Loading...
HomeMy WebLinkAbout07-1244MARY SUE SHIFFLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. N0.07- /-2 `~~° CIVIL TERM ZACHARY MATTHEW GOODLING, Defendant :CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Mary Shiffler, hereinafter referred to as Mother. Mother's permanent residence is 100B Lincoln Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Zachary Matthew Goodling, hereinafter referred to as Father, residing at 67 Conrad Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Mother. seeks a schedule for partial custody of the minor children: Name Present Residence Age Prestyn Tazz Goodling 67 Conrad Drive 8.10.03 DOB, ~3'/s years old Carlisle, PA Serenity Eliza Goodling 67 Conrad Drive 9.30.04 DOB, ~2'/z years old Carlisle, PA Prestyn anal Serenity were born out of wedlock. Prestyn and Serenity are presently in the custody of Father. During Prestyn's lifetime, he has resided with the following persons and at the following addresses: Name Address Date Mary Shiffler Zachary Goodling David Kempfer, Jr. Mary Shiffler Zachary Goodling David Kempfer, Jr. Mary Shiffler Zachary Goodling Sharon Goodling Steven Brady Heather Bayley The Brooks Apartments Williamsburg Dr Harrisburg, PA The Brooks Apartments (different street in complex) Harrisburg, PA 67 Conrad Street Carlisle, PA birth -late 8/03 late 8/03 - 9/03 9/15/03 -12/03 Mary Shiffler Zachary Goodling Gary Shiffler Rita Shiffler Robert Shiffler Mary Shiffler Zachary Goodling Sharon Goodling Steven Brady Heather Bayley Mary Shiffler Zachary Goodling Sharon Goodling Steven Brady Heather Bayley Serenity Goodling Mary Shiffler Zachary Goodling Serenity Goodling Felicia Hankey Deborah Dupert Terry Dupert Brian Hankey Lester Miller Zachary Goodling Serenity Goodling Sharon Goodling Steven Brady Heather Bayley Zachary Goodling Serenity Goodling Sharon Goodling Steven Brady Heather Bayley Julie Goodling 341h Hanover St #3 Carlisle, PA 67 Conrad Drive Carlisle, PA 67 Conrad Drive Carlisle, PA 34'/z Hanover St. #2 Carlisle, PA 67 Conrad Drive Carlisle, PA 67 Conrad Drive Carlisle, PA 1/04- 2/04 2/04 - 9/30/04 9/30/04 - 2/05 2/05 - 4/05 early 4/05 -mid 4/05 mid 4/05 - 6/05 Zachary Goodling Betty Nelson Trailer Park 6/05 - 9/05 Julie Goodling Carlisle, PA Serenity Goodling Zachary Goodling Julie Goodling Serenity Goodling Zachary Goodling Serenity Goodling Sharon Goodling Steven Brady Heather Bayley During Serenity's lifetime, she has resided with the following persons and at the various addresses b/w Zachary's parents, Julie's parents, friends' homes 67 Conrad Dr. Carlisle, PA 9/05 -1/07 1/07 -present following addresses: Name Address Date Mary Shiffler Zachary Goodling Sharon Goodling Steven Brady Heather Bayley Prestyn Goodling Mary Shiffler Zachary Goodling Prestyn Goodling Felicia Hankey Deborah Dupert Terry Dupert Brian Hankey Lester Miller Zachary Goodling Serenity Goodling Sharon Goodling Steven Brady Heather Bayley Zachary Goodling Serenity Goodling Sharon Goodling Steven Brady Heather Bayley Julie Goodling 67 Conrad Drive Carlisle, PA 341/z Hanover St. #2 Carlisle, PA 67 Conrad Drive Carlisle, PA 67 Conrad Drive Carlisle, PA 9/30/04 - 2/05 2/05 - 4/05 early 4/05 -mid 4/05 mid 4/05 - 6/05 Zachary Goodling Julie Goodling Prestyn Goodling Zachary Goodling Julie Goodling Prestyn Goodling Zachary Goodling Prestyn Goodling Sharon Goodling Steven Brady Heather Bayley Betty Nelson Trailer Park Carlisle, PA various addresses b/w Zachary's parents, Julie's parents, friends' homes 67 Conrad Dr. Carlisle, PA 4. Mother currently resides with the following persons: Name Relationship Kiara Butler Daughter 6/05 - 9/05 9/05 -1/07 1/07 -present 5. It is believed that Father currently resides with the following persons: Name Relationship Sharon Goodling Paternal Grandmother Steven Brady Heather Bayley Prestyn Goodling Serenity Goodling Paternal Grandmother's Paramour Sister Son with Mary Shiffler Daughter with Mary Shiffler 6. Mother has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of Prestyn and Serenity in this or another court. 7. Mother has no information of a custody proceeding concerning Prestyn and Serenity pending in a court of this Commonwealth. i 8. Mother does not know of a person not a party to the proceedings who has physical custody of Prestyn and Serenity or claims to have custody or visitation rights with respect to Prestyn and Serenity. 9. The best interest and permanent welfare of Prestyn and Serenity will be served by granting the relief requested for reasons including, but not limited to the following: a) Mother has a safe and appropriate home environment where she can exercise periods of partial custody with Prestyn and Serenity. b) Mother lived with Prestyn, Serenity and Father as a family unit from the time `they were born until the parties separated. She has developed close relationships with both children and believes it is important to have consistent time with both children to maintain those relationships. c) Since the parties separated, and Mother acquired her own apartment, Mother has had periods of partial custody, including overnight visits, with the children. The children are familiar with Mother's home and are comfortable with her during their visits. d) Mother is willing and able to continue