The URL can be used to link to this page

Home My WebLink About97-02072 ~ i ~ ,----- " 1 I ~ 1 "" ~ , , , ! !.) " . .::) l I i I I ! I I I ! cJ ; _I ' '1 1 r-.. l <:) ; :1 ()- ~ I NAOMI BRANOFF. PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY v. JAMES BRANOFF, DEFENDANT NO. 97-2072 PRABCIPB TO RBINSTATB CUSTODY COMPLAINT To the Prothonotary: Kindly reinstate the complaint in the above-captioned custody action. Respectfully submitted, ~ t Date ffkw It; , 19~17 I ' /t41 ;;;> ,Ic<-A ,-,L- Tomas M. Pace Robert E. ains Katherine C. Pearson SUPERVISING ATTORNEY Gail R. Shearer STAFF ATTORNEY FAMILY LAW CLINIC 45 NORTH PITT STREET CARLISLE, PA 17013 717/243-2968 717/243-3639 ". ,- ..... tr: C': j~ r;: 1'1- ..'-) l.u~ , . ()' ,- ....., ~ .'4( l.I... l~~ 1.1_ I' ., 9' c:) ~ ~ 1,0 r , -;; ~~~j :. :-. ;le t.l.. ~ . :i.t..: .) u_ l- e.) C) (]'. " 5. The Plaintiff's position on custody is a8 follows: Plaintiff believes that the child should reside primarily with her during the school year for purposes of stability with the child once she goes to school. She did not raise any particular fitness issues with regard to Father although her counsel indicated that they would be raising those issues as to show why the more appropriate household is with the Mother during the school year. 6. The Defendant's position on custody is as follows: Father believes that he should be the primary custodial parent of the child since he has bean, in his opinion, the primary custodial parent since the parties divorcsd. He wants the child to be residing with him during the school year since the child is used to the home in which he resides and is familiar with the children in East Pennsboro School District. 7. Need for separate counsel to represent child{ren): Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. 9. A hearing in this matter will take one-half day. , O. Other matters or comments: This is a case where the parties seem to be equally suitable custodial parents. Neither party had any significant problems to complain about with the other parent. In fact, they both went to great lengths to indicate that they know that the other parent is a responsible, caring and loving parent for the child. Thi. i. a .itustion where some type of .hared arrsngsment is appropriate. The major sticking point appears to be where the child will reside for purposes of going to school and if the child should be living in one household during the school year. Both parties seem to agree that the child should not be going back and forth from household to household during each week. Mother proposed that she have the child during the schOOl year and Father during the summer months and during the other periods of time, while Father indicated that he would agree to that same type of arrangement with Mother. In the alternative, Father suggested a week on, week off visitation arrangement. The Conciliator indicated to the parties that he believed the court would set up some type of shared arrangement so thet the child essentially would spend an even amount of time with both parents, however it was arranged either by having the child live in one household during the school year and the other during the summer months and holidays and other times as well as expansive visitation rights during the school year, or some other type of hybrid arrangement whereby both parents have equal access to the child. The parties agreed that during the summer months they would work on a two week on, two week off arrangement and it is hoped that prior to the commencement of the school year and before the hearing commences, that the parties will be able to work out their differences on an overall schedule. If they are not, the court will simply have to come up with an * ~Cl'r\\ Brol'ott PlaintJ.ff IIN 'l'HE COUR'l' OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA V * JQn\e-~ 5rof'ot--t Defendant . . :CIVIL ACTION - T..AW . . :NO.CXJ'd CIVIL :CUSTODY/VISITATION 19~, ORDER OF COURT' AND NOW, this (date) L\ld~ICj" upon consideration of the attached complaint, it is hereby directed that the parties and their re~pective counsel appear befo:re K\( h~-. B,()r-,Q \~~-<;.C{...., the conc~l1ator, at "lOci s.. \ RM ~+-. (~EEIL:; E:& J ___ on the ~ day of =\~a~ , 19q1 , at d' 0("') P. M., for a Prehearing 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~y the court, and to enter J.nto 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 tempC?rary or permanent order. FOR THE COURT: '- BY:~ ~ '-I~.'fl.l:'lA~' Custody cond1iiator~) YOU SHOULD TAKE 'l'HIS PAPER TO YOUR LAfiYER 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 ADHINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE PA 17013 (717 )240-6200 ,"\' . n~ v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY : 0'1'>- : NO. 97- ~ CIVIL TERM Naomi ~o(f. Plaiii~:i' James Branoff, Defendant ORDER OF COURT AND NOW, this day of , 1997, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, , the conciliator, at , Cumberland County Courthouse, on the day of , 1997, at 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. Either party may bring the child who is the subject of this custody action to the conference, but the child'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: 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4th Floor CARLISLE, PA 17013 717/240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common PIcas 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 must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. c) Plaintiff is willing to accept custody of the child; d) Plaintiff continu~ to exercise parental duties and enjoys the love and affection of the child; e) Plaintiff is willing to, and has, made the child accessible to the Defendant fpr periods of partial physical custody; 8. Each parent whose parental rights to the child 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 to her primary custody of the child. Date 'i . ;},J - q1- {~~ m!;y - Ang Montgom Certified Legal Intern Ia.J R 4-(,-,,-,-<-.-1 OMAS M. 'pLACE ROBERT E. RAINS KATHERINE C. PEARSON Supervising Attorney GAIL R. SHEARER Staff Attorney FAMILY LAW CUNlC 4S North Pitt Street Carlisle, PA 17013 717/243-2968 VDlFICA T10N I verify that the statements made in this CUJtody Complaint are true and comet to the beat of my penonal know1edae and belief. I undenland that false stalCmCnts herein are made subject to the penalties of 18 PI.C.S. Section 4904, relatinllD unsworn falsification authorities. ~ Date~ ~~ Naomi Bnnoff n " ., - - >- ~o~ lJ'llJ 'I- ...~~o ",- .z -r '0 \~:~ :~O : \'i Ii: \ l- .; /:l. ~:~: ......:~ :.\ ~~c;: ~ . . . . . :0 : . . . '-- r , .. -. , , i ~ ! r c-' e f .J , c -~ . ,. f- .) l.J ..- '] .:!2 - ~ -.J f +~ <!;:d ,(.I: U) '\ n)..] OOV()~::. Lll Oc U)v l.I1 t"iLi ~silt .. NAOMI BRANOFF, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY JAMES BRANOFF, Defendant : NO. 97-2072 CIVIL TERM AfFIDAVIT OF SERVICE I. Tim Wells, hereby cenify that I am a competent adult who is not a pany to these proceedings, and that I have served James Branoff with a trUe and correct copy of the Custody Complaint and the Order scheduling a Custody Conciliation. I accomplished service at 4:30 p.m. on May 27. 