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Home My WebLink About00-06567 '.-,,' ..~' '~-",,' ,-.-:~ " ..<,~-':'_ ,0"'- ",__;',~-, ,_'__.~_,,~,.'. '- ;'.-"-;;><'';-.Q;'-';F'~'_;''-'';-''_:__"' 'i'"!~i 0~&~ ATTORNEYS AT LAW ARTHUR K. DILS DIANE M. RUPICH 1017 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102 PHONE: (717) 233-8743 FAX: (717) 233-2567 October 11, 2000 The Honorable Edward E. Guido Cumberland County Court House One Court House Square Carlisle, P A. 17013 (Via Fax) OCT 1 2 2000 RE: Michelle Lynn Herrick v, Joseph E. Herrick No. 2000-6567 Civil/Custody Dear Judge Guido: This is to confirm that on behalf of Michelle Lynn Herrick, we are withdrawing the Petition for Special Relief, and that there is no need for the hearing scheduled for October 12, 2000 at 8:30 a,m. A conciliation conference has been scheduled for Tuesday, October 17, 2000, and it is felt that this matter should proceed via the conciliator and not through a Petition for Special Relief. Thank you for your assistance in this matter. Arthur K. Dils AKD cc: Andrew W, Norfleet, Esquire Attorney for Joseph E. Herrick (Via Fax) .i;,....il_.. ~ OCT-11-12I121 WED 17:31 FLEX AIl'frlUR 1(. OilS DIANE M, RUPICH '; , . I I .. . i", " . i . , :@)}:L ,~,~.~f~~tl:h' U~ ",~ ",~f~, I'. '. r .1. .' . ..' I,... . 1\"r:'9"N~'tllI1;T ! "'?-I , ,. . " :i- T 0'1;7. ~.Il~ !'H'~;f~.Q1'1'" .1'1(<';1' i HAI'~~~!;I:r~tl,!~!i.~\lAII)AI11 o:! .. . I' ' : i: !:' II. :WO(l The Honorable Edwardl.~. Gu~l;'Io , Cumberland County COtlJ::t ,House' ." One COlll't House Square ' Carlisle, PA. 17013 (Via Fax) ':,::" j,' '1: , f.' ..'- RE: I' .' . . 'I': ' MiCl)~H~~I~p1!iI~~1~q,~:', )()s,'ph I':, Herrick . N Q;:! 2{J.o.()i(~~:5(. r ' .,:,,',{ ,','" Cl1dp 'i~ftl-tQ'll . I" ! Dear Judge Guido: I I .- ~-", ~"m~l~ p _ 121 1 PHONE: (717) 233-8743 FAX: (711) 233.~S81 . Y This is to cOllfl1'll1 that onht;l~ilit~flrwj,Il\~~~~F,~wqn Henil:k, we an: withdrawing the Petition for Special Re,liet:a)M~tlll~r~ijl\:, !,ij,~~p~j..:ed fnr thl.: hearillg scheduled for October 12, 2000 at 8:30 a.nl,.. A~*,Jt~~~~!'~{jOllf(;:I'CllCC has been scheduled for Tuesday, October 17, 2(}OO,;~nlj~r,J~.;~::':j:~hait -qbis mmter S110uld proceed via the conciliator and not through a~()tHi~j*rf~r.~~;l(tl R~:lj(::{ Thank you for your assist~V1Cl}iu tb~~~lt~,!" - }".' l; V~~jytl'ujy VOUI:,~, r :1'; ',/: " /" "'~(> ',i til' .. ,,/. !. ,'-f ., I ..,...."') " ( . ,.'~"",'r r . ,1/..... . ".., .1~''i ii' '~"" 'I'--' ',.- :r\'".~.~~''' .' " > ,.~,' i ,,;,. Al1iHIl' K lJ i b .'.j'. "1, . j. i' AKD cc: Andrew W, Norfleet, f.1,sqMir~ Attorney for Joseph E.Jl:~rl'i;\k~' (Via. Fax) ::,:. '..'1:' I:. :!.' ,. i;. . ::: .- ii' '1;. , i . . ::. . I. . ,I: i' i -- ,#.;,~i~,;:~i ,-,::~ ! -- ~ ._,,' ""'- ( MICHELLE LYNN HERRICK : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. JOSEPH E. HERRICK : NO. 2000-6567 CIVIL TERM ORDER OF COURT AND NOW, this 5TH day of OCTOBER, 2000, a hearing on plaintiffs Petition for Special Relief is scheduled for October 12,2000, at 8:30 a.m, in Courtroom # 5 of the Cumberland County Courthouse, Carlisle, Pa. 17013. Edward E. Guido, J. Arthur K. Dils, Esquire L~~~ 10-&-00 R){g Joseph E, Herrick, Esquire 6 Campbell Place Camp Hill, Pa. 17011 :sld mlk'IT;t;::-7,t6i\~~it~ - t "",C_' . ~ , ,~., ~,- ",,'" . , .., .,-- ~ .' -''"',.,~~ ,~,~, ,'.\i'P" ,-,)\f"ll f;r" qn- ,,'1 \;-U l'~" .. 'el ~, \-' h'li (\\ \ 1 "," "," (,n\.1"'\'( 0\ i"i;",U"'I'-:-";'~\) I....'.~~ \. ...,v ?t~N'2;'i'2~i\'M\i\ ",I" "..,',.~ I .,"'''''''',.:~ .,J. I~__ e'.-""~-'~' """'"'" J:.~, ~__. ,-- :",',-,'-----, -' ;,'--;,,-. - , .~ -;,;.;"-"",, ,- ^' - -, .