to be active involved with the children as well as with their educational activities, extra-curricular activities, and other such endeavors. e) Mother has worked closely with Children and Youth Services to help develop effective parenting strategies and has been very successful in adopting recommendations and suggestions from her caseworker to establish a safe, happy and healthy home environment for the children at issue in this matter as well as her daughter from a subsequent relationship. f) Since February 2, 2007, Mother has had periods of partial physical custody on Monday, Tuesday, Friday and Saturday from 6:00 a.m. until 4:00 p.m. She has had additional times on some Thursdays, some evenings when Father runs errands or cannot be with the children, and some Sunday visits for church. Additionally, the children have each had two overnight stays with Mother in the past month. g) Father has not acted in Prestyn's and Serenity's best interests in ways including but not limited to the following: i) Depending on the status of Father's relationship with his current wife, Father arbitrarily decides when and if Mother can visit with Prestyn and Serenity. Presently, the parties have followed a consistent schedule but without an Order, Father can determine whether the schedule continues or whether Mother will again be cut off from the children. ii) Father does not regularly communicate with Mother to co-parent the children and makes decisions about the children without Mother's input. This month, since Father and his current wife are separated, Mother was permitted to make and attend medical appointments with the children. iii) Father's decisions regarding Mother's time with the children depends of the status of his relationship with his current wife. If Father and his wife are together, Mother is not permitted to visit ., , with the children or participate in decisions regarding their well= being. When Father and his wife are separated, Father allows Mother regular, ongoing contact with the children. iv) Father's inconsistency regarding Mother's visits with the children interferes with Mother's ability to maintain and nurture a loving, healthy mother/child relationship with the children. 10. Each parent whose parental rights to Prestyn and Serenity have not been terminated and the person who has physical custody of Prestyn and Serenity have been named as parties to this action. WHEREFORE, Mother requests this Court to grant her periods of partial physical custody and shared legal custody of Prestyn and Serenity. Mother further requests any other relief that is just and proper. Respectfully submitted, Je i~a Holst, Esquire d Penn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named PLAINTIFF, Mary Shiffler, verifies that the statements made in the above Complaint For Custody are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: ~ b~- .. MARY SUE SHII~~LER, vs. Plaintiff ZACHARY MATTHEW GOODLING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.07- ~~ `~ y CIVII. TERM CUSTODY AFFIDAVIT OF SERVICE BY MAII. I, Jessica Holst, do hereby swear that I served Zachary Matthew Goodling with a Complaint For Custody on 3 ' ~ ~ O'ff' , 2007 by certified mail, return receipt, restricted delivery, to the person and address below: Zachary Matthew Goodling 67 Conrad Drive Carlisle, PA 17013 I, Jessica Holst, verify that the statements made in this Affidavit of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 3~ ~ ~ ~~- Signatur t ('} n~ c',-, ~ '--+ 't') _, ~~ T r- P -, r-,. ' - _ '~-1 ` r~-J "i"t A ,<.s .~- .:) ~ ~~ ~.,..~ - ~~-~ ~.t -~. MARY SUE SHIFFLER, vs. Plaintiff ZACHARY MATTHEW GOODLING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.07- J a ~ CIVIL TERM CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Mary Shiffler, Plaintiff, to proceed in forma a~ uperis. I, Jessica Holst, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Jess~cal Holst, Esquire Mi enn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 e~y _,. '--,, _ ~ '^'~ ^~ _. .~,.-~ ~,~ i ""~ -__ _r "'.::• - )j ~ ` ) rr i• ~'~ MARY SUE SHIFFLER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ZACHARY MATTHEW GOODLING DEFENDANT • 07-1244 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, March 12, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, April 13, 2007 at 2:00 PM for aPre-Hearing Custody Conference. At such conference, an effort wilt be made to resolve the issues in dispute; or if this cam~ot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children aPe five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl ~J. Mangan, r., Esq"~ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with T)isabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. 1F YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 G~ G''~bjl/ ~yyy> --y. •„s ~ ~~~/ ~~, ;~~ ~ ~ o~,r,, ~' ~.. ,~ ~ irk t'~fy rL~ f.: ~ 'Ui i~diJ i 3 LI'9 ~~~~ ~r3~f' ~ , ~,~ ~_~~. ~ ~Nh ~0 ~ tr,~ ~ i ~ ~~ IE:~ ..+ . Mary Sue Shiffler, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. DOMESTIC RELATIONS SECTION CIVIL ACTION - Custody Zachary Matthew Goodling, Defendant DOCKET # 07-1244 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Zachary M. Goodling, the Defendant in the above captioned matter. /~l~c~ I l ~ 2007 Jacob M. Theis Certified Legal Intern Anne d-Fox Supervis' g Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax: (717) 243-3639 ~'_ c ~''Y~t"1 ..