1997, by hand delivering a copy of the Complaint and Order on defendant's fiance, Shannon Snell, who is an adult member of defendant's family and resides with defendant at 153 East Dauphin Street, Enola, Cumberland County, PA 17025. ~ I verify that the statements made in this Affidavit of Service are trUe and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. fi4904, relating to unsworn falsification to authorities. Date: ~~~;/ L.- en Li , I , (r: ( , , ; , C. ',~YI , 1.."': ... ; , .' r"~ .:J "" .~..) :~'i..' \~. ~ -?' " '!- '. .' ".~' : .'. ,. ~, " - .."'-':...,...\' ~'~. I.' . , ;,~)ot :t.:, ~, .."".~. '".. .-",".' ..".,:~ . .' .....:'"' "'. \'"" ~~,:,\\I:r'. .,4, '. I.w I{.'" ~ '.; -...~ "; . ." , ' .( ,.,'"i" """~ .~... .. .~ , -' , '1"0 ) ......J,. ..~ .;.... , ., , :"~~.Mt:'.""~i'ZilWf:~\ ;; ..,..... t~. ...,,:.:.,~ ",:t;..\~'~;' r: '/. '-'.: I.'F, ...., . <;. :~ ... ::Zfi~'f:~,'~,~;:~~:i~;.i~::;?:;;j!~,p{'i.. '" ~.. .,:::;; ~;, .;....,,,..~..,/ ~.l,l:":J. ~..C."i<_..:,.lo/,..:. 4....'l"...})~~:.;;!J\";\\~:.o.r.;;tfllo.. ''l:'' ..-..~.'~, " . . ~.,~,:,~.\:,., _. "'~' .\.~/ .~ "<:}:"I'~":;;:':r?':;:~~;::tj,:~:1j;};~:;:~7:'::!~;f~:'::,; ,,, "~-'" -. ' , ,--~.._..__..-..... " .", .,.~ "I' . .,. 1 .,:: . ;'.:--:" .. :: ~ '.;. I i ~ ~I:. a~~ -e~ ~~~ ~ U ~ .,- ~ ~ I ~~J o. 7' J ! ~t 8.1 (I) 0 17' or 0 17' " 0 C'- .. .. C'- I C'- .. .... or .. .. .. .... 0 0 0 0 .... I ,.,., I 0 .. .1.,.. ,r. ,",'., .. JII(:_. ", J' " \ \ . ''--:'...,. .' -:.'\.' '.' .oc .....-If~... .. . ."., ," . ,'.~. "'." :r'':'~, !t,': # '.. ........i(" ~.,.._ $". I t" ,.1:';l.1:~~",),,:;., ''''~l' . . '. ..~ -:'... . ~ ~ ,:' ( .,,\-\1': "r.'" . ".\ai{"!~',t'll..r~~;"~ I . 1-:-~':'I'ii{~Y'1''':~~V~. "I~..l.~.~1Nf"i-~t.~~J.'~ I . ..,'t.~ '. ..~ ' . ~-".. ~ '" ,; /..r;,..L . I . ,'.l. .~ ........ . " '.r/", .. .~'" o,~' .~."'iI' y!., . I . \. " , ,!<I",. ..""~ ' lO.'\~ t.. I:\IU"R ." . ~. , j,. .~&\'t't'.~"'''.'':';(1o! ~'.,t.""'-;tt\:.: I\~'V..! ':':':Ji,Y" '1 ... ~:....,.\.oC',,;.... ~"'", . ;.:.,",... .~......,'ii,:t ,If.;\\#I,;';' :.; .' . "",' l' -,~' :,!\' 10."'1: 1J ~"I " '.~ ;\. :. .. .' '., ,.,i" ;~J;'"'''' fi:..:>,l,., .J . '.. .::<;-":. ',.' :0.;:\ ;:::\:\;;::;~:"/::~:{'l , I ~ :--' il......~""...J\.;..,'~ ~1j.<lI.'l(:.,~j 'C',. ,'. ., ., ..,',...,.~ . ., '" .~lj~;. .,-..~._{.........Jp~,,:.. ......11; I V',.jl" ,..... :. , ,- ',;.>' f"~ I'- ...-'..,.... I\}"_ ~IJ; ";'~;':~.iT "';". \. ' '. ',' ~ . '. '. .,. ':;':"';;~".:';"('''''''~~oi~''' :""""';~'!:xl~'. I~! " ~.. .:" i~~'~~_~~"~'~,:,;,,;,::,:; ~,t:~i! .. ':'}V/l.',.';;.~.. ..\" ,'." ,~\ .";~--""'l:...:-~...i-<':W'!' ,..i.~":','f;~"..:,;./'..'-;t'_ . .. '-, . ." .,,' . .'. ..., .... :r:.~. ;.,.' ,.r.. . '. "-... :.'........". ,,,.~.'....., :,..-.:..~..\.,~,.'I'........"':.~..., " . ....l'.......'.~.,_.'... -':1'-""',: '. ....,'...:.,\\'q'.Itt..,..j\.::!':.....fl\~.<It ,'ti . ~~","h".H..' 1....1' '..'."I1",J."~:-,,,,";';I' 1- \O~.'. ~~~':~,:~l:;J'.i::~J~~)..J.~:t;.~~i:<.~~~ '.\~:.,~' -',. ,.~~1.!(~~ . . '".... "', ~:-i!','=',,~I!i*;:~'I",1"..I.~~~A~ . /. ',. " Il,~.' .';~.~.'.~':~i...~,:~~~~J~~l'::~t:~.~ ',. ,:..!I:.:_':'..'-'t..::,:'-:.~'t!,.~."\.:.;~:_,l:,:; .,' ,.'",' ~';R '....;:.l;:.'.~~~/; '.. ' ':'..,;.f:,'.l(!t...f...'tI..'~: P~-~t,/1t~ ,. '-,' ".' ." ~ ~"';' ;'. '. ," .~ . . . ,~\;';"".~. '~.~':,~ {/~t....~"::,; "~-':'!~ !:': V. ' t..... {.(,. ...~ '. 7' ~3~,~"lr.f.... '.' .'. "', .. .,,11. '-",~. .:.::':~.~::.:: ~.;::~\::::-\ .!\~/;~~~~.~~r: '.,.' EAST PENNSBORO AREA SCHOOLS I1J1I.. WITHDRAWAL FORM /lj0001 r STUDENT NUMBE~ NAME ~" : ~j \(~-I '( IF~~' . _ __ GRADE \ BIRTHDA TE J 1/ :"'./9, ADDRESS \. \,1 \; __be- o_\."- .hVt-\ . Bl'S NUMBER ~EROOM ____ NUMBER OF DAYS A TrENDED .____ ______ LAST DAY OF A ITENDANCE 111 17 -_ , CLASSIFICATION OF WITHDRA W AL PLPIL'S AGE '/ AMOUNT OF MONEY OWED 10 CARD LOCKER KEY TEACHERS: Th" i. 10 cenify Ihat the ahnv~ pupil has return.d. in sali~faclory condition, all books and school .quipm.nt loaned 10 himlher under my ,up.:rvlslon_ School prupeny not r.lurned is Iist.d below, SUBJECf GRADE TO DATE MA TERIALS NOT RETURNED SIGNATURE Enlllish Foreilln Language Geollraphy H.alth Math Readinll Sci.nc. Social Studies An Homt Ec./Shop Music Physical Education SafelY Education Library Homeroom ., Nunc: (to rel.as. M.dical and D.nlal R.cords) Special EducRtion R.cords Counselor; (remarks) Principal: Th. above mentioned student as my permission 10 withdraw from /}/I /J.._ _ . -..J /, . school on - 3- (~~ (Dale, (Princip"I'. Slanl,ure) TO THE PARENT: When children leave East P.nnsboro Schools. it is th. policy oflh. district to s.cure the signature of the parent to grant permis'Ion to I~,"e and tn '~nd puhlk IOformatinn III the r.c.iving school district, In some cases. there may be cnnFidenll,,1 IOlormalll'" 10 Ihe l'umulallV~ Fold.r which could he useful to the new school. Please indicate your willingne" 10 pernlll ynnr chlhl\ wuhd",wal from East Penl1shoro Schools, Also indic~te willinllness to have confiden- tialinFormation senlto the new sCholll. (No signature signifies that only public informalion will be senl,) EaSI Pennsboro School District has my p~rmission to wuhdraw my child's name from its rolls. Dute .'5) I.~N -, Signed 1.)J:'<I<x't\~ 'B:,()I..,~ (Paren' or Guardian) East P.nnshorn School Dislrict may release such confidential informution (including psychological repons) on my child which the counselor feels will he benelicialto his/her adjustment to the new school. Date '6jd/<; -I Sii&n.d ~'J)--(\-:" 'B'\~'"Y'Df:f' A (Parent or Guardian) V~ \ ~'i?_I~'~)' ~ (Q.~~ J ~'''J'~~~ /-, , New School District/Addre,,'_:.' \ N.... Horn. Address lu.-rAllI:"1 fill, J411 (In. l/82) . (lHI, J20.') C;JY'-04'';I'oNt:,,\.r~-I1- ~t-"fN5fL,,"Ni. .J.~AM'~t:'",jf -,.;F- >icAl,T... DIVISION O' SCHOOL H'AL TH f 1) SCHOOL HEALTH RECORD HAMS, LAIT. ""'T. M'OOI.I r r ~ I<fT tV ~ TT J 1040.... AOO...n--L/ 1'(0,..' 400'Uts /-i.j d'"3- 8~ATH DATI MONTH. DAY, v...." 07- IS-C/O I-tO...E ADO'USS !-tOME AOO''''S OISTRICT If'MAL' a:HOOL 1 ~A,S"" tf?,.-,WVS~(J/L"'~~~ . 3. COUN TV c) ,..... YO I ~~~'=', ~ -., .- -+-. +--1' -. . +-- - +- t +-- +.--- +- ~ -r I .. I ..,r.i"1 F-", U r'+' .~.. 01"01 ~_d' -t- -- -.,.. 'l.QoM QJt f\-' ;: UCy"... .,KCIAL,. H....LTH ""O.I..IMS ~k~~ ~ ATH'''' ,.".... I....S. 1=1 ~IwfIOOLE ....J It.. '1!. i 'i.) jr1AIl4~'U 6 ~ .4 tV 0 -H-) u ~ rl1 t::5 Be AN 0 fF ;u ,4 D h... ~ 'I"ION WITH ~HO'" 'UPI,- l.l\'U 1.1' OTHER ''''AN ''''''(NTI I UOT"''''INAMI LAIT, ""IT, MAIO'"", ~ }/.. .)';'1." ..'" ,'- 1~"/ - ::'f .' '" '_U"'Z" TlON. ....0 TUTS #1.6 II-/~~Q fid */ /Q-).5"-1) O"TlINITIAL .;l-If-'!/ -; I,\...l-~J SIAIU C 'LETI , ,/-/S'it "5 r-, -7-'1 'f I) I //-11-11 T T N . ... " " 'I , T II " II I, II , ......L.. VACCINI 0... Tf Q,,...."NIt.4I"'ILII 'II.CCI~1 j O. ",<3 "".,,1', ~...,. 'A by Ll" vt.e.." ,"d ,uP.Of'" h ''''''G y,.,- DATE I' ll,,4uM', VACelHI DATE RnUL T ~I_._~ATE RESUL T -- ~~1- 1---- _.___. _ ...l,... u..u_ _ ___ 'AMILV MI:DICAL HI'TORY, ".III.NT CONCIUINa: DATI IlllUll DATI T CMI!ST l( 'UVI HOht.AHO "AMILY CONDITIO..... CON~IOINTI..L IN'DR"'ATlON ON ~ILI AT '''0'' ).'f\j,~ 151~#d'f VI::tI"'N $c.UINING ---.