HomeMy WebLinkAbout01-5859
MICHAEL B. DEWIRE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - CUSTODY
AMY S. GERLACH,
Defendant
01 - 6851 CilJi I
COMPLAINT/PETITION FOR CUSTODY ORDER
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
1. Plaintiff is Michael B. Dewire, an adult individual who
currently resides at 138 Amy Drive, Carlisle, Cumberland County
Pennsylvania, 17013.
2. Defendant is Amy S. Gerlach, an adult individual who
currently resides at Leiby Mobile Home Park, 7073 Carlisle Pike,
Lot 127, Carlisle, Cumberland County, Pennsylvania, 17013-9763.
3. Plaintiff seeks the entry of a custody order involving
the minor child, Dylan Blake Gerlach, D.O.B. November 7, 2000.
4. The parties previously resided together and are the
natural parents of the child.
5. During the past year, the child has resided with Defendant
at Leiby Mobile Home Park, 7073 Carlisle Pike, Lot 127, Carlisle,
Cumberland County, Pennsylvania.
6. The natural mother of the child is Defendant.
7. The natural father of the child is Plaintiff who resides
with his mother.
8. No present custody order exists and Plaintiff has no
knowledge of any other litigation concerning custody of the
child in this or another court and Plaintiff has no information of
a custody proceeding concerning the child pending in a court of
this Commonwealth.
9. Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
10. Defendant has recently refused Plaintiff physical and
legal custody of the children without grounds and without basis.
11. Plaintiff and Defendant have been unable to agree upon a
custody schedule, pick-up and drop-off times, transportation
issues, primary physical custody, holidays, medical decisions and
other legal custody issues.
12. An Order of Court is necessary to develop a routine
period of custody along with holiday schedules and terms which
address other important dates for custodial purposes.
13. The best interests and permanent welfare of the child
will be served by ordering that both parties share legal custody
of the child and directing that Plaintiff shall have shared
physical custody of the child because Plaintiff is a fit parent
who can take care of the child and who can provide him with a
supportive, safe and healthy environment.
14. Plaintiff is capable of insuring a supportive and loving
environment for the child, a home with appropriate lodging and
insuring that the child is properly cared for, including making
arrangements for day care when both parents are working.
2
WHEREFORE, Michael B. Dewire, Plaintiff herein, respectfully
requests that your Honorable Court enter a Custody Order which
grants Plaintiff and Defendant joint legal custody, and which
grants Plaintiff shared physical custody with Defendant.
Respectfully submitted,
Date: October /0 , 2001
c
Andrew C. Sheely,
Attorney for Plaint1ff
Pa. I.D. No. 62469
127 S. Market Street,
P.O. Box 95
Mechanicsburg, PA 17055
(717) 697-7050
3
VERIFICATION
I verify that the statements made in this Complaint for
Custody 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: October 10 , 2001
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Michael B. Dewire
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MICHAEL B. DEWIRE
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
01 -5859 CIVIL ACTION LAW
AMY S. GERLACH
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Monday, October 15, 2001
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective cOlITIsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mecbanicsburg, PA 17055 on Tuesday, November 13, 2001 at 8:30 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, 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 hearing.
FOR THE COURT,
By: Isl
Dawn S. Sunday. Esq. or
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 TIllS PAPER TO YOUR ATIORNEY AT ONCE, IF YOU DO NOT
HAVE AN ATIORNEY 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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MICHAEL B. DEWIRE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs,
01-5859
CIVIL ACTION LAW
AMY S, GERLACH,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this -z.o day of l)~ , 2001,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
I. The Father, Michael B, Dewire, and the Mother, Amy S, Gerlach, shall have shared legal
custody of Dylan Blake Gerlach, born November 7,2000. 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 his health, education
and religion, Both parties shall have equal access to all records pertaining to the Child, including
medical and school records.
2. The Mother shall have primary physical custody ofthe Child,
3. The Father shall have partial physical custody of the Child in accordance with the following
schedule:
A. The Father shall have custody of the Child on Sunday, November 18,2001 from 5:00
p,m, until 7:00 p,m, at the Mother's residence,
B. The Father shall have custody on Thanksgiving Day in 2001 from 9:00 a,m, until 3:00
p,m.
