HomeMy WebLinkAbout03-1746SHERRI D. WHITSEL,
Plaintiff
KENNETH R. WHITSEL,
Defendant
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Custody
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT, if you wish to defend against the claims set forth in
the following pages, you must take prompt action. You are warned that if you fail to do so the case
may proceed without you and a decree of divorce or annulment may be entered against you by the
Court. A judgment may also be entered against you for any other claim or relief requested in these
papers by the Plaintiff. You may lose money or property or other rights important to you, including
custody and visitation of your children.
When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage counselors is available in the Domestic Relations
Office at the County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
Carlisle, Pennsylvania 17013
(717) 249-3166
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
SHERRI D. WHITSEL,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v. C a- 17q/
KENNETH R. WHITSEL,
Defendant
CIVIL ACTION - LAW
Custody
COMPLAINT IN CUSTODY
1. Plaintiff is Sherri D. Whitsel (hereinafter referred to as "Mother"), who currently
resides at 220 Constitutional Court, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
2. Defendant is Kenneth R. Whitsel (hereinafter referred to as "Father"), who
currently resides at 313 S. Logan Boulevard, Burnham, Mifflin County, Pennsylvania, 17009.
NAME
Daulton L. Whitsel
Plaintiff seeks legal custody and primary physical custody of the following child:
ADDRESS DOB
220 Constitutional Court 3/7/1999
Mechanicsburg, PA 17055
The child was not born out of wedlock.
4. During the past five (5) years, the child has resided with the following persons and
at the following addresses:
PERSONS
Mother and Father
Mother
ADDRESSES
808 Grantham Road
Grantham, PA 17027
220 Constitutional Court
Mechanicsburg, PA 17055
DATES
3/7/1999
to 6/21/2002
6/21/2002 to
Present
5. The mother of the child is Sherri D. Whitsel, currently residing at 220
Constitutional Court, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
6. The Father of the child is Kenneth R. Whitsel, currently residing at 313 S. Logan
Boulevard, Burnham, Mifflin County, Pennsylvania, 17009.
The parties are presently married but separated.
currently resides with the following persons:
,NAME
Daulton L. Whitsel
The relationship of the Plaintiffto that of the child is that of Mother. The Plaintiff
RELATIONSHIP
Son
2
currently resides with the following persons:
NAME
Self
The relationship of the Defendant to the child is that of Father. The Defendant
RELATIONSHIP
9. Plaintiff has not participated as a party or a witness, or in another capacity, in other
litigation concerning the custody of the child in this or another court.
10. Plaintiff has no information of a custody proceeding concerning the child pending
in a court of this Commonwealth.
11. 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.
12. Defendant has recently located to Mifflin County. Despite efforts, no schedule has
been confirmed between the parties and Court intervention is thus required. The parties have
created a parenting plan whereby Plaintiff shall have primary custody of the child with periods of
defined partial custody for the Defendant.
3
13. Each parent whose parental rights to the child has not been terminated and the person
who has physical custody of the child has been named as parties to this action.
WHEREFORE, the Plaintiff requests the Court to enter an order of custody consistent
with the terms of the parties' stipulation.
Dated: ////~'~- ,2003
Respectfully s~ted,
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. No. 32317
4
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
SHERRI D. WHITSEL,
Plaintiff
KENNETH R. WHITSEL,
Defendant
· IN THE COURT OF COMMON PLEAS
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO.
· CIVIL ACTION - LAW
· Custody
VERIFICATION
I, Sherfi D. Whitsel, hereby certify that the facts set forth in the foregoing CUSTODY
COMPLAINT are tree and correct to the best of my knowledge, information and belief. I understand
that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating
to unswom falsification to authorities.
SHERRI D. WHITSEL :
PLAINTIFF :
V. :
KENNETH R. WHITSEL
:
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
03-1746 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, April 25, 2003 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 301 Market Street, Lemoyne, PA 17043 on Tuesday, May 20, 2003 at 12:30 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 lwi.or to scheduled hearinl~.