--- DATI INILLIN '::.~;u'l VI.,"N O. 11II..1 Mul1V I OTMIR DISORDER RIPOAT O' IVI IXAMINIA IXAM, ..- L." , , Rill" LIfO q';;:1~ -' ~ ~1lN 3b" 30 I 4""_'~_ ----. ----- UJ ff-91 ;).{) ;"'0 i 'V - .- I , , I ---- ! .- I , ; , . - ... o. I , , , , I I . I , ",,''',Hlhu ~~HClNING ~..ti5 _ INCnCA. T t ~":;H' t; '.''''C to. i 'of r L '-.01' Q R I ACM F "'QUiNCY 'All.. INCII.;ATl "1.~t.S""'L";' lyj~, t"" ell (t")A eACH ,..IQUINCV ,..IPI Or 1000 '.111" W_lne _I.. - DIl.II.p.II' R_'" Prom Ear ...min_ DATI O. IXAM. TIITIR _.. A.!ftl"..!.M~_"I""_'__"'_ ,._ .__ LEFT EAR . z~~~ .~.Z~1~~~:,8:' :;~ &00 !'~ ZOOO 4000 ~-T ~.~~ _.~~Z ~~;;:.~ 7< -- . -~ I , I --:-... ,----.--- :-'--'-1 .---------- ....- .-...,..--.-. -...---.--.- ;....- ,__'~_'__ I__ I ' . , T'----- ....-- .--4----- , -..--.....- - HIIQHT __L-.._ ANNl.IAI. ,...EIGHT AND WEIGHT -- ~-~~:~~~l~l I il OATI WI H (]) .L~J)"C(~,.:;(4',?r:' IVJ.g:1.W ~J:j :;:,/:..~. A~'.~ . U n"'O\"'1(r;'~l:ii(2.>'. - n9@..h.::t...U... u~-::.;::.".~ .. LEVEL 2 School 2. P F.. Pupil's Name lld"(1 13/'11. ('\ () t(! A"11 lJy rAge ?/;:.?/9/) 0 Boy ~ Girl Syrs, 10mo", GradeK-Arn Date of Test 1{"-/to-9~ . T~ Teacher J')'1Rs, r AREAS AND TESTS NUMBER RAW PERCENTILE POSSIBLE SCORE RANI( STANINE PERFORMANce RATING AUDITORY SKILL AREA .. + 29 13 16 Beginning Consonants Sound-Letter Correspondence VISUAL SKILL AREA Visual Matching Finding Patterns " + 26 0 - ! 10 0 16 0 LANGUAGE SKILL AREA .. + 18 School Language '/ 9 .. Q , u Listening ! ,I 9 .. . !I S! , = QUANTITATIVE SKILL AREA + 24 , , Quantitative Concepts - 9 ,;1.. Quantitative Operations i ' 15 5 .; Number Raw Netionel POllible Scor. Percentile Renk-Stenine Pre-Reading Composite Scores 73 "',.., 5 ;), ,r. j "' . 1: .. . ~ IJ" J ~ ! I~ . .. I <:. ~ .. <) Ita) lth -ll: i; I , 't= .... t ~ i ~ICl ~ l 0 ;:L' .x .. I ~ I ... ~ ~ jjJ L I~ . . v: . , I I I I, ! 0.. i~~ ~ " j j~ ~J .' ! ! J ! c:r .. ! I I~ .' I '.~:'r~':';.::.--.. . ,.. ~ ". r.t: . p~ 1 III ].. I~ II ~ .-l .a JI j j , . j ~ .. u I~j ~ r~ ;",. .. ~ .. ",;J,: : "'J .. ~ & i~ .. ~ JI! .ll << . , .' . , .~' .. <':'~"" :'. . ~;, ',~ " ~"~:il:':t. '..- .' ,,' -;n;\'~''', :' i;, .. ...' J J I . .' .,' ,..;:. . . .:. t i' ., ). . ~ .. , . . ." '... ~ .. , ... I 8! . · J'- Jh ! ~ 0 tJ) v \.f if. if, II()Cl . I ~.d ,,' ~ ! .. ~ ~ ~ I . ....~. U' i ! I~ ... ] i i ' .. J '. i ~ ~ i III · ~ I B~ .!l i III ; 31, i ,:; ~, ~ ~.~ ... II !~ ~ ~ I a III .. .. j .. ~., r.... . ~ 3 Ii ;," . " ~ :", :i:' -.: _ ... '. ,. 3~ .. : J ~.. ~-; <. ~'~'~:.-:~~' ,,' ., '. ... II i ~ ~ ... ~a ,,' I,;" g,~~ a, -l'~:~,,:;\,"T' . .. :l :i !.. . ~ '. .~~ _', 'rl}.. "(';'':~ , .' ~ ~ I . J , , I I .: ~~'-, r;~'1" . . 1 ~ ," .'-,,; " .. '.''': ..... ",. ",:..'.' .'; I i I I. ' r'<;~ , ~..,. ." g' :." .... .. . .';"..,.".. . '''''.\'i... .. ..." .. ~ ....,... .-.......-... .... EAST PENNSBORO AREA SCHOOL DISTRICT REPORT TO PARENTS - GRADE 1 EXPLANATION Of GRADES o _ Oumanding-Work exceed, e'pectation, I - ImprCN1n8-On1y it Iludenl receiwd "N" prllllOUlly, S _ SalisfaClory-Work meets expectallons bul slill not meellng expectllliont N - Needl ImprlM!ment-Work does nol ~ IXpeclitionl " f '" , ... ... /" ./ C; /,;' .\. IV '" Teacher Comments I~~: - ~.. ~ ~;:~~ ~_ /"/ I\. . AJ4~q '//" :/ '~.A~ ~ 1/17 ~."l ~~n4l::.v~Q,.-""A1'~.J. /" 7' 7 j;;r- ...u.- ~~ / /' .--"" ~: ~'~:~tl iL _ ~ ~.J' ,; ...~~_/~1- ~'A-;" .Jw.....~ J ~~. Teacher Comments (Founh P\!!rlodl ':1,'A~ ~ ().A.L :;tZ~~ It' ~A-t:lfl.i.ct .~ ~ 'HKLR ~~ \I I&" ;::"_-1 UA<T- i!::ii~ 7J:::~ . ~' ~~~ bJ..-- Grade / ~t~. LANGUAGE ....m Hu . DOSIUW '"lIude towirdi reidintl UNI comprthen11on skills o.c.rminft word :neanlnllS ("roull" deeod'"A or 'onre~1 ....ppli.. thinki"-. sorale'IIe' to compreh.nd Hit a DOshi... ,nitud. low,rds ""'''lina ChooMt . lopic .nd d~lopi idea, In wrl!inll Wriln 10, variou, nurons.e.. Mo.<ti from femporary \p@lliniJ 10 cnn....ntlonoll 'tpellina Orllly ..prtSWS Ide." {Itlarl" lisl.,.' .nd rnponds oIpproprt.Jlely MATHEMATICS Undentand. oddilion facts Unc!entand. .ub.. action facts Can counl bv 1'. 10 I Can cou"t bv 10'. 10 Can count bv 5'. to I Can counl bv l's 10 Undertland. concepl 01 money Undenland, concepl 01 place ....Iu. onn tent .. Cln write .nd wlw number problem' H....NDW.ITING Formt lener1 corrKlly U... Ploper soaCln" Appli.. .kill. in da"'1 won. SCIENCE HfAUHlNUTRITION SOCr....L STUDIES MUSIC .....T PHYSICAL EDUCATION SOCI....L-PERSON....L DEVElOPMENT Coo~rltt!1 with olhers II cDurteau!. .1nd con'ider~r' W>rk. ind.oend.ntly \\brks ut,tullv tlnrl nr.lIl.,. Completes work on rIme Follows dirKtions Participates h.lpfully In aroup work Obey> school rules Self-conlrol Is r..pectful ... ., :;;. U if, C; IN Ie; .. Name ha, he." Iu hl/7L.liL --ril../uJ;, C ~ t3.:. ..vt.-t: Teacher', Signalure IsI 2nd Jrd .,/ r-- ./ -..I L ./ [. ", J. ,.... ~ S'" 1"'- L "" aJ -.r::. .,//' c '" r.. " IN 1\ 1\ III/ t r ,-~ ~ 4lh Tucher Comments (Second P\!!rlodl ,_ I 'If+, l4 fl.~ JI";;1 ~~aAL A~ _k~.1-jth.. dr {A'~ J. .Jr1J\,.,.I.i.~ " ll,< --II.vv ~:k wtil[T ~~ ~J..~t ~~~~ .often otf +c;lsk, ! i ~ f I.... .. RECORD OF INSPECTtON I)F PU.PIL RECORDS 'TI11l!IIT liNt! Lydia Maria Sranotf Th. tollowin. p.r.on, hav. in.p.cc.d Chi .cud.nc', r.cord, 'nd th.ir .i.nltur.. Indiuu' chu th.y will noc .hlu chi lntorut1on with, third party. . DAti SICHATUU 'UlIOS! or INS'ECTIOII tj)ifi1 _td~ ::rST,I1~~ - .' .. .,_...-.;. ...' ....~_..;..;J ~..i:'._:. . ','.' l ,~:: :. .. ;~" ,,'; .i.......~ '1.> ' 't~~~'"'' :': ,';"": . . ..' . ,_,":,;,;;+~~~:,:~,:,.' .~t;:e' ,'. ' ., . E^BT PENNBBORO ^RE^ SCHOOL DISTRICT ~AST PENNSBORO ELEMENTARY SCHOOL 1ST SUMMARY SHEET Student Name L yd/a ~t'tJ/Jofr Or-ade .::2. Teacher- J.1r.j, /!. Aarf RefeC'C'lnl;iJ Individual Jilr.$. t!.. /Jarf Oate of RefeC't"a 97 1ST M.et lng Follow-up Meeting RefeC't"ed to MDT Ye. c K -4:z. Oa t e pltu.uw~..' rqeJa,j" in 9radC. ~ III /99?-7, CONCERN I Lr!,'o.. ;5 d;sJayirlj //mi/ec1 s~ee~ wifh eompl~tl(13 work . ;ncl2fendent~'/ a nd .eorrYJlef/n~ if, tJn f/m e., She, I~ verj eas/Jj ch1./rac,rea) has c}J.P~c,ul'J sf~inq on task and tow-si n~ ~n h-tr wt'iHeh /,AJo,./<. Even wYof-h eo'nstanf v-erbaJ e.,uts I Ljd,'a, wlll i,Uot-k. Fo,.. l'J/l/j shOff per/cds ()f fime", Sht e,an p,roduce wh€.t'l ~f)rkin,1 /:1 ww.h hu- but eDmp~.j;111 work itY:I~erd~"II~ is d/fFlCJ<Jr: Sh~ e.hibif.s' diffie-wI:) wifh f}ne mohr,sKill:>, She has ~or .leHer.k~fra, -tOUe)II'lIj Gt11h.~frrtc...f 1i(1~.s IS diff,'c.u.1f and 'Aer.~paG;n.1al (f) L ycl;a. vV//I {Jomplefe wri1tGn as>sijnmenf~ independenf{y in the.a.J1offed f/rne. w/fh tIS II athieutme.nf by April lOW, @. Lydia w;'tI /eqib& complefe. as~i.9nmenfs .show/l~3 1.;I)IISi~fC"f /'/lfrou€men! by April/tJtiJ. * efween words i 5 poor, - , . _. >4" '. . ~h' , ... If I,' 'r' '-' , i i I ~ c:>., ~ I'( I - ';:.c' " , .~- ,. . ......- .. ' .. _..t: ~ :- -..... -.:: 3 ~ .. ~ ~.2~ ' j v j '~ ~ '" ..;,."1 ~ I,;" ~ -;... -~ c;' ~ ~ \;) '10 ~ vi~~ ~ ~~~1~ .'. .-I-.....~........- -... t I", ~ ~ t- ~ t-.( -- l'( ....... l:)o ~ ~ ""N' ~ , . 4.- ~ ~ ::1 ~ . tY. ~ ~ , ' ~ ~ e ~ c: ~ .