HomeMy WebLinkAbout03-0538
MATTHEW D. CONCANNON,
Plaintiff
: TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 03 - s3f
Cw~l '1~
ERlN CONCANNON,
Defendant
: CIVIL ACTION - AT LAW
: CUSTODY
COMPT ,ATNT TN cnSTonv
AND NOW, the Plaintiff, Matthew D. Concannon, by and through his attorney, Jeanne B.
Costopoulos, Esquire, makes the following Complaint in Custody:
I. The Plaintiff, Matthew D. Concannon, is an adult individual who currently resides at
1040 Lisbum Road, Camp Hill, Cumberland County, Pennsylvania 17011.
2. The Defendant, Erin Concannon, is an adult individual who currently resides at 15
Springers Road, New Cumberland, Cumberland County, Pennsylvania, 17070.
4. The Plaintiff seeks primary custody of the following children:
Name
Pre~ent Re~iden('.e
Age
Colleen Concannon
1040 Lisbum Road
Camp Hill, P A 17011
AND
15 Springers Road
New Cumberland, P A 17070
5 Y2 yrs
DOB 6/14/97
Collin Concannon
1040 Lisbum Road
Camp Hill, PA 17011
AND
15 Springers Road
New Cumberland, P A 17070
3 Y2 yrs
DOB 3/25/99
The parties currently share custody between their two residences, with Plaintiff residing at
1040 Lisbum Road, Camp Hill, Cwnberland County, Pennsylvania 17011 and with Defendant
residing at 15 Springers Road, New Cwnberland, Cwnberland County, Pennsylvania 17070.
The children have recently resided with the following persons and at the following addresses:
Name
Addre~~ Da1es
Plaintiff
1040 Lisburn Road* November 2002 to present*
Camp Hill, PA 17011
Defendant
Chris Dwyer
15 Springers Road* January 18,2003 to present*
New Cwnberland, P A 17070
Defendant
Chris Dwyer
116 W Main Street* November 2002 to January 18,2003*
New Cwnberland, P A
Plaintiff
1040 Lisburn Road* November 2002*
Camp Hill, PA 17011
Plaintiff 1040 Lisburn Road
Defendant Camp Hill, P A 17011
Chris Dwyer (off and on since July 2001)
Sept. 2001 to November 2002
Plaintiff
Defendant
126 N. 2nd Street February 1998 to September 2001
Worrnleysburg, PA 17043
*The parties have been sharing custody between their residences since they separated in November
of2002.
The natural mother of the children is Defendant, Erin Concannon, currently residing at 15
Springers Road, New Cwnberland, Cwnberland County, Pennsylvania 17070.
The natural father of the children is Matthew D. Concannon, Plaintiff, currently residing at
1040 Lisburn Road, Camp Hill, Cwnberland County, Pennsylvania 17011.
The children were born out of wedlock prior to the parties' marriage.
5. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff
currently resides with the following persons: None
The relationship of Defendant to the children is that of natural mother. Mother currently
resides with the following persons: The subject children, her boyfriend, Chris Dwyer, and
sometimes his four minor children.
6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation
concerning the custody of the children in this or another court
7. Plaintiff does not know of a person not a party to the proceedings who has physical
custody of any of the children or claims to have physical custody or visitation rights with respect to
the children.
8. The best interests and permanent welfare of the children will be served by granting
the relief requested because:
( a) Plaintiff is the natural father of the children and has played a major role in the
children's parenting since birth.
(b) Plaintiff has established a very close relationshiplbond with the children.
(c) Plaintiff desires to continue exercising parental roles and enjoys the love and
affection of the children.
(d) The children should be permitted to enjoy the love, affection, and emotional
support which has always been provided by their father.
(e) The Defendant is currently emotionally unstable and is therefore unable to
make the children her main priority.
9. Each parent whose parental rights to the children have not been terminated and the person
who has physical custody of the children have been named as parties to this action. No other persons
are known to have or claim a right to custody or visitation of the children to be given notice of the
pendency of this action and the right to intervene.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an order
granting to him primary or shared physical and shared legal custody of his children.