C, The Father shall have custody on Sunday, November 25,2001 from 7:30 a,m, until
4:30 p.m,
D, The Father shall have custody of the Child from Saturday, December I, 2001 at 10:00
a,m, through Sunday, December 2,2001 at 4:30 p.m.
E, Beginning on December 9,2001 and continuing thereafter on alternating Sundays when
the Father does not have a full weekend period of custody, the Father shall have custody on
Sunday from 7:30 a,m, until 4:30 p,m,
F, Beginning on Friday, December 14, 2001 and continuing thereafter on
alternating weekends, the Father shall have custody of the Child from Friday at
5:00 p.m. through Sunday at 4:30 p,m, The Father shall pick up the Child on Fridays at the
residence of Eddie Dawson unless otherwise agreed between the parties.
4, The parties shall share or alternate having custody of the Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall
run from Christmas Eve at noon through Christmas Day at noon, and Segment B, which
shall run from Christmas Day at noon through December 26 at noon, The Father shall have
custody of the Child during Segment A in every year and the Mother shall have custody of
the Child during Segment B in every year.
B, EASTER: The Father shall have custody of the Child every year on Easter Sunday
from 7:30 a,m, until 4:30 p,m, and the Mother shall have custody beginning at 4:30 p,m, on
Easter,
C, MEMORIAL DAYILABOR DAY: In years when the Father's regular weekend
period of custody immediately precedes Memorial Day or Labor Day, the Father shall
retain custody of the Child through the holiday at 4:30 p,m. or at such other time as
arranged by agreement of the parties, In years when the Mother has custody of the Child
over the weekend immediately preceding Memorial Day and Labor Day, the Mother shall
have custody of the Child for the holiday.
D, JULY 4TH: The parties shall share or alternate having custody of the Child on July 4th
as arranged by agreement.
E, MOTHER'S DAY/FATHER'S DAY: The parties shall have custody of the Child on
Mother's Day and Father's Day each year in accordance with the regular weekend custody
schedule,
F, CHILD'S BIRTHDAY: Each party shall be entitled to have a period of custody with
the Child on the Child's birthday each year with the specific times to be arranged by
agreement of the parties,
Q, The holiday custody schedule shall supersede and take precedence over the regular
custody schedule,
5, Each party shall have periods of vacation custody with the Child for up to 14 days each year
(with no more than 7 days to be scheduled consecutively) upon providing at least 30 days advance
notice to the other party, In the event the Mother schedules a period of custody under this provision
during the Father's regular partial custody period, the parties shall cooperate in scheduling a makeup
period of custody for the Father, In the event either party intends to remove the Child from his or her
residence for an overnight period or longer, that party shall provide advance notice to the other party of
the address and telephone number where the Child can be contacted,
6, Unless otherwise agreed between the parties, the Father shall be responsible to provide
transportation for all exchanges of custody, Exchanges of custody shall take place at the Mother's
residence, with the exception of exchanges on alternating Fridays, when the Father shall pick up the
Child at the residence of Eddie Dawson,
7, The parties shall communicate directly with each other on a regular basis either by
telephone or in person to discuss issues concerning the Child,
8, Neither parent shall do or say anything which may estrange the Child from the other parent,
injure the opinion ofthe Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
9, This Order is entered pursuant to an agreement of the parties at a Custody Conciliation
Conference, The parties may modify the provisions ofthis Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
J.
cc: Andrew C, Sheely, Esquire - Counsel for Father
Karen Kurts and Robert Rains, Esquire - Counsel for Mother
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MICHAEL B, DEWIRE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
01-5859
CNIL ACTION LAW
AMY S. GERLACH,
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 Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Dylan Blake Gerlach
November 7, 2000
Mother
2, A Conciliation Conference was held on November 13, 2001, with the following individuals
in attendance: The Father, Michael B. Dewire, with his counsel, Andrew C, Sheely, Esquire, and the
Mother, Amy S, Gerlach, with her counsel, Karen Kurts and Robert Rains, Esquire,
Date
AJO(WA/J.J,P<l
3, The parties agreed to entry of an Order in the form as attached,
(O~
Dawn S. Sunday, ES'{:;;;r
Custody Conciliator
(3 ~n^ {
,
Andrew C. Sheely, Esquire
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
MICHAEL B. DEWIRE, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - CUSTODY
vs.
