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fl\cult\lconcilr.ord
MAR :1 1 1997.tJ-
TODD A. REED, I IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: e,~I'1 '-RIJ" \
v. I NO. 9'l. /S?f&,
I
SHAWN D. BRANDT, I CIVIL ACTION CUSTODY
Defendant I
ORDER OF COURT
AND NOW, this 1.. ,,1- day of A~ 1\ \ , 1997, upon
consideration of the attached complaint, it is hereby directed that
the parties and their respective counsel appear before J r 1\, 11 ." \ ,
~:cl"~~ E;rl~. tho conCil;~tor. ot 1,.'] "J 1'1\0111 .+
tr( b:nlc~b .cg.S:~ on the rl L\ day of _He\'-I ' 199.2,
at \', OC) , L.M., for a Pre-Hearing Custody Conference. At such
conference, an effort will be made to resolve the issues in dispute I
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 conferenoe.
Failure to appear at the conference may provide grounds for entry of a
temporary or permanent order.
FOR THE COURT,
By: ,Un.) JJf\ r~ :Jut ~ <~ '
Custody Conciliato (11:>-
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO KOT
HAVE A LAWYER OR CAKHOT AFFORD ONE, GO TO OR TELEPHONB THB orrICB
SET FORTH BELOW TO FIND OUT WHERE YOU CAN OET LBOAL HBLP.
Court Administrator
Cumberland County Courthouse, 4th Floor
Carlisle, PA 170lJ
Telephone: (7l7) 240-6200
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TODD A. REED,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
; NO. 9'~- ;,:>n ~ '"c-
LAW
v.
SHAWN D. BRANDT,
Defendant
.
.
: CIVIL ACTION
IN CUSTODY
NOTICE TO DEFEND
TO THE DEFENDANT NAMED HERE:
SHAWN A. BRANDT
YOU HAVE BEEN SUED IN COURT. If you wish to defend against tho
claims set forth in the following complaint, you must take action
within twenty (20) days after the complaint and notice are served, by
entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so, the case
may proceed against you and a judgment may be entered against you by
the Court without further notice for any money claimed in the com-
plaint or for any other claim or relief requested by the plaintiff.
You may lose money or property, or other rights important to you.
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.
Court Administrator
Cumberland County Courthouse
Fourth Floor
Carlisle, PA l701J
Telephone: (717) 240-6200
fl\cu.t\r..d.com\3-91
TODD A. REED,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION CUSTODY
NO. 9"1- IS? '- (2''''l' ( ~ 01'.2 "'\
. i
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v.
SHAWN D. BRANDT,
Defendant
COMPLAINT FOR CUSTODY
l. The plaintiff is TODD A. REED, an adult individual, residing
at 26 West Willow Terrace Drive, Mechanicsburg, Cumberland County,
Pennsylvania 17055.
2. The defendant, SHAWN D. BRANDT, an adult individual, resides
at unknown location in Carlisle, Cumberland County, Pennsylvania
17013. Cumberland County Domestic Relations does know of her where-
abouts~ however, they are not able to release this information to the
Plaintiff upon request because of the Defendant's subsequent refusal
to release same.
3. Plaintiff seeks partial and shared legal custody of CHEYENNE
NICOLE REED, who is six years, one month of age having been born on
January 5, 1991.
a. The child was born out of wedlock.
b. The child is presently in the custody of the mother,
Shawn D. Brandt, who resides at an unknown location, in or around
Carlisle. Domestic Relations has knowledge of her whereabouts, but
cannot release said information.
-1-
c. During the past six years, the child has resided with
the mother in and around Carlisle.
d. The mother of the child is SHAWN D. BRANDT, currently
residing at an unknown location in Carlisle, Cumberland County,
Pennsylvania, 17013.
e. The parties have never been married.
f. The father of the child is TODD A. REED, currently
residing at 26 West Willow Terrace Drive, Mechanicsburg, Cumberland
County, Pennsylvania l7055, with his mother, Sandra Kay Reed.
g. The relationship of plaintiff to the child is that of
father.
h. The relationship of defendant to the child is that of
mother.
4. 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 any other court.
5. Plaintiff has no information of a custody proceeding concern-
ing the child pending in a Court of this Commonwealth.
6. 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. Plaintiff has not seen his daughter since the defendant since
March, 1996 because of the actions of the defendant.
B. Plaintiff has attempted visitation with his daughter, which
has been denied by the mother/defendant.