- MICHELLE LYNN HERRICK, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA No. 2000 -Co 'J C 7 Civil JOSEPH EDWARD HERRICK, Defendant CUSTODY OlIDER OF COURT AND NOW, this Day of ,2000, upon presentation and consideration of the within Petition for Special Relief, it is hereby Ordered that the above captioned parties shall share physical custody of their minor children as follows: (A) Plaintiff shall have physical custody from Wednesdays at 3:30 p,m. Until Sunday at 5:00 p,m.; and (B) Defendant shall have physical custody from Sundays at 5:00 p.m. Until Wednesdays at 3:30 p,m, ~ '-~. " i This Order of Court shall remain in effect until a custody conciliation conference is held and/or further Order of Court, BY THE COURT: 1. Distribution: Arthur K, Dils, Esquire, 1017 N, Front Street, Harrisburg, Pa, 17102 Joseph Edward Herrick, 6 Campbell Place, Camp Hill, PA, 17011 '0: , ~ , " "~- '"-bi.; MICHELLE LYNN HERRICK, Plaintiff vs, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2000 Civil JOSEPH EDWARD HERRICK, Defendant CUSTODY PETITION FOR SPECIAL RELIEF AND NOW, this Z Co Day of September, 2000, comes the Plaintiff, Michelle Lynn Herrick, by her attorney, Arthur K, Dils, Esquire, and respectfully avers the following: 1, The Plaintiff, Michelle Lynn Herrick, is an adult individual, who currently resides at 120 North 18th Street, Harrisburg, Dauphin County, Pennsylvania 17103, 2, The Defendant, Joseph Edward Herrick, is an adult individual, who currently resides at 6 Campbell Place, Camp Hill, Cumberland County, Pennsylvania, <_,_ L.. '.'- < ,,.. - l' 3. Plaintiff and Defendant were married on July 30,1993 in Reading, Pennsylvania, and as a result of said marriage, two children were born; namely: Nicholas Alexander Herrick, born November 20, 1993 in Reading, Pa,; and Christina Elizabeth Herrick, born July 10, 1995 in State College, Pa, 4. Plaintiff and Defendant separated on or about July 20, 2000, 5, Since the date of separation, Plaintiff and Defendant had been sharing physical custody of the minor children as follows: (A) Plaintiff had custody from Wednesday at 3:30 p,m. until Sunday at 5:00 p,m,; (B) Defendant had custody from Sunday at 5:00 p,m until Wednesday at 3:30 p,m, 6, On September 20, 2000, the Defendant arbitrarily denied Plaintiff custody in that after working 24 hours straight, she over slept and was late arriving at 3:30 p,m. to -2- ,- ,'" ~ . ,"-<: ~" ~" " - pick up the children, 7, Since that time, the Defendant has refused all contact with the Plaintiff and her children. 8, Simultaneously herewith, Plaintiff has filed a Complaint for Custody, requesting a conciliation conference be scheduled, 9, There has been no prior action for custody or visitation of the minor children in this or any other jurisdiction, 10, Plaintiff believes that it is in the best interest of her children that she and the Defendant share physical and legal custody, and respectfully requests your Honorable Court to enter an Interim Order reinstating the previous shared physical custody arrangement that the parties had followed until the Defendant arbitrarily denied the Plaintiff all contact whatsoever on September 20, 2000, -3- , .- ,'" J~~.,_-. - ~ __L- "'"' r,," 11, The Defendant has denied all telephone contact between the Plaintiff and her children since September 20,2000, 12, The Defendant has refused to exchange custody with the Plaintiff, which the parties have been following amicably since July of 2000, their date of separation, 13, The Plaintiff appeared at the work ofthe Defendant on September 20,2000, and when the Defendant refused to cooperate with the Plaintiff and refused her their children, the Plaintiff returned to her vehicle, took out a baseball bat, and allegedly hit the Defendant's vehicle with the baseball bat, and then allegedly swung at the Defendant, and the Plaintiff has been charged with aggravated assault and criminal mischief, as a result of these actions, 14, The minor children are being harmed in that since September 20,2000, they have been denied all contact with their mother. -4- - ---- --~--'~,;, ".', -~ , -,- "'. ':" -'r~ --;;,{. -.