~ , ~~ ~~. - .~ ~~ I ~ ~ E ~ ~. c: .~ Z 9..,'- - ~ <'"\~ -~ ..;;:;.,~ 'J......: ~ V1 rl~1: ~ ::f Cl I,".. ",'. ,.c ' J . ,......"'l-'. " . . ',',:~;." -::' I --+- C::'~ tS . 4- ~ <J\"i: ~ ""- ~ ~.. ~ ~\ _~ ~~ !:: :r'It::~ ,'- ~ :-:::- ~.l::C),)~ -.l<::l'\i...... ~ ~ ~ .~-Q._ . ""- ~ ~ ~ ~ '11, ~ ~ ~ 0') ...... ~I.~ ~ ... ~ ' .~ ~ ~ ~ ~ I.. '\]... ~ t::: "':s ') ! c ~ ~ ~ ~ ~~.. ~ .~ .~ ~} ~ "I ""- ~ ~~ ~ I 3= ~ :!") -.; ~ -+- ~ ~ -Jl.:;: ~I ~ ~ ~ ~ ~ -8 ~ ~ .~ ~ ~ ~ ~ ~ ~ . ~~~.~ 5~r~~S ~ ~ VI ~ ~ ~ 'i-.. _~ ... "'l.:::, 1 "c: ~ ~ ~ ,- -..; ~ ~ ~ tV ~ . ~ \i3 ~ <::T)...... '" Q ,!i ~.." 1 c 1l" ~ ~I" " '-'l ~.~ ~ -~, ~ ~ ~ 1--.~ () -- ~ ~ r:>. -=:: .~ ~ ~,j ~ . i l- i II j i j~ I I " . . .'>. ~~>":,:,,,'.o!., .-..,.",", . -'1:j:,",(t,-;\1*",,"1~' .,:'!" ,~.., 0" f ':'):.'-:'~"'.< .~-. . , ... -~- <3 :~ ~ "'...;) ,. ::::', ,,~'" 'l\ ~ ~ ~ .~ ~ ~ ~ ~ ~ ~ 1 t ......G l\.l q).... ~ ~ ~ ~ ~ ~ ~ i~ ~ ~ .,.. c:: ~ "'t't ~..c:: i ~ ~ \ .~~ ~ ~ ~ ~ ~9 ~ ~ ~ \;: \U (j) ,..... ~ ~ N N " ~ ~ --;r "" <:Jo ~ I'f ~ - -4.. , ~ '" ~, I I ~ b r\J) ~ ..t ~ ~ o~ j ~ ...:: ~ ~":J:: VI ~ ~ E ~ ~ Hce~~ ~ ~ ~ - 'f) ~ ~ ~ ~ i . ~ j ~ .~:::: L..~ ~";E~~ __ IIj . ~ .~ ~ ~ 3 ~ -i ~ ~ ~ ~ ~..... ~ :::r- .V\ ~ ~ ~ ... _ ~ .c: -l ... ~ \J '4\ i' ~~. ~ \J , \I'j ::5 C ~ --l ~~~ ""t.:a e~ ~ ~ ~ ~ l ~ ~ ~,~ ~ ' - , o . \ - ~ .... ~ - 'l::S ~ ~ ~ ~ o~ ~ ~.o ,~, -3 -~ ~I c: C) ~ ,.. -s ~.. ~ Ci.!. <U "3 ~ .~ c:: r::t ~" ... ~ ~ '"t'I ~ 0 -+-- ~ -~ ~ '1:: t'I'I .....a ~ ~""\j .c: or: -,.. - ~_- -+-. \l ~ v - 0 ':). -+- .- ..r;;: VI ~ -c: .::. ~ c a.. ~ "'I ~ ~ -- ~ -c ~ ""E ~ ~ .Q 'J) S ~ '-> ;~ 3~~.:.~1~~~~ . ~, \.l 0 E .0... - '() .100; c ~ .'5 'G ~ ~ ~ ~ "3 <: ~ ~ ~ ~ 1 i -I .J < ,-:: i I I\~i',: 1 . (:.~~"::l !I J ".' ~~ I ~~ J ~~ 1 ~ ~ J s I ~ i ,,"J" B ;."...,''';',:. J '-< 'i :.' '~:.) ri I f i~:',.:'; >Z R ]~ . i.<' >., ~ ] :' 1 J i ~~ III ~.. UI JC1 ~ f "B 'liI ., >. C. Ill: .J: & j, i ~ 1: '':: ~ ~ !.~ ~ l;! ~~ ~ 0; I ~ .... ~ 'Ii " ~ ~' "1 'to .~ 'v "i: ~ () ~ .s 4::l ~ t"- o- :~ ' ~ ~ ,I ~ i j __ ! ,J ~ - 3 ! . ~ ~ , " EAST PENNSBORO AREA SCHOOL DISTRICT Da. OL&NN w, ZEHNEa, 11IPEalNTENDENT CAaOLE A, CAPIUOM'l, PIUNCIPAL un PENNaaoao &LItMIINTAaV acHOOL _ PANTHU PAUWAY IINOLA. .A 11021 T&I.IIPHON& n<\+U1 March 6, 1997 Mrs, Naomi Branoff 7 Victor Drive Mechanicsburg. PA 170" Dear MIs, Branoff. Lydia Branoff has been throuah the 1ST process durina the 1996-97 ICbooJ year. Based on Lydia's classroom performance the team I. recommending a split placement for Lydia for the remainder of thi. academic year, Lydia will attend kindergarten in the morning and first grade in the afternoon. !hi. placement will bellin Monday. March 10, 1997, As a result of the split placement, Lydia will be assigned to first l\lade for the 1997.98 school year, Sincerely. CA.~ () ~r-o~ MIs, Carole A. Capriotti ( agree with the above recommendation for Lydia . Branoff, o~-oo-Q7 Date " Together We Create the Future 890 VALLEY STREET, ENOLA, PA 17015-1599 -t" Eq~ul {)pptl"~"'IY E"'p(o-,~r' WHEREFORE, Legal Services, Inc. requests that this Court grant the Motion to Withdraw as Counsel in the above-captioned case. Respectfully submitted, n , I Joan Carey Lega' Servicee, 8 Irvine Row Carlisle, PA 17013 ( 71 7) 243-9400 , ~ ) NAOMI BAANOFF, Pu\INTIFF/REPSONDENT V, JAMES BAANOFF, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERU\ND COUNTY, PENNSYLVANIA 97.2072 CIVIL TERM AMENDED ORDER OF COURT AND NOW, this 28th day of September, 1998, the order of September 24, 1998, is amended to reflect James Branoff as defendant. By the Court, / I \c~ \. Edg~, ley, J, :saa .' f';:-r:,.l-I=r:''';: rr '; - -~, -,T','1{ \,' . .';1 95 !;'='P 2l, f;I:1: to ,';}. .... ~" \..\ '1 --- '>- @ '1 ij {:: c\';;'i .~..,.... \"..~ t'...,'_'..J~T( P:\t-:':'n.'.,i/.' ~ '\, (J -j . . Ltl r. ,', >- ~ C ~.:\ - '.f ~., - , :., . .,., ~.. -- ..~ -' . :.~ , ' - ....;1") ,L ("oj 1 i: n: ~,?: l" D. t;luj ~ L>I ~ ~'I a.. II) ~~ ~ CO --) U" f..) ',: .........J ,. L;~ "- .. , , , , , \:- , .....,. '--. ~ j ) t..l: 1 C:' , , j , t. -; .:- (. ; ,. ,... '.', , - C' 0 . tP f i If ~ : i. .If,', Naomi Bri1'1Off, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY v. James Branon, Defendant : NO. 97-2fJ72 CIVIL TERM AND NOW, this ORDER "").v\~ day of \\J~, I 1998, upon consideration of the Petition of the Family Law Clinic To Make Amended Rule To Show Cause Absolute, it is hereby ordered that the Amended Rule which was issued on Naomi Branoff on October S, 1998, to show cause why the Family Law Clinic should not be allowed to withdraw u counsel for Naomi Branoff is made absolute. The Family Law Clinic is granted leave to withdraw u counsel for Naomi Branorf in the above-captioned matter. . By the court, ~/ '~ Edgar B. Bayley, J. VERIFICATION I verify that the statements made in the Petition of the Family Law Clinic to Make Amendc.d Rule To Show Cause Absolute are true and correct, to the best of my knowledge, information and belief, I understand making any false statement would subject me to the penalties of 18 Pa.C.S, 14904, relating to unsworn falsification to authorities, Date: ,d2')/';( r , \. Naomi Branoff, Pliintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNI'Y, PENNSYLVANIA v. . . : CIVIL ACI10N . LAW : IN CUSTODY : NO. 97-2072 CIVIL TERM ~ ." ? :.....J :" ::-.1 .." .'I~ -.J '" '3 '- ~~ .-'i ,. ;() - :')l"n - .' ~J => D lJ, -<; lames BmIIotf, DefeIlda.nl =': DutION OF mE FAMlJ.Y LAW CLINIC TO wrmDRAW FROM RIO'PRF.llENTATION OF TIlE PLAINTIFF. NAOl\fi BRANOFF -. The Family Law Clinic, counsel for the Plaintiff, Naomi Branoff, in the above aptioned cue, comes before the Court pursuant to Pa.R.Civ,P, 1012, and respectfully requests leave to withdraw from ~resenlation and avers in support as follows: 1. The Family Law Clinic provides free legal ~resenlation to persOIU who financially qualify for services, generally using the financial guidelines of Legal Services, Inc. Representation is normally limited to Cumberland County residents. 2. On lanuary 23, 1997, the Family Law Clinic agreed to ~resent the Plaintiff, Naomi Branoff, in her request for custody of Lydia Branoff, born luly I', 1990. At that time, Naomi Branoff was a resident of Cumberland County, Pennsylvania, whom the Family Law Clinic determined to be financially eligible. 3. On September 11, 1997, the Court entered an Order in the above-captioned case. 4. Subsequently, Naomi Branoffmoved from Cumberland County to Philadelphia, where she has obtained better employment. 5. The Family Law Clinic attempted to negotiate with Defendant', counsel I modification of the Order of September 11, 1997, after Naomi Branoff moved to Philadelphia, but no resolution of the matter was reached IS of May 22, 1998, when negotiations ended. 