~ ~"t`! ~, ~ ti -' a ~_,~ ~-- ti=-yY t'i ,. ',, `. ~,N. ~~ r 4. Kra Mary Sue Shiffler, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~. :DOMESTIC RELATIONS SECTION CIVIL ACTION -Custody Zachary M. Goodling, Defendant :DOCKET # 07-1244 CERTIFICATE OF SERVICE I, Jacob Theis, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of the foregoing Praecipe to Enter Appearance on Plaintiff's attorney, Jessica Holst at MidPenn Legal Services, 401 E. Louther Street, Suite 103, Carlisle, PA 17013, by Facsimile to 717-243-8026, and by depositing a copy of the same in the United States mail, postage prepaid, on April 12, 2007. acob Theis Certified Legal Intern Anne c onald-Fo Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ~ ~ ~~ =c'1 C.Y .~~ .~~~'- t_J ^'"^ } ~' ~;~ ~ ~:4 ~_ {„+.' MAY 0 2 2001,g~ Mary Sue Shiffler, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Zachary Matthew Goodling, Defendant 07 - 1244 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVII. PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Children who are the subject of this litigation is as follows: NAME Prestyn Tazz Goodling Serenity Eliza Goodling DATE OF BIRTH 8/10/2003 9/30/2004 2. A Conciliation Conference was held on April 13, 2007 with the following individuals in attendance: The Mother, Mary Shiffler, with her counsel, Jessica Holst, Esquire, and the Father, Zachary Goodling, with his counsel, Family Law Clinic, Jake Theis, Certified Legal Intern. 3. The parties agreed to the entry of an Order in the form as attached. L S Date ~ John gan, Esquire Cu dy onciliator ~~ Mary Sue Sniffler, Plaintiff v. Zachary Matthew Goodling, Defendant IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA 07 - 1244 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT 'Ch AND NOW this g day of May, 2007, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. The Mother, Mary Sniffler, and the Father, Zachary Goodling, shall enjoy shared legal custody of Prestyn Tazz Goodling, born 8/10/2003 and Serenity Eliza Goodling, born 9/30/2004. 2. The Father shall enjoy primary physical custody of the minor children. 3. The Mother shall enjoy periods of temporary physical custody of the minor children on Wednesday at 9:00 AM through 5:00 PM, with the following weekend from Friday at 5:00 PM through Sunday at 5:00 PM. The following week, Mother shall be granted temporary physical custody of the minor children on Tuesday and Thursday from 9:00 AM to 5:00 PM, with the next scheduled visitation to occur on the following Wednesday. This schedule shall begin on Wednesday, April 18, 2007. The Father, Zachary Goodling, shall transport his minor children to facilitate visitation with the Mother, Mary Schiffler, or as the parties may mutually agree upon transportation. 4. Holidays: Christmas and Thanksgiving shall alternate every other year. In the year 2007, the Father shall have the minor children from Christmas Eve night through Christmas day at a time mutually agreed upon by the parties and Mother shall have the minor children on Thanksgiving to be alternated every other year. All other holidays shall be mutually agreed to by the parties. Mother shall have the minor children on Mother's Day and Father shall have the minor children on Father's Day. 5. Neither Mother nor Father shall consume alcohol to the point of intoxication while the minor children are in their care and custody. 6. Each party shall enjoy one (1) week of uninterrupted visitation or custody with the children during the summertime and the requesting party shall give the other party two (2) weeks prior notice. Should either parent wish to take the minor children out of the Commonwealth of Pennsylvania, two (2) weeks notice shall be given to the other parent. 7. Should either parent wish to move out of the Commonwealth of Pennsylvania, either party has the right to file a request for a conciliation to modify the current Court Order. 8. The Mother shall take her medication as prescribed. 9. Should either custodial .pazent require babysitting services while the children aze in their caze, the other pazent shall have the right of first refusal for babysitting. 10. Should either pazent schedule any medical appointments for the minor children, that parent shall give twenty-four (24) hours notice of the doctor's visit to the other parent. 11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, ~~ ,. ~~ ~.• - hh~ ~V `b .~ D' tri ution: ca Holst, Esquire J e Theis, Certified Legal Inte , F ily Law Clinic John J. Mangan, Esq. Conciliat ~~~.I~^ %~'~~ (~ ~~ :~ ~~c~ ~~ t~~~~ ~~~~ ~;~<.arAr-f1;~~1~ 9 ?? ` ?t f r Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY MARTSON LAW OFFICES I.D. 71512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff/Petitioner MARY SUE WOODS f/k/a MARY SUE SHIFFLER, Plaintiff/Petitioner v. ZACHARY MATTHEW GOODLING, Defendant/Respondent R 21 P11 3- 2 & FALLER 1MMBER' j;rq Cry ti= RENNSYLVAt41A , t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-1244 CIVIL ACTION - LAW : IN CUSTODY PETITION TO ENFORCE AND MODIFY EXISTING CUSTODY ORDER AND NOW, comes the Plaintiff/Petitioner, Mary Sue Woods f/k/a Mary Sue Shiffler, by and through her attorneys, MARTSON LAW OFFICES, and files this Petition as follows: 1. Petitioner is Mary Sue Woods f/k/a Mary Sue Shiffler who currently resides at 436 North Pitt Street, Apt. 2, Carlisle, Pennsylvania, with her husband, Shawn Woods, and her daughter, Kiara, born August 19, 2006. 