.
.
.
.
AMY S. GERLACH : 01 - 5859
Defendant/Respondent : IN CUSTODY
CIVIL TERM
PETITION FOR MODIFICATION OF CUSTODY ORDER
Plaintiff/Petitioner, Michael B. DeWire, by and through his
counsel, Andrew C. Sheely, Esquire, hereby files this petition for
Modification of an existing custody order and respectfully states
as follows:
1. Plaintiff/Petitioner, MICHAEL B. DEWIRE, (hereinafter
referred to as UFather") is an adult individual who presently
resides at 32 Terri Drive, Carlisle, PA, 17013.
2. Defendant/Respondent is AMY S. GERLACH, (hereinafter
referred to as UMother") is an adult individual who presently
resides at 542 Criswell Drive, Apartment B, Boiling Springs, PA,
17007.
3. The parties are the natural parents of Dylan Blake
Gerlach (D.O.B. 11/07/00).
4. An Order of Court for Custody dated November 20, 2001,
signed by the Honorable Edgar B. Bayley, marked Exhibit
"A", attached hereto and incorporated by reference herein.
5. On or about April 11, 2006, Father received a phone call
from Mother stating that Father needed to remove Dylan from
Mother's home because it had been declared uuninhabitable".
6. Father believes that Cumberland County Children and
Youth Services is performing an investigation as to condition of
mother's residence.
7. Dylan has been living with Father since on or about
April 11, 2006.
8. Since prior order of court, Father married on
September 18, 2004 and presently resides with his wife, Heather
DeWire.
9. Father is capable of providing a separate bedroom,
supervision, care and support which are in the best interests of
Dylan.
WHEREFORE, Father respectfully requests this Honorable Court
enter an Order which:
A. awards shared legal and primary physical custody of child
to Father; and
B. which represents the best interests of the child,
including updating primary physical custody schedules, vacation
days and holiday times; and
C. any other relief in the best interest of the child.
Respectfully submitted,
Date: June Z. '1l
, 2006
&rf:<:e6re
Attorney for Plaintiff
Pa. I.D. No. 62469
127 S. Market Street,
P.O. Box 95
Mechanicsburg, PA 17055
(717) 697-7050
2
VERIFICATION
I verify that the statements made in this Motion are true and
correct. I understand that false statements herein are made
subject to penalties of 18 Pa.C.S.A. Section 4904, relating to
unsworn falsification to authorities.
Date: June L..8'
, 2006
~tI :PJJ~~~J
Michael B. DeWire
Exhibit "A"
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MICHAEL B. DEWIRE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
.01-5859
CNIL ACTION LAW
AMY S. GERLACH,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this .2-IJ 9-' day of ~H.-..JLH ~ , 2.0.01,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The Father, Michael B. Dewire, and the Mother, Amy S. Gerlach, shall have shared legal
custody of Dylan Blake Gerlach, born November 7,2.0.0.0. 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 his health, education
and religion. Both parties shall have equal access to all records pertaining to the Child, including
medical and school records.
2. The Mother shall have primary physical custody ofthe Child.
3. The Father shall have partial physical custody of the Child in accordance with the following
schedule:
A. The Father shall have custody of the Child on Sunday, November 18, 2.0.01 from 5:.0.0
p.m. until 7:.0.0 p.m. at the Mother's residence.-
B. The Father shall have custody on Thanksgiving Day in 2.0.01 from 9:.0.0 a.m, until 3:.0.0
p.m.
C. The Father shall have custody on Sunday, November 25,2.0.01 from 7:3.0 a.m. until
4:3.0 p.m.
D. The Father shall have custody of the Child from Saturday, December 1,2.0.01 at 1.0:.0.0
a.m. through Sunday, December 2,2.0.01 at 4:3.0 p.m.