6. On September 8, 1998, The Family Law Clinic notified Naomi Bnnatt in writing that she was no longer financially eligible for representation based on income infonnation supplied by her, and infanncd her that she would have to obtain a private anomcy to represent her in any future litiptiOl1 in the abov~ptioned case. 7. No matters on this docket arc pending before this Court at the present time. WHEREFORE, The Family Law Clinic rcquc.sl.1 that this Court i.uue a rule on Plaintiff ... to Ihow c:ause why it should not be permitted to withdnw from rcprcscnlalion of her. , Rc.spcctfuIly submitted, 'I vtl1". C. LLf)~ NepnC. Huff i.V CertifiedLeplIntcnl MK&: I ~ @1'___' Thnmas M. Place Robert Eo Rains Katherine C. Pearson SUPERVISING ATI'ORNEY Donald Mania STAFF ATI'ORNEY FAMILY LAW CLINIC 45 North Pitt Street CadisIc, PA 17013 (117) 243-2968 Fax: (117) 243-3639 Dale: C1/,1 :c,t , VERIFICATION i" I verify thal the statemenlS made in the Petition of the Family Law Clinic to Withdraw From IepraelItation ot the Plaintiff, N:wmi Branoff, are true and correct, to the best of my knowledle, information and belief. I undmtand makinl any Ca.Ise statement would subject me to the p""..ltlH ot 18 hoC.S. 14904, relatinlto unsworn falsification to authorltla. r I Date: qj 111(,<:< jIl'L~ t. l,JJr:!i Mepn e. Huff i...iJ. ' .___.. _M. _"_"".__ ~ .- . "T..' J'-' . . .L NAOMI BRAN OFF, : IN THE COURT OF COMMON P~ Of.,. ., PLAINTIFF/REPSONDENT ,..-....: CUMBERLAND COUNTY, PENNSYLVANIA F' , ..L< V, DAVID T, KJDD, DEFENDANT 97-2072 CIVIL TERM ORDER QF CQUFll AND NOW, this 24th day ot September, 1998, upon consideration ot the petition for the Family Law Clinic to withdraw from representation of the plaintiff, Naomi Branoff, IT fS ORDERED: (1) A Rule Is issued upon the respondent, Naomi Branoft, to show cause why the petitioner, the Family Law Clinic. is not entitled to withdraw from her representation, (2) Rule returnable not later than twenty (20) days from the date 01 service. Any answer filed by respondent shall be torwarded by the Prothonotary to this chambers, :saa / TRUE C"PY FnOM RECORD In - .~" ,,'; :', " ,"" :~r my hand IOU "ld ..a. 0; U ci Court at Carli:i1c, Pa. ThiS..-:J't.A. day of~:.:, 195f.~ ~....~.....1',.wu~...._ ............... oZ>fi~>.proth~~~ . . NAOMI BRANOFF, PLAINTlFF/REPSONDENT V, JAMES BRANOFF, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , , : 97.2072 CIVIL TERM AMiNDED ORDER OF COIJRl AND NOW, this 28th day of September. 1998, the order of September 24, 1998. is amended to reflect James Branoff as defendant, By the Court, I /, \.\ ,J/) Edgar-e:~, J, :saa " DEAR JUDGE BA. SIR . 10/2/98 ~ HOW ARE YOU? GOOD I HOPE MY NAME IS NAOMI BRANOFF AND I AM WRIITING TO YOU BECAUSE I AM CONCERNED FOR MY DAUGHTER LYDIA BRAN OFF ,I DON"T KNOW WHO ELSE TO nJRN TO OTHER TIlAN YOU. YOU HEARD MY CUSTODY CASE IN AUGUST 28,1997 BRANOFF VS BRANOFF. YOU GRANTED ME JOINT AND LEGAL CUSTODY OF MY DAUGHTER AND YOU STATED IT WAS IN MY BEST INTRESET TO MOVE TO PHlLADFJUPHIA AND I PROVED IT TO YOU IN COURT, YOU LEF1' ME TAKE ONE OlILD AND Nor TIlE OTHER, I WAS FORCED TO GO TO PHILADELPHIA WITHOUT LYDIA OR I WOULD LOOSE MY JOB I WAS TOLD TO NOT APPEAL YOUR DISION GIVE THINGS A TRY THE WAY YOU ORDER IT. MR.BRANOFF TOLD YOU HE WOULD MAKE SURE LYDIA'S BEST INTREST AND EDUCATION WOULD COME FIRST.BUT THIS IS NOT HAPPENING LYDIA'S BEST INTRESTS ANRE Nor BEING MET BY HER FATHER. SINCE DECEMBER 1997 WHEN I MOVED TO PHILADELPHIA MR.BRANOFF HAS HAD I ANOTHER HOUSE FIRE MOVING LYDIA AGIAN TILL THE HOUSE WAS FIXED, THIS - IS MR.BRANOFFS 2ND FIRE IN TWO YEARS, LYDIA'S EDUCATION IS STILL SUFFER t' ING,INCLOSED ARE A COPY OFLYDIA'S SCHOOL RECORDS AND CURRENT LETTER FROM HER SCHOOL I HAVE TO GO TO ANOTHER MEETING AT SCHOOL BECAUSE SHE IS NOT DOING WELL THIS YEAR ALL READY. AND AGIAN ANOTHER SCHOOL YEAR OFF ON A BAD NOTE,MR BRAN OFF BROUGHT THESE ISSUE'S UP TO YOU AT THE 1997 HEARING, I DID NOT FEEL HE ,..OULD TAKE CARE OF HER THEN AND HE IS STILL Nor . CURRENTLY LYDIA IS IN 2ND GRADE AND Nor WORKING AT GRADE LEVEL LYDIA HAS HAD A BAD START FROM KINDERGARDEN TO PRESENT. I A}I REQUESTING A HEARING TO MODIFY CURRENT ORDER SO LYDIA LIVE WITH HER BROTHER AND I DURING THE SCHOOL YEAR.SO I CAN HELP HER HAVE A BETTER FUTURE,SULLAVAN SCHOOL IN PHILADELPHIA IS READY TO TAKE HER ON.IF YOU ALLOW IT SIR. r THE SCHOOL WERE LYDIA A'ITENDS NOW HAS SENT HE LE'ITERS SH~o/ING SHE IS IN TROUBLE AGIAN THIS YEAR. MR,BRANOFF IS NOT HTERE FOR LYDIA HE WOP~S ALL THE TIME AND LETS THE THINGS THAT CONCERN LYDIA IN THE HANDS OF THE BABBYSITIER AND THE LIVE IN GIRLFRIEND. I AM LYDIA'S BIRTH MOTHER AND I HAVE RAISED HER SINCE HER BIRTH,I DID Nor WORK THE FIRST 4 YEARS OF LYDIA'S UFE SO I COULD TAKE CARE, OF HER AND ZACH BEFORE SCHOOL STARTED. ANYTHtE I TRY TO MAKE CONTAer WITH MR.BRANOFF NO RESPONCE I HAVE TO DO EVERYTHING THROUGH THE SI'ITER. IF I WANT TO SEE HER OR SPEAICTO LYDIA IT IS THROUGH THE SI'ITER,IF I WANT TO KNOW HOW SHE IS ITS THROUGH THE SI'ITER. I HAVE TRIED TO ASK MR. BRANOFF TO LET ME BRING " LYDIA HERE TO P".IlLV fTS ON1-Y IHOUR AND 15 MINtITES AWAYFROM HIM NO RESPONCE .NOW MR.BRANOFF'S PHONE IS DISCONNECfED I HAVE GIVEN HIM 2 CALLING CARDS TO CALL ME AT NO COST TO HIM SO I CAN SPEAK TO MY CHILD AND WHEN SHE IS HERE ON WEEKENDS HOLIDAYS AND SUMMER HE HAS THE CALLING CARDS, BUT He DOES NOT USE THEM. EVER I KEEP CLOSE CONTACf WITH THE SCHOOL THE SCHOOL LAST YEAR WAS UNDER THE HIPRESSION I WAS NOT IN HER UFE UNTIL I MADE A SPECIAL TRIPTO CHECj( ON THE WELL BEING OF MY CHILD. I GAVE THE SCHOOL A COPY Of THE CURRENT ORDER. SIR I WORK EVERYDAY FROM 8:30 to 5:00 AND MY KIDS ONLY NEED nlE AF1'ER SCHOOL PROGRAM BECAUSE I CAN DROP THEM OFF AT SCHOOL EVERYDAY BECAUSE I ONLY WORK 15 MINtITES FROM THE SCHOOL-SIR MY CHILDREN ARE MY EVERITHING I CANNOT HAVE ANYl-IORE CHILDRE DUE TO MEDICAL PROBLEMS,I FEEL IT IS IN LYDIA'S BEST INTREST TO LIVE WITH ME AND HER BROTHER IN PH ILLY DURING THE SCHOOL YEAR BECAUSE MR. BRANOFF IS NOT PU'ITING HER BEST INTREST FIRST,MR BRANOFF IS WORKING ALL THE TIME AND PUTTING 'i. .... v-~ - i - - ..... "" 1 c -- C". >. 9~ <~. , C"'-; , r .' J' '- J (~ :..j (~- . to", : _.~ L '" -,;; fi: ' . : ., \J ( ) ,.I_!.1.. ;- C"J - ; , , " U G' (J J tt F " ~~ ~u-\k"J -~1...0J.l\ 'J ( , . \\\~I'i~ ~\~J "JC":::, ~(~\-c\-(} ~ uJ2W(\ '-~~.~ ~ ~~\ ~~~ Cl. , ,.4.'r ~~ cs..,~. W\\~c.,~ -\0 lY'<.>-lI"-'<1 ~ lJG.N-~ ~cu..0 ~ ~a~c\ -b ~ Ov.".., ~ Y'C\ ~ ~ Q....0....D ~ -\0 '(n<x\,~ ~w ~ ~C\~. -.J:' .I.. - " ~ -r L. ~ --eu~~~. '-10J...G ~"~6 \ u ~~ -r'-> ' , tJ I' D ~lJ 1.....QUf\, ,'~~ .....I'~. c\ ~ ,.). . (} crC\ ....., 'I..-'.J:J ~Y1 ,-.}\ G..i.~ \-..0= Cl If'"~ buL\<.J, \~'-" Vn "-.. ,~~ 'd w+,-> Uw \0..~,-,,- "''-'"U. ~ ~ ~ ~&'^- ~ -Jl...c.u..p I,~ "" "-""'-'\0.. ~ ~=\ b.. <~'-js ~ ~ ~ ~ +I..... ""'-~ <\--<e -Iu,\. Nc~ ~ "'- ~. s '-^-A<.0 k.. b ~'I "",u.. ~ cl....,..., ku ~ ~ ~L'--l"\,<, 11'-<f'W ~ 8 ~ 'i'-^""~, "-i.l t\Do"'-"",,~~_ ~ ~ ~C\~ (~, ~ Q.3~o. ~ ~ u..N ~ ~ ~ ~\~ -\-c CJI~ ~ ~cc..N:...'..)\ 0,<: 1'N.c\,u\...0 ~, f..l ~~ ~>U"'" \\-x..Y'1\6> '2>\ \I....D COl\.;' CL ~ Qj- ~~ .:.:J.J"S J:fJ;CJ .:n<.o......, ~""->~.Nj.\il'1C4 ~~y~ \~\"'.:LI....~ <}\l :2"Y2>S\' :S~ 5:, I .f UST PENNSBORO ARU SCHOOL DISTRICT 190 \llIIley Sl1'eet Enola. PA 1702S \~(' C'~l ~t. In I ~~' lu....