2. Respondent is Zachary Matthew Goodling, who currently resides at 318 North West Street, Carlisle, Pennsylvania, with his wife and the two children who are the subject of this custody matter. 3. In 2008, the parties entered into an agreed Order for Custody dated May 8, 2007, for the two minor children, Prestyn Tazz Goodling, born August 10, 2003; and Serenity Eliza Goodling, born September 30, 2004. A copy of the Order is attached hereto as Exhibit "A." 4. Since the entry of that Order: a. Father has failed and refused and continues to fail and refuse to provide Mother with temporary custody set forth in the Order. When Mother requests her periods of custody, Father through his wife, tells her they simply have other plans. b. Father has failed and refused and continues to fail and refuse to provide ?FP Mother with information concerning the children as required by the shared legal custody requirement. Specifically, Father has not provided Mother with information concerning the school, copies of report cards, and has not listed Mother as a contact person or involved parent with the school district. Actually, there are two school districts involved since one of the children is a special needs child. C. Father has refused to speak to Mother at all, does not even look at her when she is in his presence and insists that all of their contacts be through his wife. These contacts with his wife have not gone well. Mother has been called a "whore" and a "one-night stand" in the presence of the children. 5. Since the entry of the Custody Order on May 8, 2007, the children have entered school and the weekdays granted to Mother as temporary custody are impractical during the school year. In lieu of full custody days as set forth in the Order, Mother is willing to accept evenings only on those days when the children are in school. 6. The Honorable M. L. Ebert, Jr., has been involved in this case and John J. Mangan, Esquire, has been the Conciliator. WHEREFORE, Plaintiff/Petitioner requests that her custody rights be enforced and re- enforced with the Defendant/Respondent, modified as set forth herein. MARTSON LAW OFFICES Thomas J. WilliamVsquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff/Petitioner Date: March Zd , 2012 Mary Sue Shiftler, IN TILE COURT OF COMMON PLEAS OF Plaintiff CUhMERLAND COUNTY, PENNSYLVANIA v ' 07-1244 Cron. ACTION LAW Zachary Matthew Ooodling, IN CUSTODY Defendant O O' OIX AND NQ't1V this clay of May, 2007, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: l . The Mother, May Shiffler, and the Father,-Zachary Goodling, shall enjoy shared legal custody of Prestytr Tazz Goodling, born 8/10/2003 and Serenity Eliza Goodling, born 9/30/2004. 2. The Father shall enjoy Primary physical- oustody of the minor children, 3. The Mother shall- enjoy periods;of temporary physical custody of the minor children on Wednesday at, 9:00 -AM through 5:00 PM, with the following weekend from Friday at 5:00 PM through Sunday at 5:00 PM. The following week, Mother shall be granted temporary physical custody of the minor children on Tuesday and Thursday from 9:00 AM to 5:00 PM, with the next scheduled visitation to occur on the.following Wednesday. This schedule shall begin on Wednesday, April 18, 2007. The Father, Zachary CYoodling, shall transport his minor children to facilitate visitation with the- Mother, Mary Sehiffler, or as the parties may mutually agree upon transportation; , ' 4. Holidays: 'Christmas and TI anksgiving shall alternate every other year. In the year 2007, the Father shall have the minor children from Christmas Eve night through Christmas day at a time mutually agreed upon by the parties and Mother shall have the minor children on Thanksgiving to be alternated every othor•year. All other holidays shall be mutually Mother shall have the minor children on Mother's Day and Father shall have them or children on )Father's Day. 5. Neither Mother nor,Father shall consume alcohol to the point of intoxication while the minor children are in thelrscare Md'-custody. 6. Each part -shall ep?o? one (1) week of uninterrupted visitation or custody with the children during the summertime and the requesthig party shall give the other party two ) we pri notice., Should either parent wish to take the minor children out of the Commonwealt or Pennsylvania, two (2) weeks notice shall be given to the other parent, 7. Should 'either parent wish to move out of the Commonwealth of Pennsylvania, either party has the right to-fuea request for a conciliation to modify the current Court Order, LOT-9 MAIM 888-1 EXHIBIT "A" -WOE WOW Zt,-LL-ZA S. The Mother shall take hdr medication as prescribed. 9. Should either custodial Parent require babysitting services while the children are in their care, the other parent shall have the right of first refusal for babysitting, 10. Should either parent schedule any medical appointments for the minor children, that parent shall give twenty-four (24) hours notice of the doetofs visit to the other parent. 