-2-
9. The best interest and permanent welfare of the child will be
served by granting the relief requested because:
a. The child needs both parents in order to maintain a
continuous healthy and loving relationship with their parents;
b. While the mother is able to provide a stable home and
family type environment for the child, she must allow the child the
opportunity to spend time with the child's father consistent with the
following proposed schedule:
1. The father is to have liberal and free visitation
of the child every other weekend beginning on the first Friday at 5:00
p.m. and ending with the father returning the child to the mother's
home on Sunday night between 5:00 p.m. and 6:00 p.m. On those
weekends where the child wishes to attend religious services, the
father will drop the child off at her maternal grandmother's house
before the church services on Sunday morning.
2. The father is not to have any restrictions placed
on his visitation away from the residence of the mother while enjoying
his visitation with the child.
3. The father is to have visitation during the
following holidays according to this schedule:
(a) CHRISTMAS. Father is to enjoy visitation from
twelve (12) noon on Christmas eve day until noon on Christmas day
every other year, beginning with Christmas, 1997, and every odd
numbered year thereafter. For even numbered years, Father is to have
visitation beginning at twelve (12) noon on Christma~ day and ending
-3-
on December 26 at noon. Mother will enjoy the opposite schedule of
Father's alternating Christmas rotation.
(b) EASTER AND THANKSGIVING. Father is to enjoy
visitation from 3:00 p.m. until 9:30 p.m. every year for these two
holidays.
10. Summer vacations. Father is to have four (4) weeks of non-
consecutive visitation and custody with the child. One full week will
be taken in June, July and August, with the fourth week to be deter-
mined with at least sixty (60) days notice given to the Mother, to be
taken during the summer months.
ll. Father's day will be spent with Father.
l2. Mother's day will be spent with Mother.
13. Telephone contact. Reasonable telephone contact will be
allowed by the Father to the Mother's home. Mother will not in anyway
interfere with this contact, so long as the phone call is made at
reasonable hours during the day.
14. Mother agrees that if the need for a babysitter arises, she
will first call the Father to give him the right of first refusal. If
the Father is unable to fulfill this request, then the Mother agrees
to then call Sandra Reed, the child's paternal grandmother, and give
her the right of second refusal.
15. Father will have the child every other year for her birth-
day, beginning in 1998, and every even numbered year thereafter.
Mother will have the child on odd numbered years beginning in 1999,
-4-
and thereafter. Each parent is to extend an invitation to the other
parent if any birthday parties are held.
l6. Each parent whose parental rights to the children have not
been terminated and the person who has physical custody of the child
have been named as parties to this action.
WHEREFORE, plaintiff requests the court to grant him partial
and shared legal custody of his daughter, CHEYENNE NICOLE REED
pursuant to the requests herein.
STONE LaFAVER & STONE
zab h' B.
Supreme Court I-.
414 Bridge Street ,.0. Box E
New Cumberland, ~'17070
Telephone: (717) 774-7435
Attorneys for Plaintiff
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VERIFICATION
TODD A. REED states that he is the Plaintiff named in the forego-
ing instrument and that he is acquainted with the facts set forth in
the foregoing instrument 1 that the same are true and correct to the
best of his knowledge, information and beliefl and that this statement
is made subject to the penalties of lB Pa. C.S.A. 54904 relating to
unsworn falsification to authorities.
~--t CA. 72ed_
TODD A. REED
.
.
Date:..3/ C/ /7 7
vs.
NO. 97-1576
CIVIL TERM
, .
TODD A. REED,
Plaintiff
IN THE COURT OF COMMOO PLEAS OF
CUMBERLAND COUNTi', PENNSYLVANIA
SHAWN D. BRANDT,
Defendant
IN CUSTODY
ClU>ER OF CXXlRT
AND tuoI, this I '2. ~ day of /'10) /fA(
consideration of the attached Custody Conciliation Report,
and directed as follows:
, 1997, upon
it is ordered
1. The Mother, Shawn D. Brandt, shall have svle legal custody of
Oleyenne Nicole Reed, born January 5, 1991, until the overnight partial
cllBtody schedule begins under this Order, at which time the Father, Todd A.
Reed, and the ~lother shall have shared legal custody of the Child. The
Mother shall have primary physical custody of the Child.
2. The Father shall have visitation/partial custody of the Child
on a gradually increasing basis as follows:
A. The Father shall have a four (4) hour period of
visitation with the Child (with the Mother present) on
Sunday, May 18, 1997 from 1:00 p.m. until 5:00 p.m. at
the Sports Emporillll1 in Carlisle.