-/ '-ll ATTENTION DEFI('IT DISORDER CONSULTATION CONFIOENTIAL ....... JteevaL CIftM Student II N_: Plinth): AddreN: 011OOO7 L}dl. Br.aoff MIM J.I1lC. Braao/f IJ~ !. Dauphin 51. ___ Enol., PA 1702~ SocI.1 Seturit} II Scl: ...L DOB: Grade: 2 177-U-91'" 7-15-90 rho..: ACI: 1-2 732-5756 Dlatrlct Residuee: [ut PeanlOOro Home Scbooi: EDt PcnlUboro lle_nlary Date of Report: 10-16-98 REASON FOR REFERRAL: Lydia was referred for an ADHD consult due concerns about her off task behavior in spite of interventions over the years This evaluation included classroom observations of Lydia, interviews with both sets of parents, a completed teacher checklist, and review of records. Lydia Branoff, aged 8-2, resides with her natural father, Jim and his girlfriend, Shannon, Shannon and Jim have a youngster, Alex, aged 14 months and also Blake, Shannon's son from a previous rulationship, who is three Lydia has ftequent visits with mother, Naomi, who lives in the Philadelphia uea with her boyfriend. Naomi's boyftiend. Gabe, has a SOil Lucas, who is age ten In addition, Naomi's son lack, age nine, lives with the family, In terms of educational history, Lydia apparently attended the Little Brown Bear's Nursery School from approximately three years to five years of age, Her parents recalled Lydia had unremarkable comments from staff there In kindergarten she attended the East Pennsboro Elementary School Her report card from then indicated that she was quite talkative and often restless with weak letter-sound understanding, The following year she split half of the year between kinderganen and first grade classes due to off task and immature behaviors. There was "needs improvements" across all sociallbehavior areas, The following year she apparently attended the Green Ridge Elementary School in lhe Cumberland Valley School District for approximat.:ly the first marking period The teacher from that school also noted her "needing to improve" her attention span, following directions, and cooperating with peers, Last year she then repeated tile first grade at East Pennsboro Elementary, Again. continued difficulties with staying on task, in spite of being on academic grade level In the second marking period she was falling off grade level expectations a bit while having "needs improvements" for working carefully, handwriting. and self-control . BranolT. Lydia-ADD Consult. Pale 1 She had undergone the instructional support team process on three occasions. She had received some form of instructional support team process The goals were usually completing homework and time on task As of 4/98, attention proDlems were noted with her having trouble completing paper pencil tasks even in spite of many teacher prompts, Favorably, she scored at a 97 percent accuracy level on level 16 (End of first grade materials) reading books at that time, Metropolitan Readiness Testing of 5/96 showed some fluctuation in her scores with her auditory percentile of25; language percentile of 18; visual percentile of 0, and quantitative percentile of 7, CURRENT TEACHER IMPRESSIONSIRA TING SCALE: Lydia's current second grade teacher indicates that she has great difficulty staying on task and completing her work Often she will wander about the room or is looking about the room even when at her desk. Her teacher completed the Conner's Teacher Rating Scale-Revised Edition, At aT-Score of 77 was the Conner's ADHD Index (T-Score of 70+ equals Clinical Significance). Also in the significant range at aT-Score of71 was the hyperactivity domain. Items endorsed under a "very much" true basis were her being inattentive and easily distracted, restless, disturbing other children, leaving her seat, fidgeting, and having a short attention span, CLASSROOM OBSERVATION: On 10/16/98, the undersigned was able to observe Lydia doing a variety of activities. Upon initial observation, she was to complete a copying/writing task, She sat in the very front of the room and in the center. While writing some words down, she was also quite talkative with her neighbor and they seemed to be sharing answers, After a few minutes the teacher noticed this and the two were separated, Lydia was then in line to have her paper reviewed by her teacher and was observed to grab at her crotch area. She then received teacher feedback and went to the bathroom where she then showed appropriate placement of her hands, However, when back at her desk she constantly had her thumb in her mouth, Later, the teacher was directing the class about a new reading story, She showed variable attention sometimes following along with the story and at other times playing with her sneaker or some other object, At other times she was standing away from her desk or would lean back in an exaggerated fashion, When called to read orally, she showed adequate skill when compared to her peers. When it was not her turn. she sometimes would completely turn around in her chair and look at others behind her. PARENT INTERVIEW: A developmental history was obtained with Jim and Shannon on 10/9/98. The parents recalled that during teacher conferences their general impression from teachers was that she could not sit still, leaves her seat, in spite of seeming to have adequate academic ability, The family has not taken her for any outside services such as speech and language or counseling help. A later interview with Lydia's mother reported that she had received some counseling through a church during this past summer. In tenns of pregnancy and birth history, no complications were recalled about Lydia, She was born as a product of a fullterm pregnancy at approximately 6 Ibs, plus oz. There were no post delivery complications and she did go right home with her parents. In tenns of developmental skills, she was recalled as doing adequately for gross motor milestones in tenns of sitting up and walking as well as achieving balance and coordination. In . Btanorr. Lydia-ADD Conlull. rl" } terms of fine motor skills, she did show some slowness in terms of establishing right hand preference While she engaged in some prewriling activities. her handwriting was not recalled as being neatly applied when younger While she was able to dress herself adequately. she did have some problems learning tie her shoes and that she was in a hurry Toilet training was achieved without incident. In terms of speech and language milestones, she spoke her first word it eight months while later achieving phrases easily In terms of her present speech and language abilities, she is viewed as speaking too quickly at times, but generally is intelligible Regarding early emotional status, she was not recalled as being colicky, hard to comfort, or difficult to establish in routines, She does have a minor touch aversion to anything around her neck, but no other aversions , ;; i. , In terms of social and emotional history, Lydia was not recalled as being an overactive youngster, However, she can be impulsive at times when it is time for her to wait her tum. In terms of ease of distractibility, she does show some problems panicularly with homework completion, Her frustration tolerance also is felt to be low in that she will want to quit. Organization skills historically have been preny weak and she will lose things, In terms of peer relati')ns, she is fell to do adequately, but also can be a bit bossy lIP f In terms of her