11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions- of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, ? s. Distribution: ?. Jessica Holst; Esquire . Jake Theis, Certified Ugal Intein, Family Law Clinic John J. Mangan, Esq. Conciliator 1 Y, !"A RrTORD I n Testi;,r , -.•t my hand grad a s?i, ; i, p T ......... ar, ri.. LOT-d 900/900d 888-1 -WOE W:01 ZL,-LZ-ZO MAY 0.2 2007 fl Mary Sue Shiffler, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND couNTY, PENNSYLVANIA V. 07 - 1.244 CIVIL ACTION LAW Zachary Matthew Goodling, IN CUSTODY Defendant 0='0DY CO gamTYON gIM11LA g UN ACCORDANCE WYTH CT.TNIDFRI,AND COUNTY RULE OF CIM PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1 • T44crtiuent inforina0on pertaining to the Children who are the subj cot of this litigation is-as follows: NAMM DATE-Qj BIRTH Prestyn Tazz 4oodling 8/10/2003 Screnity Eliza. Goodling 9/30/2004 2. A.Conciliatiori Conference was,held on April 13, 2007 with the following individuals in attendance:: The Mother, Mary, ShiPIIer, with her counsel, Jessica Holst, Esquire, and the •Pather, Zachary Coodling, with his counsel, Family Lave Clinic, Jake Theis, Ceitificd Legal intern. 3. The pafties agreed to the entry of an Order in the form as attached. Date LOT-3 900/900d 888-,1 John 8?,lysqui C dy onciiiator l -WOM 2:01 311-LL-ZO VERIFICATION The foregoing Petition is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. P'k?U< Vary ue Woods M e Shiffler CERTIFICATE OF SERVICE I, Tricia D. Eckenroa.d, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Petition to Enforce Petition to Enforce and Modify Existing Custody Order was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Mr. Zachary Matthew Goodling 318 North West Street Carlisle, PA 17013 MARTSON LAW OFFICES Trici D. Ec e oad Ten East High et Carlisle, PA 17013 (717) 243-3341 Dated: Marche, 2012 F:\FILESTlients\13994 Pro Bono\13994.30 Woods\13994.30.pra Revised: 3/19/12 4:27PM t Nt PRO1 t1`1r Thomas J. Williams, Esquire 2012 MAR 21 PPS 3: Vat? ` MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALL" BERLAND MARTSON LAW OFFICES PENNSYLVANIA t r' I.D. 71512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff/Petitioner MARY SUE WOODS f/k/a MARY SUE SNIFFLER, Plaintiff/Petitioner V. ZACHARY MATTHEW GOODLING, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-1244 CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Mary Sue Woods f/k/a Mary Sue Shiffler, Plaintiff, to proceed in forma ap uperis. I, Thomas J. Williams, Esquire, attorney for the party proceeding in forma pauperis, certify that I believe the parry is unable to pay the costs and that I am providing free legal service to the party. MARTSON LAW OFFICES By i k's %^-k `A C"' ' Thomas J. William F Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: 3 Z C) , L MARY SUE WOODS F/K/A MARY SUE IN THE COURT OF COMMON PLEAS OF SNIFFLER c-, . , PLAINTIFF CUMBERLAND COUNTY, PENNSYLVA 2007-1244 CIVIL ACTION LAW - --? = 4 ZACHARY MATTHEW GOODLING c , t IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, March 26, 2012 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, April 27, 2012 at 9:00 AM 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. Failure to appear at the conference may provide grounds for entry of a temporary or pennanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ohn . Man an r. Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street / G?? ??o?-S Carlisle, Pennsylvania 17013 ???, ??/ ?N?a? Telephone (717) 249-3166 c v r Gam `?? /1<0 , rod f. aV ?p - 6nc/%a ?r oy "Od Q'Fy Place d in ,?a y s117112 4C 91 MARY SUE WOODS F/K/A MARY SUE IN THE COURT OF COMMON PLEAS OF SHIFFLER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. 07 - 1244 CIVIL ACTION LAW ZACHARY MATTHEW GOODLING, IN CUSTODY Defendant Prior Judge: M.L. Ebert, Jr., J. ORDER OF COURT AND NOW this 16'r day of May 2012, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Mother, Mary Woods, and the Father, Zachary Goodling, shall enjoy shared legal custody of Prestyn Tazz Goodling, born 8/10/2003 and Serenity Eliza Goodling, born 9/30/2004. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody: The Father shall have primary physical custody of the Children subject to Mother's partial physical custody on a repeating two week schedule as follows: a. During the school year, commencing 05/11/12, Mother shall have physical custody of the Children on alternating weekends from Friday 6:00 pm until Sunday 6:00 pm. b. During the summertime, in week one, the Mother shall enjoy periods of physical custody of the minor children on Wednesday at 9:00 am through 5:00 pm, and then from Friday 6:00 pm until Sunday 6:00 pm. In week two, Mother shall have physical custody of the Children on Tuesday and Thursday from 9:00 am to 5:00 am. C. The non-custodial parent shall pick up the Children to begin periods of physical custody. In the event a parent fails to exercise their custodial period, the parent that has custody of the Children shall retain custody until the next scheduled custodial period for the other parent. d. The custodial parent shall ensure that the Children attend their scheduled extra- curricular events when the Children are in their respective custody. e. The parties may alter the physical custodial schedule by written mutual agreement. Counseling: The Children shall continue to engage in their counseling as recommended. Additionally, Mother shall make efforts to become involved and attend the Children's counseling appointments as often as possible. At a minimum, Mother shall attend between three to four sessions in the next three months. 