FOR THE COURT~
By: /s/
Melissa P. Greevy, Esq.
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
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
MAY 2 9 2003
SHERRI D. WHITSEL,
Plaintiff
V.
KENNETH R. WHITSEL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-1746 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER TO RELINQUISH JURISDICTION
AND NOW, this 20th day of May, 2003, the parties having reached an agreement which has
been memorialized in a Stipulation to be filed with this Court, the Conciliator hereby relinquishes
jurisdiction of the above captioned matter.
Custody Conciliator
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SHERRI D. WHITSEL,
Plaintiff
KENNETH R. WHITSEL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 03-1746
:
: CIVIL ACTION - CUSTODY
ORDER ADOPTING STIPULATION OF PARTIF.~
AND NOW, to wit, this ~.~day of x.~"',O.~ ~ , 2003, upon consideration of the
foregoing Stipulation for Custody and on Motion of Barbara Sumple-Sullivan, Esquire, counsel
for Plaintiff and Motion of Gregory Reed, counsel for Defendant, is hereby ordered, adjudged
and decreed that the terms, conditions and provisions of the Stipulation for Custody dated May
27, 2003 is adopted as an Order of Court as if set forth herein at length.
Ob-ta-o'3
BY THE COURT,
~- Ju~d~ge
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
SHERRI D. WHITSEL,
Plaintiff
KENNETH R. WHITSEL,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
NO.. 03-1746
C1VIL ACTION - CUSTODY
Petition for Contempt
1. Plaintiffis Sherri D. Whitsel, an individual residing at 22.0 Constitutional Court,
Mechanicsburg, and Cumberland County, PA 07050.
2. Respondent is Kenneth R. Whitsel, an individual residing at 313 S. Logan Boulevard
Burnham, Mifflin County PA 17009
3. On June 9th, 2003, an Order of Custody was entered by stipulation of the parties. A copy
of the Order is attached hereto.
4. During the negotiations of the stipulation underlying the Order, Plaintiff agreed to allow
Defendant additional time during his actual workweek adjacent to his weekend so that the
child could spend time with Defendant's extended family even if he was not off on those
days.
5. In order to insure that the child spent such time with Defbndant's family, the parties
agreed on prior notice and restrictions on transportation of the child.
6. Paragraph I of the stipulation provides:
TRANSPORTATION: Father shall provide Mother with at least twelve (12) hour
notice of who will be providing transportation in the event Father is unable to do so. All
third party transportations shall be approved by both Father and Mother
7. Immediately prior to the execution of the stipulation, Defendant balked at the inclusion of
paragraph I.
8. Since removal of this safeguard and restriction was critical to Plaintiff's concurrence in
granting to the Defendant the additional time, she would not agree to the stipulation
without it.
9. Defendant agreed to execute the stipulation containing the additional time and
transportation restriction and confirming his intention to abide by same.
10. Almost immediately since the Order's implementation, Defendant has now flagrantly
admitted to the Plaintiff that he would not abide by the requirement, deeming it
ridiculous, and he has consistently allowed his present paramour (who has been a prior
wife) to transport the child. This is occurring despite the express prohibition by the
Plaintiff.
11. Plaintiff's objection to Defendant's use of his current p~rramour for transportation is
grounded in actual statements made by the Defendant to Plaintiff about this woman that
leads the Plaintiff to fear for the safety of the child.
12. The sole purpose of allowing the extended days between the child and Defendant's
extended family is thwarted due to the child being left with the paramour, contrary to the
express desire of the Plaintiff.
2
13. Defendant's actions are direct and willful violation of the'order of court dated June 9,
2003.
14. Additionally, the parties share legal custody.
15. Paragraph 1 provides, inter alia
"...Each party shall notify the other of any activity or circumstance concerning their child
that could reasonably be expected to of concern to the other..."
16. After a recent visit, the child advised Petitioner that he had to go to a new Sunday School
class and he was supposed to be brave and not cry.