B. The Father shall have three additional periods of custody
wi th the Child on May 25, 1997, June 1, 1997 and June 8,
1997 from 1:00 p.m. until 5:00 p.m. with specific
arrangements for such periods of visitation or partial
custody to be made by agreement of the parties.
C. Beginning on June 13, 1997, the Father shall have partial
CllBtody of the Child on alternating weekends from Friday
at 5:00 p.m. until Sunday at 5:00 p.m. During his
weekend periods of custody, the Father shall insure that
the Child is transported to the maternal grandmother's
residence on Sunday mornings at 9:00 a.m. for Sunday
school and church, and the Father shall insure the Child
is piCked up at the church at 11:30 a.m.
D. During the slllTlller of 1997, the Father shall have an
extended period of custody with the Child from Thursday
at 5:00 p.m. until the following Tuesday at 5:00 p.m.
upon providing thirty (30) days advance notice to the
Mother. This period of extended cllBtody shall be
scheduled to include one of the Father's regular
alternating weekend periods of custody. The parties
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shall cooperate in establishing arrangements for extended
periods of custody for the Father in subsequent summers.
3. The parties shall share custody of the Child on holidays as
follows:
A. Christmas - In 1997, the Mother shall have custody of the
Child from Christmas Eve until Christmas Day at 2:00 p.m.
The Father shall have custody of the Child from 2:00 p.m.
on Christmas Day until December 26 at 4:00 p.m., unless
the Father has custody under the regular schedule over
the weekend following Christmas in which case the
Father's period of holiday custody shall extend through
the weekend. The parties shall cooperate in making
arrangements for sharing or alternating custody of the
Child on subsequent Christmas holidays by agreement.
B. Thanksgiving - In every year, the Mother shall have
custody of the Child on Thanksgiving Day until 4:00 p.m.
and the Father shall have custody of the Child from
Thanksgiving Day at 4:00 p.m. until the following Friday
at 4:00 p.m.
C. Easter - The Father shall have custody of the Child in
every year on Easter Sunday from 11:30 a.m. until 5:00
p.m.
D. Mother's Day/Father's Day - The Mother shall have custody
of the Child in every year on Mother's Day from 1:00 p.m.
until 6:00 p.m. and the Father shall have custody of the
Child on Father's Day from 1:00 p.m. until 6:00 p.m.
4. Exchanges of custody under this Order shall take place at the
Hess gas station on the Carlisle Pike across from the Carlisle Truck Plaza.
5. The Father shall not drive with the Child but shall insure
that transportation is provided for the Child by the paternal grandmother
or another responsible adult who has a valid driver's license and is not
under the influence of alcohol or drugs.
6. The Father shall not consume alcohol during periods of
custody with the Child.
7. The Father shall insure that the Child has her own sleeping
space during his overnight periods of custody.
8. In the event the Father takes the Child to the races during
his period of custody, the Father shall insure that the Child returns to
his home at a reasonable hour for bedtime.
9. In the event the Mother requires chi1dcare for the Child for
a period of three (3) hours or longer, the Mother shall make a reasonable
effort to first contact the Father to give him the opportunity to provide
care for the Child instead of a babysitter or other third party.
10. Each party shall have reasonable telephone contact with the
Child when she is in the custody of the other party.
11. If, during the Father's periods of custody, the Child is to
stay overnight at a place other than the paternal grandmother's or Father's
residence, the Fath0r shall provide the Mother with a telephone number
where the Child can be reached.
12. If either party takes the Child away from his or her
residence for an overnight period or longer, that party shall provide the
noncustodial party with an address and telephone number where the Child can
be reached.
13. The holiday custody schedule shall take precedence over the
regular custody schedule.
14. 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 agreement. In the absence of mutual
agreement, the terms of this Order shall control.
BY THE COURT,
/14-
J.
co:
Elizabeth B. stone, Esquire - C unse1 for Father
Jacqueline Verney, Esquire - Counsel for Mother --
~AZ-'~A. 51/3/9-1,
..J. 1".
Plaintiff
IN THE COURT OF rotMOO PLEAS OF
: CUMBERLAND COONTY, PENNSYLVANIA
TODD A. REED,
.
.
vs.
: NO. 97-1576
CIVIL TERM
.
.