- c- _ , ~'t:' 15, Continual refusal of Defendant to cooperate is detrimental to the minor children, WHEREFORE, Plaintiff, Michelle Lynn Herrick, respectfully requests your Honorable Court to enter an Interim Order of Court granting shared physical custody of the parties' minor children. B -5- ~;u. '~ ~,- " "" " . . ildk~J' VERIFICATION 1 verify that the statements made in this PETITION are true and correct. 1 understand that fals<: stat<:ments h<:r<:in ar<: made subject to the penalties of 18 Pa. C,S. Section 4904 rdating to unswom falsification to authorities, )j~ ;;( /&nAd.- ~ MICHELLE LYNN HERRICK Date: SEPTEMBER 26, 2000 "~ '~""'~~};", MICHELLE LYNN HERRICK PLAINTIFF V. JOSEPH EDWARD HERRICK DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-6567 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 29 day orEPTEMBEe, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S, Sunday, Esq, , the conciliator, at 39 West Main Street, Mechanicshurg, PA 17055 on the 17TH day of OCTOBER ,2000, at 9:30 A,M for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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. FOR THE COURT, By: Isl Dawn S, Sunday, Rsq,f;t 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 t- ~, ,_.,- ~~ ' '>-- .. - -"_ ___h""'_' -~,~-," -. ,w",,__,_, _,~, ,~' '",0"0' . '~'.~,""'-~'~. ,,-', ....,..'-i('.t F\Lt:U-'~u!~~"~:~ :(yr~.r"y cr ~:":-:'-i )ll'~~ ::'-;',) \}"'l\ 00 OCT --3 PH 3: 2.6 CUM~gm1~;itv~~KNW /O-3.c:{;? M-~ ~ ~ ~.p~ /O:1,oe:;J ~ ~ zj) ~ /tJ:J-oc; ~ ~ ;# ~ ~ I I I , , I ., I, " j I fi I !. !I H " ;\ :1 " , :1 !~~ . t :' i: I:: 1'1 ~j I,:: iJ ~ " ,.e "__,_^,",^,,,,~!II[l, :'lIlIf_~""'" {l ~"","""~JP.ll_';til~~',~iiNl~~11lf>1If%:,,,,~~~~~'ffi~~~'''''' .. - -" , . : ~ -"-" '~'t'!ilIJkh MICHELLE LYNN HERRICK, Plaintiffs Vs, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 2000-b>5iP7 Civil Term JOSEPH EDWARD HERRICK, Defendant CIVIL ACTION-LAW QRDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Conciliator, on , the day of 2000 at ,m. in the office of said conciliator located at for a pre-hearing custody conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis cannot be accomplished, to defme 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 the entry of a temporary or permanent order. FOR THE COURT: Date: BY: Custody Conciliator --- ~ ~ 0-- , -, '" .,- ~--~-"!<<& YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator Cumberland County Court House One Court House Square Carlisle, Pa, 17013 (717) 240-6200 ;;;;=""-- , ~ ,- . ~~ - MICHELLE LYNN HERRICK, Plaintiff vs, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No, 2000 - (,,!:'(, '7 Civil JOSEPH EDWARD HERRICK, Defendant CUSTODY COMPLAINT FOR CUSTODY AND NOW, this Day of September, 2000, comes the Plaintiff, Michelle Lynn Herrick, by her attorney, Arthur K. Dils, Esquire, and respectfully avers the following: 1, The Plaintiff, Michelle Lynn Herrick, is an adult individual, who currently resides at 120 North 18th Street, Harrisburg, Dauphin County, Pennsylvania 17103, 2, The Defendant, Joseph Edward Herrick, is an adult individual, who currently resides at 6 Campbell Place, Camp Hill, Cumberland County, Pennsylvania, ,.--'-, ~ . - ',o.-'- ._, ", ' .. - r_~ .', _, _',. .~ "~ ~ --; 3, Plaintiff and Defendant were married on July 30, 1993 in Reading, Pennsylvania, and as a result of said marriage, two children were born; namely: Nicholas Alexander Herrick, born November 20, 1993 in Reading, Pa,; and Christina Elizabeth Herrick, born July 10, 1995 in State College, Pa, 4, Plaintiff and Defendant separated on or about July 20, 2000. 5. Since the date of separation, Plaintiff and Defendant had been sharing physical custody of the minor children as follows: (A) Plaintiff had custody from Wednesday at 3:30 p.m. until Sunday at 5:00 p.m.; (B) Defendant had custody from Sunday at 5:00 p,m until Wednesday at 3:30 p,m. 6, On September 20, 2000, the Defendant arbitrarily denied Plaintiff custody in that after working 24 hours straight, she over slept and was late arriving at 3:30 p,m. to -2- ,.