Respectfully submitted,
Dated: z/ r / ().>
J~POulos, Esq;;;;;'
ATIORNEY FOR PLAINTIFF
5000 Ritter Road, Suite 202
Mechanicsburg, PA 17055
(717) 790-9546
Supreme Ct ill No. 68735
MATTHEW D. CONCANNON,
Plaintiff
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
ERIN CONCANNON,
Defendant
: CIVIL ACTION -ATLAW
: CUSTODY
VF.RTFTCA nON
I, Matthew D. Concannon, hereby verify that the statements made in the foregoing
Complaint in Custody are true and correct to the best of my knowledge, information, and belief.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904,
relating to unsworn falsification to authorities.
Date: / / 3/ /0 ...
,
Signature: ~. 6-.
Matthew D. Concannon
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PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MA TIHEW D. CONCANNON
v.
03-538
CIVIL ACTION LAW
ERIN CONCANNON
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, February 12, 2003 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, March 18,2003 at 1:00 PM
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. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
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 hearinJ!;.
FOR THE COURT.
By: Isl
Dawn S. Sunday- Esq.
Custody Conciliator
t-
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 TI-IIS 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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MATTHEW D. CONCANNON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 03-53.8 CIVIL TERM
ERIN A. CONCANNON,
Defendant
: CIVIL ACTION - LA W
: IN CUSTODY
DEFENDANT'S ANSWER TO
PLAINTIFF'S COMPLAINT FOR CUSTODY
AND NOW, comes Defendant, Erin A. Concannon, by and through her counsel of
record, Marylou Matas, Esquire, and GRIFFIE & ASSOCIATES and Answers Plaintiffs
Complaint for Custody as follows:
1. Admitted.
2. Admitted.
3(4). Admitted.
4(5). Admitted in part and denied in part. It is admitted that the relationship of the Plaintiff
to the child, Colleen, is that of natural father. It is denied that the relationship of the
Plaintiff to the child, Collin, is that of natural father. By way of further response, it is
suspected that another individual may be the natural father of the child, Collin. The
defendant is pursuing DNA testing to prove or disprove that allegation. It is admitted
that Plaintiff currently resides with no other person but the children at issue on a
shared basis.
It is admitted that the relationship of Defendant to the children is that of natural
mother. It is admitted that Defendant currently resides with the subject children, her
boyfriend, Chris Dwyer, and sometimes his four minor children.
5(6). Admitted.
6(7). Admitted.
7(8). Admitted in part and denied in part.
(a) It is admitted that Plaintiff is the natural father of the child, Colleen. It is denied
that Plaintiff is the natural father of the child, Collin. Refer to Defendant's
Answer in paragraph 4 for further response. It is denied that Plaintiff has played
a major role in the children's parenting since birth. By way of further response, it
is alleged that Plaintiff worked long hours and often was not available to care for
the children at all.
(b) Denied. It is denied that Plaintiff has established a very close relationshiplbond
with the children. Specific proof thereof is demanded at trial. By way of further
response, it is alleged that Plaintiff works long hours daily and does not spend
time enough with the children to develop a close relationship.
(c) The averments in this subsection are conclusions that require no response.
(d) The averments in this subsection are conclusions that require no response.
( e) Denied. It is specifically denied that Defendant is emotionally unstable and is
unable to make the children her main priority. Specific proof thereof is
demanded at trial. By way of further response, it is alleged that Defendant has
been and continues to be the primary caretaker for the children.
8(9). Admitted.
WHEREFORE, Defendant requests your Honorable Court to dismiss Plaintiffs
Complaint for Custody, deny Plaintiffs request for primary or shared physical and shared legal
custody of the children, and award primary custody of the children to Defendant.
Respectfully submitted,
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Date
7~~~/~s
Maryloatas, Esquire
Attorney for Defendant
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, P A 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document 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 falsifications to authorities.
