stipulation For Custody, dated May 19, 1999, is attached hereto as Exhibit "A". 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 because: a. The plaintiff has been the primary caregiver ofthe child since March, 1999. _.~.~- ~ " ,~~ - ~~~. ~--" ~, '" , ~3, b. The plaintiff has acted in loco parentis of the child since March, 1999. c. The child has attended Carlisle school since living in the home of Plaintiff and to remove her now would be detrimental. d. Plaintiff has genuine care and concern for the child. e. Both parents consented to the plaintiff having care and custody of the child since March, 1999. f. Mother has visited with the child only four times in one year. g. Plaintiff can provide a loving, nurturing, safe, environment and home for the child. 8. 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 parties to this action. WHEREFORE, plaintiff, paternal grandmother of the child requests the court to grant legal and primary physical custody ofthe child to plaintiff. Date: if-I 1./ -0 0 Respectfully submitted, ~e~:~ 44 South Hanover Street Carlisle, P A 17013 Supreme Ct. ID 23167 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Complaint 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. Dated: 4 -( L( -(j() - -,. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTYPENN&YL~ . c . ~ ~ ~ : NO. 99- 2084 CIVIL ~ ~ i,~Fn : ~~ 'D 3~ : IN CUSTODY ~t.:I -0 j~"; ~O :x g~ ~g ~ S? , STIPULATION FOR CUSTODY ~ r;; ~ STIPULATION made this /9':i. day of May, 1999, between Rebekah S. Christopher, hereinafter referred to as Mothe , and John Christopher, III, hereinafter referred to as Father. REBEKAH S. CHRISTOPHER, Plaintiff v. JOHN CHRISTOPHER, ill, Defendant WHEREAS, the above-named Mother and Father had born to them the following children on the following dates: NAME Alleshia Christopher Alexandria Christopher Adrienne Christopher John Christopher, IV BIRTH DATE February 12, 1992 July 26, 1995 November 25, 1996 November 24, 1997 AND WHEREAS, the above-named Mother and Father desire tdenter into a Stipulation as to the custody of the above-said children and to the visitation rights of the non-custodiai parent NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. The Mother and Father shall have shared legal custody of the children. 2. The Mother shall have primary physical custody of the children. 3. The Father shall have periods of partial physical custody: a. The Father shall pick-up the children at daycare each Wednesday at 5:30 p.m. and retum them to daycare on Friday at 8:30 a.m.. b. The Mother shall deliver the children to the Father's residence at 10:00 a.m. . every other Saturday, and Father shall retum the childran to de:yoars at 8:30 a.m. the following . Monday. 4. Mother and Father will arrange for custody of the children on HolidayS by mutual agreement. TO THIS PURPOSE, The parties hereto intenl;! to, be legaIlY/bOU~~~'Y e tjlrms of this Stipulation and desire to have the Stipulation eIItet'efas1n O,ttler Coort. .--l , / I I. If t i "j, , . ! ,1/ j ,,:/ h I / /1 r;I" ~'/ '/ ,I.' " . l ~ Witness: i r./~ " Ii, i l Rebeka S. cnri~topher, Mot r .1, ~: .' ._.....-...-/ . /. ,., / .,'./...;..: --~-- .., ,..?JLl'A1~~ ." /' .0' L.if{dsay Dare Baird, Esq. John Clyist er, III, Fat I -' o or:: " .4 II /C.-)( ~- , LISA CHRISTOPHER, PetitionerlPlaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA V. : CIVIL ACTION - LAW REBEKAH S. CHRISTOPHER, : NO. 2000- 2414 CIVIL TERM JOHN CHRISTOPHER, III, Respondent/Defendant : IN CUSTODY ORDER OF COURT AND NOW, this / ~ ~ of..d~. L , 2000, following consideration of , Petitioner's Emergency Petition, it is hereby ordered that a hearing is scheduled for the ~'I~ day of L!y1L/ '- ,2000, at": DO A . m. in Courtroom No. S of the Cumberland County Courthouse, fourth floor, Carlisle, Pennsylvania. J. GI4HI44I $. t: 14" tltJ~ .;;: ~'~-:.<)"""~~,,I , <- - ._~ "'0 !D',-~ ".,.lU.....~ ~, ,~ , ,'~ n .J_~:J!I_ ,~ . - '-'~ , ~" , -<f ~" -~ --~- -'"'~~= . ..-~~< = -" '- -,'" I ",!:~~:r:i,..RY nrJ fn:~ 1 ') .- l... " i ,', I t.~ , n I ,1-):1 U; I.' I '. C' 11,<,:". , .' ", U,vlUl ",1 "I"',' ,,',I 'Nrrv. . .. '~J \ ,'- u'}l 'j i/ r PEiI!NSYL\I/V~iK p..w.~ ~ !n:, ~'J~~ ~ N.u~ -\0 Reb~~ <rd j.,h~ CJ.