E. Beginning on December 9,2.0.01 and continuing thereafter on alternating Sundays when
the Father does not have a full weekend period of custody, the Father shall have custody on
Sunday from 7:3.0 a.m. until 4:3.0 p.m.
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F. Beginning on Friday, December 14, 2001 and continuing thereafter on
alternating weekends, the Father shall have custody of the Child from Friday at
5 :00 p.m. through Sunday at 4:30 p.m. The Father shall pick up the Child on Fridays at the
residence of Eddie Dawson unless otherwise agreed between the parties.
4. The parties shall share or alternate having custody of the Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall
run from Christmas Eve at noon through Christmas Day at noon, and Segment B, which
shall run from Christmas Day at noon through December 26 at noon. The Father shall have
custody of the Child during Segment A in every year and the Mother shall have custody of
the Child during Segment B in every year.
B. EASTER: The Father shall have custody of the Child every year on Easter Sunday
from 7:30 a.m. until 4:30 p.m. and the Mother shall have custody beginning at 4:30 p.m. on
Easter.
C. MEMORIAL DAYILABOR DAY: In years when the Father's regular weekend
period of custody immediately precedes Memorial Day or Labor Day, the Father shall
retain custody of the Child through the- holiday at 4:30 p.m. or at such other time as
arranged by agreement of the parties. In years when the Mother has custody of the Child
over the weekend immediately preceding Memorial Day and Labor Day, the Mother shall
have custody of the Child for the holiday.
D. JULY 4TH: The parties shall share or alternate having custody of the Child on July 4th
as arranged by agreement.
E. MOTHER'S DAY/FATHER'S DAY: The parties shall have custody of the Child on
Mother's Day and Father's Day each year in accordance with the regular weekend custody
schedule.
F. CHILD'S BIRTHDAY: Each party shall be entitled to have a period of custody with
the Child on the Child's birthday each year with the specific times to be arranged by
agreement of the parties.
G, The holiday custody schedule shall supersede and take precedence over the regular
custody schedule,
5. Each party shall have periods of vacation custody with the Child for up to 14 days each year
(with no more than 7 days to be scheduled consecutively) upon providing at least 30 days advance
notice to the other party, In the event the Mother schedules a period of custody under this provision
during the Father's regular partial custody period, the parties shall cooperate in scheduling a makeup
period of custody for the Father. In the event either party intends to remove the Child from his or her
residence for an overnight period or longer, that party shall provide advance notice to the other party of
the address and telephone number where the Child can be contacted.
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6. Unless otherwise agreed between the Parties, the Father shall be responsible to provide
transportation for all exchanges of custody. EXChanges of custody shall take place at the Mother's
residence, with the exception of exchanges on alternating Fridays, when the Father shall piCk up the
Child at the residence of Eddie Dawson.
7. The Parties shall communicate directly with each other on a regular basis eitber by
telephone or in person to discuss issues concerning the Child.
8. Neither parent shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natura] development of the
Child's love and respect for the other parent. Both Parties shall enSUre that third Parties having contact
with the Child Comply with this Provision.
9. This Order is entered pursuant to an agreement of the Parties at a Custody Conciliatiou
Conference. The parties may modity the Provisions of this Order by mutual consent. In the absence of
mutual consent, the tenus of this Order shall control.
BY THE COURT,
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1.
cc: Andrew C. Sheely, Esquire - Counsel for Father
Karen Kurts and Robert Rains, 'Esquire - Counsel for Mother
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MICHAEL B. DEWIRE
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
V,
01-5859 CIVIL ACTION LAW
AMY S, GERLACH
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Wednesday, July 05, 2006
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq.
at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, Aue,!,st 02, 2006
, the conciliator,
at 11:30 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. 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 hearin\(.
FOR THE COURT,
By: isi
Dawn S. Sunday. Esq.