17. Petitioner had previously been advised by Respondent, that he would be attending church
with his extended family and the child would be attending Sunday School where his Aunt
was the child's teacher.
18. No notification of change of church and/or religion was ever given to Petitioner by
Respondent.
19. Respondent has failed to discuss this matter or consult c,r communicate with Petitioner on
this important matter in violation of the Court Order.
20. Plaintiff requests that the Defendant be held in contempt and that Defendant be required
to pay all costs, including attorney's fees, incurred by her in the prosecution of this
matter.
WHEREFORE, the Plaintiff requests the Court to enter an urder of custody consistent with
the terms of the parties' stipulation.
Dated: July 3, 2003
Respe~ct~.~lI:~,
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070~ 1931
EXHIBIT "A"
SHERRI D. WHITSEL,
Plaintiff
KENNETH R. WHITSEL,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 03-1746
:
: CIVIL ACTION - CUSTODY
ORDER ADOPTING STIPULATION OF PARTIES
AND NOW, to wit, this ~ day of _~_~_, 2003, upon consideration of the
foregoing Stipulation for Custody and on Motion of Barbara Sumple-Sullivan, Esquire, counsel
for Plaintiff and Motion of Gregory Reed, counsel for Defendant, is hereby ordered, adjudged
and decreed that the terms, conditions and provisions of the Stipulation for Custody dated May
27, 2003 is adopted as an Order of Court as if set forth herein at length.
BYTHE COURT,
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
SHERRI D. WHITSEL,
Plaintiff
: IN THE COURT OF COMMON PLEAS
· CUMBERLAND COUNTY, PENNSYLVANIA
v. · NO. 03-1746
KENNETH R. WHITSEL,
Defendant
: CIVIL ACTION - CUSTODY
STII~ULATION FOR ENTRY
OF CUSTODY ORDER
This Agreement is made thiso,~ day of May, 2003 by and between Sherri D. Whitsel
(hereinafter "Mother") and Kenneth R. Whitsel (hereinafter "Father"). The purpose of this
Agreement is to confirm the understandings of the parties as they relate to custody. It is the
express purpose of this document that it shall be submitted by the parties to the court for entry of
a stipulated order of custody.
WHEREAS, Mother and Father were married on December 18, 1993 and separated on
June 21, 2002;
WttEREA$, the parties are the natural parents of one child being, Daulton L. Whitsel
(born March 7, 1999);
WtIEREAS, a divorce is pending between the parties to Docket No. 02-3506 in
Cumberland County;
I, VItEREA$, the parties desire to enter into a plan which sets forth their agreement for
custody and create a Custody Order;
NOW THEREFORE, the parties, intending to be legally bound, do agree as follows:
CUSTODY:
1. Mother and Father shall have legal custody of the parties' son. Mother agrees that
as is possible, she shall discuss with the Father the decisions concerning the
child's upbringing, including issues concerning the child's health, welfare,
education, religious training and upbringing. Each party shall notify the other of
any activity or circumstance concerning their child that could reasonably be
expected to be of concern to the other. Day to day decisions shall be the
responsibility of the Mother. With regard to ~my emergency decisions which must
be made, the parent having physical custody of the child at the time of the
emergency shall be permitted to make any immediate decisions necessitated
thereby. However, that parent shall infom~ the other of the emergency and
consult with him or her as soon as possible. Each party shall be entitled to
complete and full information from any doclor, dentist, teacher, professional or
authority and to have copies of any reports given to either party as a parent.
The parties agree that they shall discuss all extra curricular activities in which
Daulton shall be enrolled. If an activity is agreed upon, the parties shall share
equally the cost of the activity. If one parent does not agree but the activity can
be conducted solely during the parent's custodial period, then that party shall be
entitled to enroll the child and shall pay 100% of the cost of said activity.