SHAWN D. BRANDT,
Defendant
IN CUSTODY
amaJY CXH:ILIATIOO 5U'IMARY REl'OOT
IN ACXXlUll\NCB WITH a.tmERLAND ~ RULE DE' CIVIL PIlO '1<1 (JRB
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
IlI\TE DE' BIRTH
alRRENTLY IN amaJY DE'
Cheyenne Nicole Reed
January 5, 1991
Defendant/Mother
2. A Conciliation Conference was held on May 1, 1997 with the
following individuals in attendance: The Father, Todd A. Reed, with his
counsel, Elizabeth B. Stone, Esquire, and the Mother, Shawn D. Brandt, with
her counsel, Jacqueline Verney, Esquire.
3. The parties agree
to entry of an Order in the form as attached.
Jl.m ~-ctL/"~
Dawn S. Sunday, Esqu
Custody Conciliator
rn""" Ct. /997
Date I '
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TODD A. REED, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v. I NO. 97-1576
I
SHAWN D. BRANDT, I CIVIL ACTION CUSTODY
Defendant I
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
) ss.
COUNTY OF CUMBERLAND )
I, ELIZABETH B. STONE, of Stone LaFaver & Stone, attorneys for
the plaintiff hereby certify that I served the Complaint for Custody
in the above captioned matter on the defendant, Shawn D. Brandt, at
her place of employment Ross's Distribution, 1707 Shearer Drive,
Carlisle, PA 17013, by United States Certified Mail, postage prepaid,
restricted delivery on April 4, 1997, as evidenced by the attached
Certified Mail return receipts.
SWORN TO AND SUBS~IBED
bef~ me, this '.Z:!!!...- day
of )/, { , 1997.
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TODD ALAN REED
PLAINTIFF
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
97-1576 CIVIL ACTION LAW
SHAWN D. BRANDT
DEFENDANT
IN CUSTODY
ORI>F.R OF COllRT
AND NOW, Wednesday, November 06, 2002 . upon considcration of the attached Complaint.
it is hereby directed that parties and their respcctivc counsel appear bcfore Dawn S. Sunday, Esq. , the conciliator.
at 39 West l\faln Slreet, Mechanltsburg, PA 17055 on Thursday, November 21, 2002 aIIO:OO AM
for a Pre-Ilearing Custody Conference. At such conference. an effort will be made to resolve the issues in disputc; or
iftbis cannot be accomplished, to definc and narrow the issues 10 bc hcard by thc court, and to enter into a temporary
order. All children age live or older may also be prcsent at the conference. Failure to appear at the conference may
providc 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 conelllalor 48 hours prior to scheduled hearing.
FOR TilE COURT.
By: Isl
DawII S. SllIIday. ESQ.
Custody Conciliator
Coo
Thc 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, plcasc contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before Ihe court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE TillS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
IIA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIm OFFICE SET
FORTII BELOW TO FIND OUT WIlERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty A venue
Carlisle,Pennsylvania 17013
Telephone (717) 249-3166
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AMF.RICANS WITH J)JSAIIIJ.lTIF.S
ACTOF 1990
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The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For infonnalion about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
.,
please contact our ofliee. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduling conference or hearing.
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TODD ALAN REED,
Plaintiff
: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
97-1576 CIVIL TERM
SIIA WN D. BRANDT,
Defendant
IN CUSTODY
11ed,r;c.-a/~/7
COMPLAINT FOR CUSTODY
AND NOW comcs the Plaintiff, Todd Alan Reed, by his attorneys, Irwin, McKnight and
Hughes, and prescnts the following Complaint for Custody.
,
It.
1.
The Plaintiff is Todd Alan Recd, an adult individual residing at 75 West Main Street,
Newville, Cumberland County, Pennsylvania 17241.
.-
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2.
The Defendant is Shawn D. Brandt, an adult individual residing at 923 Spring Circle,
Mechanicsburg, Pennsylvania 17055.
3.
The parties are the natural parents of one (I) minor child, namely Cheyenne Nicole Reed,
born January 5, 1991.
4.
On Friday, October 25, 2002, Cheyenne Nicole Reed, moved to reside with the Plaintiff
on a pennanent basis.
5.
The Plaintiff desires primary physical custody of the minor child, Cheyenne Nicole Reed,
and joint legal custody with periods of visitation to Defendant as can he mutually arranged
betwecn the parties.
6.
The Defendant has consented to the ehange in primary custody and the enrollment of
Cheyenne Nicole Reed at the Big Spring School District. A copy of the Student Withdrawal
Fonn is attached us Exhibit "An.