\~'L-;'~ ." ]. - ~ ~~.., _ _J.).,JI,\I~~~~'~'!!j(~~i!ll~~~ ._,. ~'~"', ",~ - , ,-: - " ,~" -.~-I LISA CHRISTOPHER, Petitioner/Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA V. CIVIL ACTION - LAW REBEKAH S. CHRISTOPHER, : NO. 2000- d. '11'1 CIVIL JOHN CHRISTOPHER, III, Respondent/Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ of APL4' L , 2000, following consideration of . the Emergency Petition and pending the conciliation conference, it is hereby ordered as follows: I. The parties, Lisa Christopher, Rebekah Christopher and John Christopher, III, shall have shared legal custody of Alleshia Christopher, DOB 2/12/92. 2. Petitioner, Lisa Christopher, shall have primary physical custody ofthe child. John Christopher, III is ordered to return the child to Petitioner immediately. 3. Respondents shall have periods of partial physical custody of the child on alternating weekends if requested. 4. Transportation shall be provided by the Respondents. BY THE COURT: J. . " II ~, LISA CHRISTOPHER, Petitioner/Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA V. CIVIL ACTION - LAW REBEKAH S. CHRISTOPHER, : NO. 2000- .2'11Y JOHN CHRISTOPHER, III, RespondentJDefendant CIVIL : IN CUSTODY EMERGENCY PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 AND NOW, comes the petitioner, Lisa Christopher, by and through her attorney, Jacqueline M. Verney, Esquire, and represents the following in support of her Emergency Petition for Special Relief Pursuant to Rule 1915.13: I. The Petitioner is Lisa Christopher, who resides at 430 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania. 2. Petitioner has standing to bring this Petition based on 23 Pa.C.S.A. S 5313 (b) (I), (2), and (3). 3. The Respondents are Rebekah S. Christopher, who resides at 2044 Green Street, Harrisburg, Dauphin County, Pennsylvania and John Christopher, III, who resides at 3649 A. Derry Street, Harrisburg, Dauphin County, Pennsylvania. 4. The Respondents are the natural parents of Alleshia Christopher, DOB 2/12/92. 5. Petitioner is the grandmother of Alleshia Christopher, the subject of this Emergency Petition, who has had physical custody of the child and has acted in loco parentis of the child since March, 1999. " """ ~ ~ ~~~H ~ 6. On April 9, 2000, Respondent, John Christopher, III, removed the child from Petitioner and has refused to return the child to Petitioner. 7. The child attends school in the Carlisle School District. Father failed to take the child to school on Monday, April I 0, 2000, but has transported the child to school the remainder ofthe days. 8. The removal of the child from the home of the Petitioner has disrupted the child's education and caused an emotional trauma to the child. Petitioner has been the sole contact with the child's school since March, 1999. 9. The child has lived with Petitioner since the Respondents separated in March, 1999. The Respondents, however, executed a Custody Stipulation providing for Rebekah Christopher to have primary physical custody of the child. Said Custody Stipulation is attached hereto as Exhibit "A". 10. Respondent Rebekah Christopher has not had physical custody of the child since March, 1999 and has only visited with the child approximately four times in the past year. II. Neither parent has shown an interest in the physical, emotional, religious, medical or educational needs of the child since March, 1999. 12. Petitioner has filed, contemporaneous with this Emergency Petition, a Complaint For Custody. A custody conciliation conference has not been scheduled pursuant to the Custody Complaint and may not be scheduled for approximately four weeks. ~ <-~ 9'," 13. Petitioner believes it is critical to the physical, emotional, and educational well-being of the child that the child be returned to Petitioner pending the resolution of the Custody Complaint. 14. Petitioner has provided a loving, nurturing, stable, safe environment and home for the child for the past year. 15. The child has friends and relatives in Carlisle and removing her from the home of Petitioner has adversely affected her emotional well-being. 16. It is in the best interests of the child to remain with Petitioner pending the conciliation conference. 