The parties agree that Daulton shall continue to be enrolled in the Early Learning
Center until he is eligible to commence kindergarten. He shall be enrolled in the
School District servicing Mother's home address for commencement of his public
school education, unless the parties agree otherwise in the best interest of their
son or unless a court enters and order to the corttrary.
In the event of an emergency or sickness of Daulton while he is at his
daycare/nursery school or in public school, i[t is agreed that Mother shall be that
entity's primary contact member and Father shall be the secondary contact
member.
PHYSICAL CUSTODY: Mother shall have primary Physical custody of the
minor child Father shall have partial physical custody of the child as follows:
A. ALTERNATING WEEKENDS:
Father's first alternating weekend shall cormmence on Thursday at 8:00 a.m. to
Sunday night at 6:00 p.m. Father's next alternating weekend shall commence on
Thursday at 8:00 a.m. to Sunday at 6:00 p.m.
B. WEEK NIGHTS:
Each Tuesday from 4:30 p.m. to 7:30 p.m. This time shall be at the option of
Father. However, Father shall have the fight to have the child from 8:00 a.m. to
7:30 p.m., should he not work on Tuesday. However, to exercise same, Father
must give notice to Mother by 12:00 noon on Monday preceding his Tuesday
visitation.
C. OTHER TIMES:
Such other times as the parties shall mutually agree. However, Father shall not
remove the child from his daycare/nursery school without Mother's express prior
consent·
HOLIDAYS: The parties shall celebrate holidays as follows:
a. In each year, Mother shall have custody of Daulton for the following
holiday periods:
3
1. Daulton's birthday which shall be defined as March 6th from
8:00 p.m. until March 8th a'L 9:00 a.m.
2. Mother's Day which shall be defined as the Saturday prior to
Mother's Day at 8:00 p.m. until the Monday morning after
Mother's Day at 9:00 a.m.
3. Each Christmas from Ckristmas Eve at 9:00 a.m. through
Christmas Day at 8:30 p.m.
bo
In each year, Father shall have custody of Daulton for the following
holiday periods:
1. Father's Day which shall be defined as the Saturday prior to
Father's Day at 8:00 p.m. until the Monday morning after
Father's Day at 9:00 a.m.
2. Each Christmas from Christmas Day at 8:30 p.m. until
December 27th at 8:30 p.m.
1. The parties shall altemate Thanksgiving Day. Thanksgiving
Day shall be defined as 9:0.0 a.m. on Thanksgiving to the day
after at 9:00 a.m. Mother shall have this period in even years
and Father having this period in odd years. If the weekend
following this holiday is Father's, he shall maintain custody of
Daulton until the conclusion of the weekend period.
2. The parties shall alternate Easter. Easter shall be defined as
6:00 p.m. the Saturday preceding Easter until Monday morning
after Easter at 9:00 a.m. Mother shall have this period in odd
years and Father shall have this'period in even years.
The holiday schedule as set forth above shall supersede all other provisions of this Order.
4
VACATION: Each party shall be entitled to two (2) weeks of vacation
each year. This shall be defined as seven (7) days including the parties'
alternating weekend period. Father shall give notice of his intended weeks
to Mother at least 90 days in advance.
RIGHT OF FIRST REFUSAL: Except for the time periods of when the
child is customarily enrolled in daycare/riursery school, if either party is
required to be away from the child for a period of excess of four (4) hours
that parent shall be required to make the offer to the other parent to have
custody of Daulton for the time peric,d which he or she is away. If the
parent asked chooses not to exercise this right for additional custodial
time, the parent having custody shall then have the obligation of securing
an appropriate caregiver or sitter.
NOTICE OF LOCATION OF CHILD: If either parent intends to travel
out of the immediate geographic area wkile the child is in his or her
custody, said party shall give notice to the other, including an itinerary and
telephone contact number.
POSITIVE RELATIONSHIPS: Each 6f the parties and any third party
in the presence of the child and the party shall take all measures deemed
advisable to foster a feeling of affection between the child and the other
party and neither will do anything which may estrange the child from the
other party or impair the child's high regard for the other party. Neither
party shall do anything which may estrange the child from the other party
or injure the child's opinion of the parent or which may hamper the free
and natural development of the child"s love and respect for the other
parent.