DAT~
[-un ~ COl~
ERIN A. CONCANNON, Defendant
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MATTHEW D. CONCANNON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
03-538
CIVIL ACTION LAW
ERIN CONCANNON
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 2.:>--- day of ~ , 2003,
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
upon
1. The Father, Matthew D. Concannon and the Mother, Erin Concannon, shall have shared
legal custody of Colleen Concannon, born on June 14, 1997 and Collin Concannon, born on March 25,
1999. Each parent shall have an equal right, to be exercised jointly with the other parent, 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 this paragraph
each parent shall be entitled to all records and information pertaining to the Children including, but not
limited to, school and medical records and information.
2. Pending further Order of Court or agreement of the parties, the parties shall continue to share
having physical custody of the Children in accordance with the agreed upon schedule in effect
immediately prior to the initial custody conciliation conference.
3. The parties and their counsel shall attend a Custody Conciliation Conference in the office of
the conciliator, Dawn Sunday, on April 10, 2003 at 10:30 am.
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cc: Marylou Matas, Esquire - Counsel for Mother \ f!.A.In..;~~ . /# Do 1
Jeanne B. Costopou10s, Esquire - Counsel for Father / .,_ ~
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MATTHEW D. CONCANNON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
03-538
CIVIL ACTION LA W
ERIN CONCANNON
Defendant
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subjects of this litigation is
as follows:
NAME
DATE OF BIRTH
Colleen Concannon
Collin Concannon
CURRENTLY IN CUSTODY OF
June 14, 1997
March 25, 1999
F ather/Mother
Father/ Mother
2. A Conciliation Conference was held on March 18, 2003, with the following individuals in
attendance: The Father, Matthew D. Concannon, with his counsel, Jeanne B. Costopoulos, Esquire and
the Mother, Erin Concannon, with her counsel, Marylou Matas, Esquire.
3. The Father filed this petition for primary physical custody of the Children. Immediately prior
to the conference, the Father's counsel and the conciliator were provided with copies of the Mother's
Answer in which the Mother alleges that the Father is not the biological Father of the parties' four year
old son. The Mother indicated that she and her boyfriend are in the process of obtaining DNA testing,
which the Mother believes will confirm the boyfriend's paternity.
The Father's counsel informed the Father of the paternity issue outside the conference room
and returned to advise that due to the understandable impact of this disclosure, the Father had departed.
It was agreed that the conference would be delayed until April 10, 2003, at 10:30 am. It was further
agreed that an interim Order be entered in the form as attached maintaining the status quo until the
conference reconvenes.
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Date
rG-AAn. j~e7
Dawn S. Sunday, Esquire
Custody Conciliator
,
IN THE COURT OF COMMON PLEAS Of
CUMBERLAND COUNTY, PENNSYL V AN~A
(1Artl1t.J D. COrJCAr-JtJv,v
Plaintiff,
No. 63.538 Civil Te m
v.
{tIN (}ONCAN,JU,..)
Defendant
Civil Action - Custody
STIPULATION FOR ENTRY OF AN AGREED ORDER OF rUSTOI Y
TillS STIPULATION AND AGREEMENT entered into this ~ day of !If} I L.
2005, by and between f1Rtttlf~ ~t-.J(I'l~N"'" ,(hereinafter referred to s "Father') and_
l'ltlN L'CNCAN.V o"j , (hereinafter referred to as "Mother").
NOW TillS AGREEMENT WITNESSETH THAT:
WHEREAS, the Mother and Father, (hereinafter jointly referred to as the ".part es"), are the
natural parents of two (2) children, namely, Colleen C. Concannon, born lun 14 1997 and Collin
T. Concannon, born March 25. 1999 ,(hereinafter" children"); and
WHEREAS, the parties wish to enter into an agreement relative to the c stody an visitation of
the children.
NOW, THEREFORE, in consideration of the mutual promises, coven nts and a reements as
hereinafter set fortll and intending to be legally bound, the parties hereto agree as f llows:
1. Mother and Father shall share legal custody of the children. I accorda! 'e therewith,
both Mother and Father will keep each other advised and informed of any imp01tant decisi ns or issues
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affecting the children, including but not limited to: (1) access to all medical ~ecords at the children
including records of immunizations and inoculations; (2) notice within twenty fo~r (24) hou s to the non-
,
custodial parent of any injury or illness of the children necessitating medical treatl!,ent or int rvention; (3)
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notice to the non-custodial parent of any major medical procedure, operation or tr atment to the children.