4. Holidays: In the absence of agreement otherwise, the parties shall adhere to the holiday schedule as attached. The parents have agreed to have joint birthday parties for the Children. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 6. Each parent shall have two non-consecutive weeks of vacation with the Children per summer. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 7. In the event the custodial parent should take the Children out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 8. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. 9. In the event of a medical emergency, the custodial party shall notify the other parties as soon as possible after the emergency is handled. 10. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 11. The Mother shall take her medication as prescribed. 12. Should either custodial parent require babysitting services for a period of time in excess of four hours while the children are in their care, the other parent shall have the right of first refusal for babysitting. 13. Should either parent schedule any medical appointments for the minor children, that parent shall give twenty-four (24) hours notice of the doctor's visit to the other parent. 14. Relocation. The parties are advised that neither party shall hereafter relocate the child or children if such relocation will significantly impair the ability of a non-relocating party to exercise his or her custodial rights unless (a) every person who has custodial rights to the child/children consents to the proposed relocation or (b) the court approves the proposed relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337. 15. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of written mutual consent, the terms of this Order shall control. By the Court, Distribution: The Family Law Clinic Thomas Williams, Esq. ? John Mangan, Esq. TIMES EVEN ODD HOLIDAYS AND YEARS YEARS SPECIAL DAYS Easter Day 1St Half From 9 am until 3 m Father Mother Easter Day 2n Half From 3 m until 9 pm Mother Father Memorial Day From 9 am until 9 m Mother Father Independence Day From 9 am until 9 pm Father Mother Labor Day From 9 am until 9 m Mother Father Halloween From one hour before trick or Father Mother treating to one hour after trick or treating Thanksgiving 1St From 8 am Thanksgiving Day to 2 Father Mother Half pm on Thanksgiving Da Thanksgiving 2° From 2 pm on Thanksgiving Day to Mother Father half noon the day after Thanksgiving Day Christmas 1St Half From noon on 12/24 to noon on Father Mother 12/25 Christmas 2n Half From noon on 12/25 to noon on Mother Father 12/26 New Year's From 6 pm 12/31 until noon January Mother Father 1St (with the 12/31 year to control the even/odd determination) Mother's Day From Saturday 6 pm until Sunday 6 Mother Mother m Father's Day From Saturday 6 pm until Sunday 6 Father Father pm na rnw = rn Wr- X M _ A co --t w cn -r? Z i? MARY SUE WOODS F/K/A MARY SUE IN THE COURT OF COMMON PLEAS OF SHIFFLER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. ZACHARY MATTHEW GOODLING, Defendant Prior Judge: M.L. Ebert, Jr., J. 07 - 1244 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of birth Currently in the custody of Prestyn Tazz Goodling 8/10/2003 Primary Father Serenity Eliza Goodling 9/30/2004 Primary Father 2. A Conciliation Conference was held on April 13, 2007, an Order issued May 08, 2007 and a conciliation conference was held April 27, 2012 with the following individuals in attendance: The Mother, Mary Woods, with her counsel, Thomas Williams, Esquire The Father, Zachary Goodling, with his counsel, Family Law Clinic 3. The parties agreed to the entry of an Order in the form as attached. U1/?- ? Date John . M gan, Esquire Cus y onciliator Mary Shiffler Woods, Plaintiff V. G0al?in Zachary Pefe Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : NO. 07-1244 CIVIL TE C ?5 z m v_ ?? tv l -C r CD t- -tc A n c? PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Zachary Goodling, Petitioner/Defendant, to proceed in forma pauperis. The Community Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date ( t"'!4 1 ?? LA J4?- Marisa Burkett Certified Legal Intern MEGO RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ZACHARY GOODLING, Plaintiff V. MARY SHIFFLER WOODS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 07-1244 CIVIL TERM CERTIFICATE OF SERVICE I, Marisa Burkett, Certified Legal Intern, Community Law Clinic, hereby certify that I am serving a true and correct copy of the Petition for Special Relief Seeking Emergency Custody on Mary Shiffler Woods, residing at 436 N Pitt St., Apt B, Carlisle, PA 17013, by depositing a copy of the same in the United States mail, first class. ?uiU' o K,44z?