17. It is unknown whether Respondents are represented by counsel. A draft of this Petition has been sent to the parties prior to filing. Wherefore, Petitioner requests this Honorable Court enter an order granting shared legal custody to the parties and primary physical custody of the child to Petitioner with periods of partial physical custody as requested by Respondents on alternating weekends. Respectfully submitted, i.f -I <{ -() d Ih, c eline M. Verney, Esquire # 2 67 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Petitioner .--. - -- ." "a::r.~~i'i '. VERIFICATION I verify that the statements made in this Emergency Petition 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. Dated: /1 -{ If -(f1) ~a/ 4/.. !~il5ky;h /J LI A CHRIST PHER - ,-- , ~ -- - '. REBEKAH S. CHRISTOPHER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENN~YLW.~ : z ~ .~ : NO. 99-2084 CIVIL T~ ~ ?~~~ &5 5:. \..0 .~3 L ,,<:.;:.,"",9 c: Ci -0 :I::, ~ ~ '",J" :2: 0- :::r: '::..~ C) 6:0 _..'\ brn )>r-. ..... ._1 Z .,- ~ =< W -< STIPULATION made this /<1:; day of May, 1999, between Rebekah S. Christopher, hereinafter referred to as Mothe , and John Christopher, III, hereinafter referred to as Father. v. JOHN CHRISTOPHER, III, Defendant : IN CUSTODY STIPULATION FOR CUSTODY WHEREAS, the above-named Mother and Father had born to them the following children on the following dates: NAME Alleshia Christopher Alexandria Christopher Adrienne Christopher John Christopher, IV BIRTH DATE February 12, 1992 July 26, 1995 November 25,1996 November 24, 1997 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said children and to the visitation rights of the non-custodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. The Mother and Father shall have shared legal custody of the children. 2. The Mother shall have primary physical custody of the children. 3. The Father shall have periOds of partial physical custody: a. The Father shall pick-up the children at daycare each Wednesday at 5:30 p.m. and return them to daycare on Friday at 8:30 a.m.. b. The Mother shall deliver the children to the Father's residence at 10:00 a.m. Q,\/Q,nl nthp... ~"::Iturd~y '.:3in.... I=,=,'thl=llr" eh~" "-Cl"U"" 'h.o r-hilrlro!'"t f..... d..':'''.....o:-e ~t p..~o ... n"! thn -f.....!I"'V!ir"lrc -'-'J .....~-._, '-''-'. , ~', ........ . ......_, ....:_,. l,-"t .., ...-..... ,-"".."" ........-..; Co:.............. 0.. ""...... 0..... ...1... ,V.,... ~...~ Monday. 4. Mother and Father will arrange for custody of the children on Holidays by mutual agreement. ... TO THIS PURPOSE, The parties hereto in, tend t~. be. legallY, !bOUP~Y.- ~ e t, erms of this Stipulation and desire to have the Stipulation ~rltete~fas ~n Offjer ff Co,~rt. .~. . h' I /'!~ /; ., .' /' " , ! t,l ,I! ,0/ /"., / ,/') ) , ! 1/ j f/'. 1"1 ct'/;'. I 'J :. "( aL' '_ ' - ': Witness: i /t;vtlJ1/ I>v 4 iI.YJ I j ~ Rebekah'S( christopher, Mot~r /1 i ;:.> / L i '~4'" ',/iVl ~~ John Christ her, III, Fato.er-';' / _/ --: . /-..,-'~ /] /;?),t[/Mt:.~~ \.if1dsay Dare Baird, Esq. '.~'~.:.~/7 !/i-x "4: Ii "'-"i . -... LISA CHRISTOPHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. REBEKAH S. CHRISTOPHER, JOHN CHRISTOPHER, III, Defendants CIVIL TERM - LAW NO. 2000-2414 CIVIL TERM IN RE: CUSTODY ORDER OF COURT ./ AND NOW, this 24th day of Apri~, 2000, the Respondents having failed to appear, it being related to the Court that the child is back in the custody of the Petitioner, it is ordered and directed as follows: 1. The parties, Lisa Christopher, Rebekah Christophe~, and John Christopher, III, shall have shared legal custody of Alleshia Christopher, DOB: 2/12/92. 2. Petitioner, Lisa Christopher, shall have primary physical custody of the child. 3. Respondents shall have periods of partial custody as agreed upon between the parties. This is a temporary order which we will review on an emergency basis upon petition by any party. This matter By ~ ~\JY DO \j( ~,~~~ is to proceed through the conciliation process for the entry of a permanent order. Edward E. Guido, J. , .,. ,~lI'I ~ -~- -~- ~" , ,''','''''"'.J"', , ~ ~- 'I c-" , -J-.i ':; ") Cf I"~ ,'\ \ i; ~ ,1 .1 \-\':\ \c~\;'i:\0;j~J \{~j}~i<i,( ~rv,'Iil'IllII~_ ........../ IHI_ ~ ~~-- , ..