(4) Access to all school records including report cards and progress reports. A ditionally prior to the
start of each school year, Mother shall provide Father with a school schedule to Ilow Fat! er to arrange
other periods of visitation with the children in accordance with this stipulation.
2. Father shall have primary custody and Mother and Father shal share ph sical custody
of the children in accordance with the following schedule of custody and visitation:
3. The parties shall have reasonable telephone contact with the children uring the other parties
periods of physical custody or visitation as the case may be and both Mother an Father s lall make all
efforts to ensure such contact
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4. The parties shall do nothing that may estrange the children from the dev~lopment of the child's
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love or affection for the other party. I
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5. The parties will endeavor to establish a positive and amicable relationshi in recogo tion of the
mutual goal of promoting a happy and healthy relationship that is in the best interes s of the chi d.
6. Any modification or waiver of any of the provisions of this agreement s
7. The parties agree that in making this agreement therc has been no fraud concealm
madc in writing and only if executed with the same formality of this agreement
overreaching, coercion or other unfair dealing on the part of the other.
8. The parties hereby stipulate to the entry of the above as an order of court and waive heir right
to appear before the court for the presentation of this stipulation and its incorporatio as an ord r. The
parties further acknowledge that the Court of Common Pleas of Cumberland County has jurisdi tion over
the issue of custody of the parties' minor children and shall retain such jurisdiction ould cir
change and should either party desire further or require further modification of said rder.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bou d by the te s hereof,
set forth their hands and seals the day and year set forth.
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MATTHEW D. CONCANNON
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ERIN A. CONCANNON
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RECEIVED APR 082005
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IN THE COURT OF COMMON PLEAS OF THE 9th JUDICIAL
DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA
jl;1ItrrH[t-J /) COrJ{AI",VoN
Plaintiff
No. 63 56'13 Civil Tefl1L--
v.
Cf:.IN CONt"",""'" 'v
Civil Action - Child Custody
Defendant
ORDER
AND NOW, thi~ay of
~..
____;2005
III
consideration of the Stipulation for Entry 0 fan Agreed Order of Custody filed by the
parties to the above-captioned matter, it is ORDERED that said stipulation is hereby
made an ORDER OF COURT as iffully set forth herein.
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BY THE COURT ~'
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FiLED-C~~i:;C:E
OF THE P~:~:)"i'H,}:\)OT/J~Y
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MATTHEW D. CONCANNON, '
Plaintiff '
VS. '
ERIN CONCANNON ·
Defendant ·
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
03-538 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this ~ day of ~/?~ , 2003, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this court dated March 25, 2003 is vacated and replaced with this Order.
2. The parties shall submit themselves, their minor children, and any other individuals deemed
necessary by the evaluator, to a custody evaluation to be performed by Arnold Sheinvold, PhD,
Chrissie Hart, PhD, or other professional selected by agreement of the parties and counsel. The
purpose of the evaluation shall be to obtain independent professional recommendations concerning
ongoing custody arrangements which will best serve the needs of the Children. The parties shall sign
all authorizations deemed necessary by the evaluator in order to obtain additional information
pertaining to the parties or the Children. The Father shall pay all costs of the evaluation initially, but
reserves the right to request an apportionment of the costs from the Court at a later date.
3. The parties shall participate in a course of counseling with a professional to be selected by
agreement of the parties. The purpose of the counseling shall be to assist the parties in developing
sufficient communication and cooperation to enable them to effectively coparent their children. All
costs of counseling which are not paid by insurance shall be shared equally between the parties.
The parties shall follow the recommendations of the counselor with respect to the frequency and
duration of counseling sessions.