school anitude, she generally is favorable about school and gets along adequately with her teacher, Homework ilas been a problem in that she is quite off task, but will do bener if a parent sits near her, If this does not happened, homework can take up to three hours. In terms of hobbies and interests, she is in the Girl Scouts and enjoys camping with her grandparents. In her free time she likes to be on her bike and be outside, She can get somewhat argumentative during discipline times. There have been some instances of lying on her pan, itthough she is not viewed as being cruel or outwardly defiant. She can be destructive with some of her things, but this is not in an intentional manner but she likes to take things apart. In terms of odd/strange behaviors, father and her girlfriend were concerned that she had inappropriately kissed Z:lck at one time l\lld that she and Blake will share the same bed. (Guidelines were given on how to break this habit). In terms of traumatic experience, her father's house apparently burned down at one time, but Lydia was not there, In terms of medical history, she generally has been in a good state of health. She has had a recent outbreak of lice and has been actively treated for this condition by her parents. She did have chickenpox when younger, but no other childhood illnesses. She has never been hospitalized. She may have a possible mild asthma difficulty, but no perceived allergies She has never shown any convulsions/seizures, temperature over 105, o. undergone any form of head trauma, She has no perceived vision or hearing problems. There is no history of ticing or thyroid problems on either side of the family, She did have four ear infections lasl year, but was never tubed, She does not receive any current medication nor has she been diagnosed any particular childhood syndrome She is followed by the Harrisburg Clinic and Dr Arronson, a pediatrician at SI. Anthony's Hospital in Philadelphia In terms of systems review, she goes to bed at 8to 8:30 while arising at 6:30 to 7. She is viewed as being a sound sleeper with no enuresis, She is felt to be a rather restless sleeper though. Her appetite and personal hygiene are adequate. In tenns of emotional status, she is viewed as being fairly stable with her overall mood, 'uut will complain to her parents about easily being bored She is viewed as being a tad on the sensitive side. On occasion she will show some sadness, but is not viewed as being depressed or overly sad. Anger control is felt to be adequate. She does have somlLfears about her natural mother BnBoff. Lydia-ADD Consult. PI.e ~ illd'thi w;;.ti;;') Generally she is not viewed as being an anxious child She does show ~e-adapiability to change in the family routines. At times she shows guilt about misbehavior, but sometimes makes excuses. Emotionally, she is felt to be close to her mother and father's girlfriend In terms of significant genetic history, father indicated he earned C's and B's in school, but has current difficulties with siuing still and that his mind wanders while also recalling difficulties with reading comprehension, Her mother reported that she had been diagnosed as having learning difficulty with reading comprehension when tested at age 18, Both sets of parents accused the other of previous drug and alcohol use. Lydia's father and father's girlfriend completed a SNAP Checklist. Two of five characteristics were endorsed under the hyperactivity domain for the "pretty much" area including exceS8ive running and climbing as well as motor restlessness during sleep, Two oftive were also endorsed under the "pretty much" column under the inattention domain with her seeming to not listen and having diOOculty concentrating on school work and other tasks requiring sustained attention, Four of six characteristics were endorsed under the "just a liule" and "pretty much" column under impulsiveness. SUMMARY AND RECOMMENDA nONS: Lydia Branoff, aged 8-2, had been referred for psychological consult due to possible ADHD concerns. She currently auends second grade at East Pennsboro Elementary School. She has received previous intervention via the instructional support team for off task behaviors and inconsistent work completion, While she has ahown some fluctuation in her kindergarten Metropolitan Readiness scores, she did earn a 97% when tested with grade one materials at the end oflast year A classroom observation of Lydia reading orally also suggested at least average reading skills, Lydia is a youngster who seems to be under multiple stressors in addition to having ADHD- combined type difficulties, One notes the showing of immature behaviors in terms of over dependency on her little brother, sucking her thumb, and some manipulative behaviors described by both sets of parents. There certainly would appear to be an emotional component to her difficulties also in that both sets of parents have some mistrust of each other and may relay these attitudes toward Lydia when she is visiting with them. Historical difficulties with work completion. self-control, and ea3<l "f dist.3ctibility has been seen as early as kindergarten l'lU across different school systems and teachers, The parent impressions also support her problems maintaining her focus and ease of distractibility, There also appears to be genetic support for ADHD difficulties, Based on the above, the following recommendations are offered: I, Both sets of parents were encouraged to read more about ADHD and also to take stock of Lydia's emotional difficulties and try to work together to serve her in the best manner possible, Further, consultation with the undersigned was offered, Lydia does appear to be under emotion duress due to the cOllllictual messages she hears from both sets of parents, Providing her with counseling could help her adjustment and the parents' issues, 2 There should be continued monitoring by adults in Lydia's life with any demonstrations of inappropriate sexual behavior on her pan, . Dranoff, Lydia-ADD Consult. Pa.. :! ), Lydia recently look the Slanford Achievenienl Test and these scores will be reviewed in November for indiealions of any learning problems given Ihe parents' history, Funher evaluation could follow 4, She should have regular hearing checks given her difficulties last year and earlier described problems with mastery of letter-sound relations. Should her teacher notice additional academic concerns, she may be referred for psychological evaluation, 5, A medical evaluation for ADHD difficulties would be welcomed and IlatTwould be glad to complete teacher checklists to assess the effectiveness of this intervention, (..~ ,",0 ~'~I.~. George Sc midt, Ph,O, School Psychologist I)CT :I 0 1998t:P Naomi Branoff, Plaintiff : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Y. : CIVIL ACTION - LAW : IN CUSTODY lame.t Branolf, Defendant : NO. 97-2072 CIVIL TERM ORDER AND NOW, this .:),..J.... day of .....::::t:l .,..... '.., '-' , 1998, upon consideration of the Petition of the Family Law Clinic To Make Amended Rule To Show Cause Absolute, it is hereby ordered that the Amended Rule which W33 issued on Naomi Brano{{ on October S, 1998, to show cause why the Family Law Clinic should not be allowed to withdraw 33 counsel {or Naomi Branof{ is made absolute. The Family Law Clinic is granted leave to withdraw 33 counsel {or Naomi Brano{{ in the above-captioned matter. By the court, IS/ p~, )3, ~I-(t' - Edgar B. yley, I. ., . ~0.