5
TELEPHONE CONTACT: The parents are entitled to speak with the
child on their non-custodial days at least once per day. The custodial
parent shall make the child available for the other parent's call and shall
provide a phone number for contact of the ckild during each period of
custody.
COMMUNICATION: All coramm~ications concerning Daulton shall
occur directly between Father and Mother only in writing or verbally.
TRANSPORTATION: Father shall provide Mother with at least twelve
(12) hour notice of who will be providing transportation in the event
Father is unable to do so. All third party transportations shall be approved
by both Father and Mother.
No.~w,.~FI-IEREFORE, the parties, intending to be legally bound, do agree to set forth
their !and~/o~/~Mh~~st written above.
Barbara Sumple-Sullivan, Esquire
C~ory R. Reed, E~ Kenneth R. Whitsel
6
Barbara Sumple-Sullivan, Esqmre
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
SHERRI D. WHITSEL,
Plaintiff
: IN TI-I~ COUR,T OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v. ' NO. . 03-1746
KENNETH R. WHITSEL,
Defendant
· CIVIL ACTION - CUSTODY
VERIFICATION
I, Sherri D. Whitsel, hereby certify that the facts set :forth in the foregoing PETITION
FOR CONTEMPT are true and correct to the best of my knowledge, information and belie£ I
understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A.
Section 4904 relating to unsworn falsification to auth-orities.
Whitsel
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
SHERRI D. WHITSEL,
Plaintiff
KENNETH R. WHITSEL,
Defendant
: 1N THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.. 03-1746
:
: CIVIL ACTION - CUSTODY
CERTIFICATE OF SERVICE
I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on
this date, I served the Petition for Contempt, in the above-captioned matter upon
the following individual by first class mail, postage prepaid, addressed as follows:
DATE: July 3, 2003
Gregory R. Reed, Esquire
2423 N. Third Street
Harrisburg, PA 17110
~' Barbara S~
~le-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. 32317
cz
z
SHERRI D. WHITSEL :
PLAINTIFF :
V, :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
03-1746 CIVIL ACTION LAW
KENNETH R. WHITSEL
: IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Friday, July 11, 2003 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 301 Market Street, Lemoyne, PA17043 on Tuesday, Aul~ust 19,2003 at 10:30 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 I~rior to scheduled hearinr,.
FOR THE COURT,
By: /s/ Melissa P. Greevy. Esq.
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 befbre 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 ItELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 24%3166
SHERI D. WHITSEL,
Plaintiff
VS.
KENNETH R. WHITSEL
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
03-1746 CIVIL ACTION LAW
IN CUSTODY
Prior Judge: J. Wesley Oler, Jr.
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
Daulton L. Whitsel
March 7, 1999 Mother
2. A Conciliation Conference was held on September 3, 2003, with the following individuals
in attendance: The Mother, Sheri D. Whitsel, with her counsel, Barbara Sumple-Sullivan, Esquire, and
the Father, Kenneth R. Whitsel, and his counsel, Gregory R. Reed, Esquire.
3. The parties established custody arrangements for their four year old son by a Stipulation
which was entered as an Order by the Court on June 9, 2003. Subsequently, the Mother filed a Petition
for Contempt, seeking to address problems which had developed in the custody situation.
4. To their credit, the parties were able to discuss and resolve the concerns raised by the Mother
and to commit themselves to improving their ongoing parenting relationship. It was determined at the
conference that entry of an additional Order is not necessary at this time as the parties will proceed
under the existing June 9, 2003 Order with clarifications discussed at the conference.
Date Dawn S. Sunday, EsquireC/
Custody Conciliator
cc:,~(~arbara Sumple-Sullivan, Esquire - Counsel for Mother
~gory R. Reed, Esquire - Counsel for Father