4. The Father, Matthew D. Concannon and the Mother, Erin Conconnan, shall have
shared legal custody of Colleen Concannon, bom June 14, 1997 and Collin Concannon, bom March
25, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, 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 this
paragraph each parent shall be entitled to all records and information pertaining to the Children
including, but not limited to, school and medical records and information.
5. Pending further Order of Court, or agreement of the parties, the parties shall share having
physical custody of the Children in accordance with the following repeating bi-weekly schedule:
A. During the school year, the Mother shall have custody of the Children fi.om Tuesday
after school through Sunday at 4:00 pm, the Father shall have custody from Sunday at
4:00pm through Tuesday after school, the Mother shall have custody from Tuesday
after school through Friday after school and Father shall have custody fi.om Friday after
school through Tuesday after school.
B. During the summer school break, the Mother shall have custody of the Children fi.om
Wednesday through Sunday at 4:00 pm, the Father shall have custody fi.om Sunday at
4:00 pm through Tuesday, the Mother shall have custody fi.om Tuesday through Friday
and the Father shall have custody fi.om Friday through Wednesday. The specific times
for exchanges of custody on weekdays shall be arranged by agreement between the
parties with the goal of equally sharing custody while accommodating the Children's
summer daycare or activities schedule.
6. Pending completion of the custody evaluation and further agreement of the parties or Order
of Court, the parties shall share having custody of the Children on holidays as follows:
A. Easter: The Mother shall have custody of the Children on Easter Sunday from
1:00 pm until 5:00 pm and the Father shall have custody for the remainder of the
holiday.
B. Memorial Day: The Mother shall have custody of the Children on Memorial Day
from 1:00 pm until 5:00 pm and the Father shall have custody for the remainder of the
holiday.
C. July 4th: The Father shall have custody of the Children for vacation over the July 4th
holiday from June 28, 2003 through July 5, 2003.
D. Labor Day: The Mother shall have custody of the Children over Labor Day weekend
fi.om Sunday at 4:00 pm thorough Monday at 4:00 pm.
E. Thanksgiving: The Mother shall have custody of the Children from after school on
the Wednesday before Thanksgiving through Thanksgiving Day at 3:00 pm and the
Father shall have custody from Thanksgiving Day at 3:00pm through Friday at 3:00 pm.
F. Christmas: The Father shall have custody of the Children from Christmas Eve at
12:00 noon through Christmas Day at 12:00 noon and the Mother shall have custody
fi.om Christmas Day at 12:00 noon through December 26 at 12:00 noon.
G. Vacations: The Father shall have custody of the Children for vacation in 2003 from
June 28 through July 5. The Mother shall be entitled to have an extended period of
vacation custody with the Children upon providing reasonable advance notice to the
Father.
H. The holiday custody schedule shall supercede and take precedence over the regular
custody schedule.
7. In the event the parties are not able to reach an agreement as to all outstanding custody issues
upon completion of the custody evaluation, counsel for either party may contact the conciliator within
sixty days of receipt of the evaluator's recommendations to schedule an additional custody conciliation
conference.
8. 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.
Edgar B. Bayl~
Jo
cc't,,~eeanne B. Costopoulos, Esquire - Counsel for Father
o-l~arylou Matas, Esquire - Counsel for Mother
MATTHEW D. CONCANNON, :
Plaintiff :
:
vs. : 03-538
ERIN CONCANNON : Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
IN CUSTODY
Prior Judge: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subjects of this litigation is
as follows:
NAME
Colleen Concannon
Collin Concannon
DATE OF BIRTH
June 14, 1997
March 25, 1999
CURRENTLY IN CUSTODY OF
Mother/Father
Mother/Father
2. A Conciliation Conference was held on April 10, 2003, with the following individuals in
attendance: The Father, Matthew D. Concannon, with his counsel, Jeanne B. Costopoulos, Esquire, and
the Mother, Erin Concannon, with her counsel, Marylou Matas, Esquire.
3. The parties agreed to entry of an Order in the form as attached with the exception of the
specific days for exchange under the temporary Order pending completion of the evaluation, which is
the recommendation of the conciliator.
Date
Dawn S. Sunday, Esquire
Custody Conciliator