-\ 1u.-c\0y ~(~t~~ ~~ \.,J~~ ~o..'('(J{.:.{J I\\~I~~ ~ ux:Wc\ '-~;..~ ~ ~ ~ ~~'-U:~ ~ CD\'\~~ -\0 ~\-\:.d' ~ ~ ~, ~ lJ~ ~CU-.0 ~ ~~<1-b L~ OvV\ '0(\ ~ ~ CL.l..J.J ~ +0 '<Y\cx\,~ ~ ~ G....>C\~, ..J...""-. 1.. .', -1 -r 'L. ~ ~~~, ~O ~~6 lu ~~<6.""T'--' . ......Q , L.cJ I~ D ~lJ <}Wb. ~~ ~Y1 di~("\ ~'I , . "-<41::> Q ~, k\=J\ ~ "'" ~" ,~Q '0 ~C>. <:A'-' w"'~~ ~ ~ ~ ~ ~~ "'...... ~ '" "" &xo,,, ~ ~<<>\ b.. ~'l5. ~ ~ '\u ~ ~ ""'-""", ","L ,=,. '-"-'c. ~ Q ~" .8 ~ ~. -b ~~ ""\JI.. lD, clQ",-, ~ "'" ~ ~'-'-h'" ~C<,f'W (l,YX:I 8 ~ \tlM-:>","-, C'0J ~~~cw, ~~ ~6~~,~ ~~~c:), ~ ~ <::A.~ ~ ~~ ~\~ W ~\.~ ~ ~c:....'N:.s'_)\ O'l. 1'N.c\,<su, ~lA, 0-..Q.u.J CU\~ ~Y'\~ ~~~\Q.lj~ S\ \\.il COho C'. ~ ~ ~~ ~/:S -5:J:,G -:27(0'-1 ~ V()>. \C\O-y <1I'l 21S 2~~ .:S~ ~ I ". i ~ NACl'II BRANOFF, . IN THE COURT OF CXHoIC:tl PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : VB. . NO. 97-2072 CIVIL TERM . . CIVIL ACTION - LAW . JAMES BRANOFF, : t Defendant I IN CUSTODY CIUlI!R OP CXXRT , / AND tol, this 'hV day of 0.tt!,tJ" _ upon COrl8ideration of the attached CUstody Conciliation ordered and directed as follows: , 199 ~ , Report, itTs 1. 'It1e prior Order of this Court elated Septentler 11, 1997 is vacated and replaced with this Order. 2. The Mother, Naomi Branoff, and the Father, James Branoff, shall have shared legal custody of Lydia M. Branoff, born July 15, 1990. 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. The Father shall have custody of the Child during the school year, subject to the Mother J s periods of partial custody on alternating weekends from Friday at 4:30 p.m. until S~'lday at 5:00 p.m. During the school year, the Father shall notify the Mother of all school activities, including report: cards, special events, school pictures, notable school work and any other significant events which may occur at school. Both parties shall notify each other of all major church activities involving the Child in advance. 'It1e parties shall notify each other of any medical emergencies occurring while the Child is in his or her custody and provide the other party with information ccncerning the identity of the Child's doctor and the health care facility at which care for the Child was provided. 3. 'It1e Mother ahall have custody of the Child during the sUlTl1lllr school break for the last three weeks of June, the entire mnth of July, and the first three weeks of August. 4. The parties shall share or alternate having custody of the Child over holiclays as follows: A. Christmas: In every year, the Father shall have custody of the Child from Christmas Eve until Christmas Day at 2:00 p.m. and the Mother shall have custody of the Child from Christmas Day at 2:00 p.m. through January 1st. B. Alternating Holiclays: The Mother shall have custody of the Child in odd nUllDered years on Thanksgiving Day, Easter Sunday, Spring break, Meroorial Day, July 4th and Labor Day. , \" t , , '!'he Father shall have custody of the Child in even nuntlered years on Thanksgiving Day, Easter Sunday, spring break, MemOrial Day, July 4th and Labor Day. C. Mother's Day/Father's Day: The Mother shall have cuatody of the Olild every year on Mother's Day and the Father shall have custody of the Child every year on Father's Day. D. Each parent shall be entitled to have custody of the O1ild for two full non-consecutive weeks of vacation during each calendar year upon providing thirty (30) days advance notice to the other party. The Father shall not schedule more than one (1) week of vacation time under this provision during the Mother's SlJll1\lllr period of custody. 5. Neither party shall remove the Child's residence from the state of PeM8ylvania without first obtaining a Court order or agreement of the parties approving such a move. , 1 ! .~ < ~ t L ! ~ 'f L H ~f i ~ , 6. In the event either party intends to remove Lydia fran the state of PeMsylvania for a period of vacation, that party IlDJ8t provide advance notice to the other party as well as the address and telephone nUllDer where the O1ild can be reached. ! t t t , 7. Each party shall ensure that the other party has his or her current telephone n~r and address. B. '!'he non-custodial party shall be entitled to have reasonable telephone contact with the Child. 9. Neither party shall be under the influence of illegal drugs or alcohol while in the presence of the Child. 10. 'rt1e parties shall ccmnunicate directly with each other in addressing issues affecting the Child and shall minimize interference from third parties. 11. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child ss to the other parent, or hamper the free and natural developnent of the Olild's love and respect for the other parent. 4 12. entry. '!'he Father may appeal this order within thirty (30) days after .' / BY THE rouRT, cc: Naomi Branoff, Mother James Branoff, Father / I ,.' /,.Aj/ Edgar B. ~ey,{ ('...b.~... ~ut. I~I :1'11'11. ---u- ..J "fJ J. NAa-II BRA."lOFF, plaintiff IN THE COURT OF CXXoIMCtl PLEAS OF CUMBERLAND CCXlNTY, PENNSYLVANIA vs. NO. 97-2072 CIVIL TERM JAMES BRANOFF, Defendant . . CIVIL ACTION - LAW IN CUSTODY : PRIm JUIXZ: Bdgar B. Bayley ammY a:tlCILIATIQiI SlMIARY REl'CR1' IN ACXDIDANCB WITH CDl8I!RLAND CXl.NlY ROLE CP CIVIL P9Jo ~ . lIB 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 01." BIRTH ~y IN aJSTCDY CP Lydia M. Branoff July 15, 1990 Father 2. A Conciliation Conference was held on DecentJer 22, 1998, with only the Mother, who was not represented by counsel in this matter, in attendance. The Mother stated that she had discussed the scheduled Conciliation Conference with the Father, who indicated that she would find out who his attorney was at the time of the Conference. However, neither the Father nor his attorney, attended the Conference. 3. '!his Court previously entered an order in this matter on Septenber 11, 1997, after Hearing, providing for the parties to share physical custody of thll Child on a two week on/two week off basis. The Mother was transferred by her employer to philadelphia in Decerrber 1997. The Mother filed this Petition to modify the current Custody order to provide for the Mother to have physical custody of the Child during the summer school break and the Father to have custody of the Child during the school year. 4. Based upon the Mother's representations at the Conference, the Father's failure to attend the Conference, and the fact that the proposed Custody arrangements basically reflect the current arrangements followed by the parties since at least prior to the sunmer of 1998, the Conciliator recomnends an Order in the form as attached. The proposed order permits the Father to appeal within thirty (30) days. Of U""" J~, J:5 179 F Date . ~U~'~ff~~-1' Da s. sunday, Esqu re I Custody Conciliator