~ Jacqueline M. Verney, Esquire For the Plaintiff :lfh -~ <'l!" ~ . ., LISA CHRISTOPHER, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-2414 CIVIL TERM . : REBEKAH S. CHRISTOPHER, . CIVIL ACTION - LAW . JOHN CHRISTOPHER, III, : Defendants . IN CUSTODY . ORDER OF COURT AND NCIIJ, this J,,;r day of ~ upon consideration of the attached CustOdy Conciliation ordered and directed as follows: , 2000, Report, it is 1. The prior order of this Court dated April 24, 2000 is vacated and replaced with this order. 2. The Paternal Grandmother, Lisa Christopher, shall have legal custody and primary physical custody of Alleshia Christopher, born February 12, 1992. 3. The Mother, Rebekah S. Christopher, and the Father, John Christopher, III, shall have partial physical custody of the child as arranged by agreement of the parties. 4. Lisa Christopher shall make a reasonable effort to keep the Father and Mother informed as to any significant medical, educational and social developments concerning the Child. cc: Jacqueline M. Verney, Esquire - Counsel John Christopher, III, Father Rebekah S. Christopher, Mother for Paternal Grandmother J. ~~ t~.~1-DO ~(? Edward E. Guido, ill I , I i'-t. ._ I .. ,-~= ~''''''- I=~ ~~ ~,' ,~ ~~ 26 j:\;; ~i: II~ (':Ur' j',"C, , t,,' !\ITV .....- \"..."._lll_'"'., --_',.JL", I i}EI~t\:SYLVAr~IA . ~ ~~~llftl.~'"'I7,)c,_",1!!!l -~~,.~- .,__.." _'" ,JIIlIIll; --'-' .. .' ' '. . ~ LISA CHRISTOPHER, : IN THE mURT OF OOMMON PLEAS OF Plaintiff : CUMBERLAND COlJNTY, PENNSYLVANIA . . vs. . NO. 00-2414 CIVIL TERM . : REBEKAH S. CHRISTOPHER, . CIVIL ACTION - LAW . JOHN CHRISTOPHER, III, : Defendants . IN CUSTODY . PRIeR JUDGE: Edward E. Guido CUSTODY CD!lCILIATIOO SUMMARY REPORT IN Aco::m>ANCE WITH CUMBERLAND COONTY 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 Alleshia Christopher February 12, 1992 plaintiff/Paternal Grandmother 2. A Conciliation Conference was held on June 13, 2000, with the following individuals in attendance: The plaintiff/Paternal Grandmother, Lisa Christopher, with her counsel, Jacqueline M. Verney, Esquire. The Mother, Rebekah S. Christopher, who currently lives in California, did not attend the Conference or contact the Conciliator. The Father, John Christopher, III, who currently resides in Carlisle, Pennsylvania, did not attend the Conference or contact the Conciliator. 3. The Grandmother's counsel indicated that both Defendant parents were served with notice of the Conciliation Conference. The Paternal Grandmother advised the Conciliator that she spoke to both the Mother and the Father prior to the Conference and was advised by both parents that they did not intend to attend. 4. This Court previously entered a Temporary Order on April 24, 2000 granting the Paternal Grandmother primary physical custody of the Child with periods of partial physical custody to both parents as agreed upon between the parties. The Court also ordered that the matter should proceed through the Conciliation process for the entry of a permanent Order. 5. The Paternal Grandmother stated that the Child has resided with the Grandmother since March 1999 by agreement of both parents and the ."~-. .. ." . ~ . , Grandmother. The Grandmother indicated that the Mother has visited with the Child 4 times since March 1999 and the Father, who has custody of the parent's 3 other children, contacts the Grandmother on a more regular basis to make arrangements for partial custody. 6. Based upon the representations of the Grandmother at the Conciliation Conference, the events leading up to the entry of the Emergency Temporary Order on April 24, 2000, and the fact that neither the Mother nor the Father attended the Conference or contacted the Conciliator, the Conciliator recommends an Order in the form as attached. 7. It should be noted that as the Mother has not provided her address in California and the Paternal Grandmother has not been able to obtain her address, it will be necessary to forward the Order to the Mother at her last known address in Harrisburg, pennsylvania. ~ IU/,J..oOr:i O~~, i!=1 Dawn S. Sunday I Esquire Custody Conciliator Date