- Marisa Burkett Certified Legal Intern `--> ? C C) ZACHARY GOODLING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY MARY SHIFFLER WOODS, Defendant : NO. 07-1244 CIVIL TERM ORDER OF COURT Q'th AND NOW, this 14 l day of u (% t_ , 2012, upon consideration of the attached Petition, it is hereby ordered as follows: Petitioner, Zachary Goodling, is granted sole physical custody of Serenity and Prestyn Goodling pending further Order of Court. W'%? be st-lut- A "ter A Hearing on this matter ' before the Honorable Judge M. L.Ebert Jr. FOR THE CO_....., By: / C") C) -'-, cc: e Community Law Clinic, for Plaintiff -O :x rn r-- =,-n Mary Shiffler Woods, Pro se . zrn a „nr ` Cs c CA -<> ? = C CJ , L? "Vied z r ? ? t.3 MARY SNIFFLER WOODS, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN V. ZACHARY GOODLING, DEFENDANT NO. 07-1244 CIVIL IN RE: FATHER'S PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 16th day of July, 2012, after further review of the Father's Petit for Special Relief and the Order of Court dated June 29, 2012, regarding that Petition, IT IS HEREBY ORDERED AND DIRECTED that The Court Administrator shall schedule this matter to be heard before a custody conciliator as soon as practicable. By the Court, Community Law Clinic For Father Mary Shiffler Woods, Pro Se ?John Mangan, Esquire Custody Conciliator M. L. Ebert, Jr., J. r..) r7l 7 r- 3 > J C7 : -r .JV Court Administrator bas & p. es MARY SHIFFLER WOODS IN THE COURT OF COMMON PLEAS OF PENNSYLV CUMBERLAND COUNTY PLAINTIFF , V. ?,,. 2007-1244 CIVIL ACTION LAW to =x't?; ,..? ZACHARY GOODLING IN CUSTODY DEFENDANT C-3 ORDER OF COURT AND NOW, Monday, July 23, 2012 , upon consideration of the attached. Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the co ciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, August 03, 2012 at 2:3 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in disp te; 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR. THE COURT. By: _/s/ John J Mangan, Jr., Esq. _ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Am( with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangen must be made at least 72 hours prior to any hearing or business before the court. You must attend the sch conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NO' HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ?de?? J r. ?s a,,,-lld7?r ???%l 0pp,.e-, ~~ MARY SUE WOODS F/K/A MARY SUE 1N THE COURT OF COMMON PLEAS OF SNIFFLER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. 07 - 1244 CIVIL ACTION LAW ZACHARY MATTHEW GOODLING, IN CUSTODY Defendant Prior Judge: M.L. Ebert, Jr., J. ORDER OF COURT AND NOW this ~ day of September 2012, upon consideration of the attached Custoddy Conciliation Report, it is Ordered and Directed as follows: 1. This Order is entered pursuant to a Custody~onciliation Conference. A Custody Hearing hereby scheduled on the J per- day of ~•.e~~- , 2x12 at /; 41S aet/pm in Courtroom number 2 in the Cumberland County Court of Common Pleas, Carlisle, PA 17q~3 at which time testimony will be taken in regard to the physical custody for the subject Child. ' for purposes of this hearing, the Mother shall be deemed to be a moving party and shall proa~ed initially with testimony. Counsel for each party shall file wi~h the Court and opposing counsel a Memorandum setting forth each parry's. position on custody, a list of witnesses who will Abe expected to testify at the.hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to th$ hearing date. 2. Lesal Custody: The Mother, Mary Woods, and the Father, ~achary Goodling, shall enjoy '. shared legal custody of Prestyn Tazz Goodling, born 8/10/2~J03 and Serenity Eliza Goodling, born 9/30/2004.. The parties shall have an equal right tom a all major non-emergency decisions affecting the Children's general well-being includ' g, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, $ach parent shall be entitled to all records and information pertaining to the Children including,'',but not limited to, medical, dental, religious or school records, tl~e residence address of the Children and of the other parent. To the extent one parent h~s possession of any such recd#'ds or information,, that parent shall be required to share the samle, or copies thereof, with the gltlier parent within such reasonable time as to make the records axld information of reasonable use to the other parent. 3. Physical Custody: The Father shall have primary physical cau tody of the Children subject''to Mother's supervised partial physical visitation/custody as follows: a. Mother shall have visitation two times per week. Mother shall have visitat}~n every Sunday from 4:00 pm unti16:00 pm and one other evening per week! or two hours by agreement of the parties. Fathejr shall give Mother a copy of his work schedule so that the visits may be planned accordingly. Mother's visitation shall occur in a neutral public location, such as Biddle Mission Perk or some other appropriate location. Father, pat~rnal grandmother or some other mutually agreed upon person shall also supervise Mother's visitation. b. Mother shall contact Father to confirm her periods of visitation two hours prior to the visit. Failure by Mother to attend said visits may result in her forfeiting said visits. c. The custodial parent shall ensure that the Children attend their scheduled extra- curricular events when the Children are in their respective custody. d. The parties may alter the physical custodial schedule by written mutual agreement. 