7.
The best interests and penn anent welfare of the minor child requircs that the Court grant
the Plaintiff's request as set forth ahove.
WHEREFORE, Todd Alan Reed, respcctfully requests that he bc awarded primary
physical custody and shared legal custody of Cheyenne Nicole Reed, as provided herein, with
periods of temporary custody to Defendant as provided herein.
By:
Respectfully submitted,
IRWIN'tJ4UGIIES
Mare s A. MeK ght, II, Esquire
Attorney for Plai 'fT
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I. D. No. 25476
Date: October 29. 2002
EXHIBIT A
EAGLE VIEW MIDDLE SCHOOL
!
Cumberlalld Valley School DiJrricl
6j4(, Carlisle Pike
1\lccllUllicsbllrg, Pennsylvania 1;050
(717) i66-0217 /249-6996
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Cumberllnd Valley School District
Eagle View Middle School
6746 Carlisle Pike
MechanlCSburg, PA 17055
STUDENT WITHDRAWAL FORM
Student name: cht.veY\Y\e- t?eec!
Grade/Team: If 6.0/ Homeroom: ___ If,,~ I
Withdrawal Date: /~~~~,,;J
New Addre..:
New School:
6; j"-'JY SC/,t'(Jf LbP;"d"
Sublect
Grade to Dlte
Telchl"s
Language Ana (EngUah)
Soc&.! 81Uc11n
MlthlAlgeIlnl (CIIde _)
Science
Reading
. Ponlon Langu.gl: frtnCh,
GermMt, La1ln,llplnllh
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Art
Compulllr
FACll
Hallth
MutlIc
Tech Ed
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Phy8lcaIEduCltlon
BandlOrc,,""
Ch<<ua
NUrM
MedllC4lnlar
Homeroom taacher
Scl1oo1 0IlIclI (lunch money IIlC.)
~.:rf/ If'
Palllnl: I he~ Ill'llnl p"rmlssion to the Cumbllr1and Valley School 0lstrlcI to send school
reconls to 111, requesting school for my cl1IId,
S/v:l,~ bl2..a..~*-
Counselor: _ M~. Mullin
Palllnl Sigl18lure
-x'Mr, Rauscner _ Hn. Fone.
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TODD ALAN REED,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97.1576
CIVIL ACTION LAW
SHAWN D. BRANDT,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this '1~ day of ~ , 2002,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated May 12, 1997 is vacated and replaced with this Order.
2. The Father, Todd Alan Reed, and the Mother, Shawn D. Brandt, shall have shared legal
custody of Cheyenne Nicole Reed, born January 5,1991. 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 her health, education
and religion. Both parties shall have equal access to all records pertaining to the Child, including
medical and school records.
3. The Father shall have primary physical custody of the Child.
4. The Mother shall have partial physical eustody on alternating weekends from Friday
through Sunday with the times for exchange to be arranged by agreement of the parties.
5. The parties shall share having custody on holidays as arranged by agreement.
6. Unless otherwise agreed between the parties, the Mother shall be responsible to provide
transportation for exchanges of eustody during the alternating weekend schedule and the parties shall
share providing transportation for exchanges of custody on holidays.
7. Ncither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
8. The parties may modify the p:ovisions of this Order by mutual consent. In the absence of
mutual consent, the tenus of this Order shall control.
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TODD ALAN REED,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97-1576
CIVIL ACTION LAW
SHA WN D. BRANDT,
Defendant
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
I. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Cheyenne Nicole Reed
January 5, 1991
Father
2. A Conciliation Conference was held on November 21, 2002, with the Father's counsel,
Marcus A. McKnight, III, Esquire in attendance on the Father's behalf. The Mother, Shawn D. Brandt,
did not attend the Conference as apparently an understanding had been reached with respect to the
transfer of primary custody to the Father.
3. The Father's counsel represented that he had served the Mother with notice of the
Conference and the Father's Petition for Modification. The Conciliator was provided with a student
withdrawal form and written consent signed by the Mother providing permission to withdraw the
student from the Cumberland Valley School District and enroll her in the Big Spring School District,
where the Father resides. Based on the representations made by the Father's counsel at the Conference
and the fact that the Mother did not appear or contact the Conciliator, the Conciliator recommends an
Order in the form as attached which provides an opportunity for a review of the custody arrangements
if deemed necessary by the Mother.
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Date I
~~
Dawn S. Sunday, Esquire d--
Custody Conciliator