--< ,. . pick up the children. 7. Since that time, the Defendant has refused all contact with the Plaintiff and her children, 8. Simultaneously herewith, Plaintiff has filed a Petition for Special Reliefrequesting the Court to enter an interim Order setting forth the shared physical custody arrangement as the parties had previously followed. 9, There has been no prior action for custody or visitation of the minor children in this or any other jurisdiction, 10. The minor children have resided at the following addresses: 52 B. Greentree House, Douglassville, PA. 19518 Until April of 1994; 283 Governor's Park road, Bellefonte, Pa, 16823 Until April of 1996; -3- . - . --'-'~ 279 Greenland Drive, Lancaster, PA, 16802 Until April of 1999; 1822 North Street, Harrisburg, Pa, 17103 and 6 Campbell Place, Camp Hill, Pa, 17011 Shared until September 20,2000, 11. Plaintiff believes that it is in the best interest of her children that she and the Defendant share physical and legal custody, WHEREFORE, Plaintiff, Michelle Lynn Herrick, respectfully requests your Honorable Court to grant shared physical and legal custody of the parties' minor children, Respectfully submitted, BY: Arthur K. Dils, Esquire 1017 N, Front Street Harrisburg, Pa, 17102 (717) 232-9724 I.D, No, 07056 -4- ,,~<- - ~- > ~ 1-'~11i",""" VERIFICATION I verify that the statements made in this COMPLAINT are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section -+904 relating to unsworn falsitication to authorities. ~d.ikMd - Date: SEPTEMBER 26, 2000 MICHELLE LYNN HERRICK I i" <~ .. -~_d , _ ,_~. '-ISlf'o<1<1f , MICHELLE LYNN HERRICK, : IN THE CXJORT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. : NO. 00-6567 CIVIL TERM : . CIVIL ACTION - LAW . JOSEPH EDWARD HERRICK, . . Defendant . IN CUSTODY . ORDER OF COURT AND lOl, 'this XJI'. day of ~ consideration of the attached Custody Conciliation and directed as follows: , 2000, upon Report, it is ordered 1. The Mother, Michelle Lynn Herrick, and the Father, Joseph Edward Herrick, shall have shared legal custody of Nicholas Alexander Herrick, bOrn November 20, 1993, and Christina Elizabeth Herrick, born July 10, 1995. 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. 2. The parties shall share having physical custody of the Children in accordance with the following schedule: A. During alternating weeks, the Mother shall have custody of the Children from Wednesday at 3:30 p.m. through Sunday at 5:00 p.m. and, during the interim weeks, the Mother shall have custody from Thursday at 3:30 p.m. through Sunday at 5:00 p.m. B. During alternating weeks, the Father shall have custody of the Children from Sunday at 5:00 p.m. through Thursday at 3:30 p.m. and, during the interim weeks, the Father shall have custody from Sunday at 5:00 p.m. through WedneSday at 3:30 p.m. C. The alternating weekly schedule shall begin with the Mother having custody of the Children on Wednesday, October 18, 2000 at 3:30 p.m. Thereafter, the parties shall transfer custody frcm the Mother to the Father every Sunday at 5:00 p.m. and shall transfer custody from the Father to the Mother on Wednesdays or Thursdays at 3:30 p.m. on an alternating basis. 3. The parties shall share or alternate having custody of the Children over holidays as follows: A. CHRISTMAS: In even numbered years, the Mother shall have custody of the Children from Christmas Eve at 7:00 p.m. through Christmas Day at 7:00 p.m. In odd numbered years, the Father shall have custody of the Children from Christmas Eve . ~" ~~~~'i' at 7:00 p.m. through Christmas Day at 7:00 p.m. B. THANKSGIVING: In even numbered years, the Father shall have custody of the Children on Thanksgiving Day from 9:00 a.m. until 7:00 p.m. In odd numbered years, the Mother shall have custody of the Children on Thanksgiving Day from 9:00 a.m. until 7:00 p.m. C. EASTER/CRrHOOOX EASTER: In