Custody Conciliator
pi'
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For infonnation 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
HA VE 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 Bedf(lrd Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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" Andrew C. Sheely, Esquire
121 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-1050 (Phone)
717-697-7065 (FaX)
MICHAEL B. DEWIRE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner: CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : CIVIL ACTION - CUSTODY
AMY S. GERLACH, 01 - 5859 CIVIL TERM
Defendant/Respondent IN CUSTODY
o'<P/:1<-
AFFIDAVIT OF SERVING .CQU'..AilU
COMMONWEALTH OF PENNSYLVANIA :
: SS
COUNTY OF CUMBERLAND
ANDREW C. SHEELY, being duly sworn according to law, deposes
and says that a true and correct copy of the Petition for
Modification of Custody Order in the above-captioned matter to be
served upon AMY S. GERLACH, by Certified Mail, Return Receipt
Requested, as indicated by the attached receipt cards, on July 14,
2006.
1:::c~qg -
SWORN to and subscribed before me
this/[0Lday of ~u1y, 2006.
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N ary Pub1~c
My conunission Expires: "//<( peXH.
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SENDER l.ut"lFJ.LrE (HiS vt:.CrJON
tiI Complete items 1, 2, and 3, Also complete
item 4 jf Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front jf space permits.
1. Article Addressed to:
Amy S. Gerlach
542 Criswell Drive
Apartment B
Boiling Springs, PA 17007
2. Article Number (Copy from service label)
Received by (Please Print Clearly)
/y\ )', G <I }.. < I'{
C Signature
x a",,! y, 3L.i,t:u t..-
o Is dellvery address different from item 1?
If YES. enter delivery address below:
3. Service Type
~ Certified Mail
o Registered
o I:1sured Mail
o Agent
o Addressee
DYes
o No
o Express Mail
o Return Receipt for Merchandise
o C.OD,
4. Restricted Delivery? (Extra Fee)
DYes
7001 2510 0000 3029 4329
102595.00-M-0952
PS Form 3811 , July 1999
Domestic Return Receipt
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RECEIVED ,~'jG r) 41006 Y'
MICHAEL B, DEWIRE
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
01-5859
CIVIL ACTION LAW
AMY S. GERLACH
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this ~ day of .A. .. J-- ' 2006,
consideration of the attached Custody Conciliation Repo~dered and directed as follows:
upon
1. The prior Order of this Court dated November 20,2001 shall continue in effect as
modified by this Order.
2. The Father shall have primary physical custody of the Child.
3. For the remainder of the Summer school vacation, the Mother shall have partial
physical custody of the Child on Wednesdays and Thursdays from 7:30 a.m. until
4:30 p.m. The Mother shall also have custody on Fridays from 7:30 a.m, until a time
to be arranged by agreement between the parties. After school begins, the Mother
shall have custody every Wednesday and Thursday from after school until 8:00 p.m.
In addition throughout the year, the Mother shall have custody of the Child on
alternating weekends on Saturday from 8:00 a,m. until 2:30 p.m. and on Sunday
from 4:30 p,m. until 8:00 p.m,
4. The Mother shall notify the Father when she has obtained a residence appropriate for
overnight periods of custody, at which time the parties shall cooperate in expanding
the Mother's custodial periods to include overnights after the Father has an
opportunity to observe the Mother's proposed housing arrangements,
5. Unless otherwise agreed between the parties, the parent receiving custody shall be
responsible to provide transportation for the exchange of custody. The Father shall
pick up the Child at the residence of Eddie Dawson, unless otherwise notified by the
Mother,
6, The parties shall cooperate in scheduling Christmas holiday time for the Mother
during the segment running from Christmas Eve through Christmas Day if the
Mother is not working,
7. This Order is entered pursuant to the agreement of the parties at 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.
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MICHAEL B, DEWIRE
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLV ANlA
vs,
01-5859
CNIL ACTION LAW
AMY S, GERLACH
Defendant
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 Child who is t he subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Dylan Blake Gerlach
November 7, 2000
Father
2, A Custody Conciliation Conference was held on August 2, 2006, with the following
individuals in attendance: The Father, Michael B. DeWire, with his counsel, Andrew C.
Sheely, and the Mother, Amy S. Gerlach, with her counsel, Gail Guida Souders, Esquire.
3. The parties agreed to entry of an Order in the form as attached,
#VrWlf- -2, ~u
Date
D*.~Wre~
Custody Conciliator