4. Counseling: Tl~e Children shall continue to engage in their dounseling as recommended. Additionally, Miother shall make efforts to become involved end attend the Children's counseling appointments as often as possible. At a minimum;, Mother shall attend between;,' three to four sessions in the next three months. 5. The non-custodial parent shall have liberal telephone contact',with the Children on a reasoz~~ble basis. 6. Neither party may say or do anything nor permit a third party! to do or say anything that ma estran a the Children from the other party, or injure the opinion of the Children as to the o~ier g party, or may hamper the free and natural development of the Children's love or affection t}or the other party. To the extent possible, both parties shall not allow third parties to dispara~e the other parent in the presence of the Children. 7. In the event of a medical emergency, the custodial party shah notify the other parties as sopn as possible after the emergency is handled. 8. During any periods of custody or visitation, the parties shall i~ot possess or use illegal substances or consume/be under the influence of alcoholic bwerages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household'..' members and/or house guests comply with this provision. 9. The Mother shall take her medication as prescribed. 10. Should either parent schedule any medical appointments for the minor children, that parent shall give twenty-four (24) hours notice of the doctor's visit to the other parent. 11. Relocation. The parties are advised that neither parry shall hereafter relocate the child or children if such relocation will significantly impair the ability of anon-relocating party to exercise his or her custodial rights unless (a) every person who has custodial rights to the child/children consents to the proposed relocation or (b) the court approves the proposed relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S', §5337. 12. This Order is entered pursuant to ~~~ ~ iation Conference. The parties may mpdify the provisions of this Order b~k~ { ~Q absehce of written mutual consent, the terms of this Order shall contr 1 ~ ~ ~$ Nb L- d3S tidy the Court, '.~~`~10Nn~1Otid 3N~..~"' ~~i~~0-a3~: J. Distribution: /~ The Family Law Clinic I~T'homas Williams, Esq. John Mangan, Esq. C®p;es ,~, I ~~ 9 /7/~a ~~ MARY SUE WOODS F/K/A MARY SUE 1N THE COURT OF COMMON PLEAS OF SHIFFLER, CUMBERLAND COUNTY, PENNSYLVANY:A Plaintiff v. ZACHARY MATTHEW GOODLING, Defendant Prior Judge: M.L. Ebert, Jr., J. 07 - 1244 CAVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY T~ULE OF CIVIL PROCED~RE 1915.3-8(b), the undersigned Custody Conciliator submits the follov~ing report: 1. The pertinent information pertaining to the Children ~1vho are the subject of this litigation is as follows: Name Date of birth ~urrently in the custody of Prestyn Tazz Goodling 8/10/2003 Nrimary Father Serenity Eliza Goodling 9/30/2004 primary Father 2. A Conciliation Conference was held on April 13, 207, an Order issued May 08, 207, a conciliation conference was held April 27, 2012, ate Order issued May O1, 2012, Order issued June 29, 2012 re petition for special reli~f, an Order issued July 16, 2b1,12 and a conciliation conference was held August 08, 2812 with the following individt}als in attendance: The Mother, Mary Woods, with her counsel, Thomas Williams, Esquire The Father, Zachary Goodling, with his counsel, The' Community Law Clinic 3. The parents' position on custody is as follows: Father has significant concerns regarding Mother's living arrangements, specificallyinadequate home conditions, financial resources and hygiene issues for the Child. ',Father has additional concern$ regarding adequate supervision of the Child. Father ~equests that Mother's visitatidn not occur at her residence at this time until the lice ai~d other conditions are improved. Father's requested that Mother's visitations occur in !,a neutral place, such as in the community or at his mother's residence. Father just !would like some advance notice of the requested time. Father also agreed to give Mother a copy of his work scheduh.~~ Father further requested that he or his mother supervised the visits. Mother denies the allegation that her residence is no proper for the Children to come. Mother indicated that representatives from CYS and~the Steven Center come out randomly and there are no concerns. Mother indicat~ that any problem in regard Igo lice has been dealt with. Mother has a license, but nb vehicle. Mother indicates that she has a good relationship with paternal grandmother. Mother asserts that she does nmt necessarily have a problem with Father, but rather h1s wife. 4. The Conciliator recommends an Order in the form as attached scheduling a Hearing and entering an Order of Court regarding custody as outlined. It is the Conciliator's belief that this would be in the Child's best interest. It is expected that the Hearing will require one half day. 5. The proposed recommended Order may contain a requirement that the parties file al~re- trial memorandum with the Judge to whom the matter'has been assigned. l ~. Date Jo J. angan~ Esquire Cu tod Conciliator