every year, the Mother shall have custody of the Children on Easter Sunday from 9:00 a.m. until 7:00 p.m. and the Father shall have custody of the Children on Orthodox Easter Sunday from 9:00 a.m. until 7:00 p.m. D. MEMC:I.UAL DAY/LABOR DAY: In every year, the Mother shall retain custody of the Children after her weekend period of custody through Memorial Day and Labor Day at 7:00 p.m. E. MO.rHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Children every year on Mother's Day from 9:00 a.m. until 7:00 p.m. and the Father shall have custody of the Children every year on Father's Day from 9:00 a.m. until 7:00 p.m. F. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 4. Each party shall be entitled to have custody of the Children for two additional weeks (consecutive or non-consecutive) each year. In the event a party intends to schedule his or her periods of vacation custody under this provision during the school year, that party shall provide at least 30 days advance notice to the other party and obtain school approval. In the event either party intends to schedule his or her periods of vacation custody under this provision during the surrnner school break, that party shall provide notice to the other party by May 1. Neither party shall schedule periods of custody under this provision during the other party's holiday period of custody unless otherwise agreed between the parties. 5. The non-custodial parent shall be entitled to have reasonable telephone contact with the Children. 6. In the event either party intends to remove the Children from his or her residence for an overnight pericd or longer, that party shall provide advance notice the other party and shall designate a contact person in the event the non-custodial parent needs to contact the Children. Unless otherwise agreed between the parties, Evelyn Herrick shall be designated as the contact person on the Father's behalf and Elizabeth LaRue shall be designated as the contact person on the Mother's behalf. 7. After the parties have followed the shared custody schedule set forth in this Order for a reasonable period, counsel for either party may contact the Conciliator within 90 days of the date of this Order to request an additional COnference, if necessary, to consider adjustments to the schedule. ,,_. "" t&;"'"'..~: 8. This Order is entered pursuant to an agreement of the parties at a Custody conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. All changes made by agreement to the provisions of this Order shall be confirmed in writing by both parties. J. . C\ I Cop.l~J) {YlcUM 10 -.2.5-00 RX~ cc: Arthur K. DUs, Esquire - Counsel for Mother Andrew W. Norfleet, Esquire - Counsel for Father I I I I, I; Ii d Ii Ii Ii I , I , il 'I 'I I, 1 i I Ii I: Ii Ii II " [,[ ii! i-;,,^ .. , , _" ,,,,,,,=1!Iil!l'IlIlI~~~,,,,",,,_, ,~ . ~_ 0" .'H~ _M' ~'! <y:tJiV 0":" ;; Pi', ::;~ n5 'iU cuu~\rr( F ci\li 'J~)' {L\//.;"~>\ ,1~;"'~'i!('M~~"'~II!iml~_"I!\lMl~llif--!;.,;~,,,.,,,,,?,'""l1"(''''''~''' ''''''....T ,~~~._=~~' , ""'"-,~, . MICHELLE LYNN HERRICK, : IN THE OJORT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 00-6567 CIVIL TERM . : . CIVIL ACTION - LAW . JOSEPH EDWARD HERRICK, . . Defendant : IN CUSTODY CUS'lWY c:c:.NCILIATICN SUMMARY REPOOT IN ACCORDANCE WITH CUMBERLAND COllN'l'Y 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: ~ DATE OF BIRTH CURRENTLY IN CUS'lWY OF Nicholas Alexander Herrick Christina Elizabeth Herrick November 20, 1993 Mother/Father July 19, 1995 Mother/Father 2. A Conciliation Conference was held on October 17, 2000, with the following individuals in attendance: The Mother, Michelle Lynn Herrick with her counsel, Arthur K. Oils, Esquire, and the Father, Joseph Edward Herrick, with his counsel, Andrew W. Norfleet, Esquire. 3. The parties agreed to entry of an order in the form as attached. Dr:kbv1 Date /9, .Jaz) , 4~~ Dawn S. Sunday, Esquire Custody Conciliator