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HomeMy WebLinkAbout03-1866 RICHARD P. BROWN, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. . P,j-- Ii' to . SHIRLEY A. LEFEVRE, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, RICHARD P. BROWN, by and through his attorney, ROBERT B. LIEBERMAN, ESQUIRE and respectfully represent as follows: 1. The Plaintiff is RICHARD P. BROWN, residing at 101 Orchard Crest Court, Gardeners, Cumberland County, Pennsylvania. 2. The Defendant is SHIRLEY A. LEFEVRE residing at 820 Torway Road, Gardeners, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Residence Age Samuel R. Brown 820 Torway Road Gardeners, Pennsylvania 6 years The child was born out of wedlock. The child is presently in the custody of Defendant, SHIRLEY A. LEFEVRE, who resides at 820 Torway Road, Gardeners, Cumberland County, Pennsylvania. ___"_~h~.__ "'--~~__"'~N'.__.~<<~".___..~"" The child has resided with the following persons and at the following addresses: Persons Addresses Dates Plaintiff and Defendant 101 Orchard Crest Court January 1997 to August 2001 Gardeners, Pennsylvania Plaintiff 101 Orchard Crest Court August 2001 to August 2002 Gardeners, Pennsylvania (Shared Custody) Defendant and 26 East Street August 2001 to August 2002 Amanda M. Lefevre and Mount Holly Springs, (Shared Custody) William R. Lefevre Pennsylvania Plaintiff 101 Orchard Crest Court August 2002 to Present Gardeners, Pennsylvania (Shared Custody) Defendant and 820 Torway Road August 2002 to Present Amanda M. Lefevre and Gardeners, Pennsylvania (Shared Custody) William R. Lefevre The mother of the child is SHIRLEY A. LEFEVRE, currently residing at 820 Torway Road, Gardeners, Cumberland County, Pennsylvania. She is single. The father of the child is RICHARD P. BROWN, currently residing at 101 Orchard Crest Court, Gardeners, Cumberland County, Pennsylvania. He is single. 4. The relationship of Plaintiff to the child is that of Father. The Plaintiff currently resides alone. -2- 5. The relationship of Defendant to the child is that of Mother. She resides with the following persons: Name Samual R. Brown Amanda M. Lefevre William R. Lefevre Relationship Son Daughter Son 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 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. 7. The best interests and permanent welfare of the child will be served by granting the relief requested because Plaintiff is ready, willing and able to provide a stable home environment for the child. 8. Each party whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. -3- WHEREFORE, Plaintiff requests this Honorable Court to grant him legal and primary physical custody of the subject minor child. Respectfully submitted, DATED: 'I-I,. ~"'> ~ . ~. BERT B. LIEBERMAN, ESQUIRE 500 North 3rd Street, 12th Floor P.O. Box 1004 Harrisburg, P A 17108-1004 (717) 236-1485 Attorney for Plaintiff -4- VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904, relating to unsworn falsification to authorities. DATED: April 17, 2003 ~~..~~ Ri~P. Brown, Plaintiff ~ ~ "- w ...Q ~ C> .L] Q ~ ~ '-"\ ~ '-. C> ~ -- CD> v..., C ~ r- "'" l:S'""' ~ ~ >.' > @ '^ ." '. ; l f'" RICHARD P. BROWN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 03-1866 CNIL ACTION LAW SHIRLEY A. LEFEVRE DEFENDANT 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 Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, P A 17055 on Thursday, May 22, 2003 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 hearin2. FOR THE COURT, By: /s/ Dawn S. Sunday, 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 A l' ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE 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 ~~?? ~ ~ (Og-e-11 ..h ~ ~ ~~ ["~ 2>-e~ ~ jv%~~f'l C~)J(".A ~ 1 !' t(.,~1~1,~SNN3d l\.....1 'I , " I i r J, ''-fllJ:1, --I ,'AI n '.n,. '..' I,.:-::-jh a ... 'U .f' "J - v .c" r]r 8 Z (j.jH i,"f), ....... 1.,1,; :10 RICHARD P. BROWN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-1866 CNIL ACTION LAW SHIRLEY A. LEFEVRE Defendant IN CUSTODY ORDER OF COURT AND NOW, this IS' day of <1.-.- , 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Richard P. Brown, and the Mother, Shirley A. Lefevre, shall have shared legal custody of Samuel R. Brown, born January 9, 1997. 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. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The parties shall share having physical custody of the Child on an alternating weekly schedule, with the exchange to take place every week on Saturday at 5:00 pm. The parties shall cooperate in making arrangements for a mid-week period of custody for the noncustodial parent as necessary to serve the Child's needs. The alternating weekly schedule shall begin with the Father having custody ofthe Child on Saturday, June 14,2003 at 5:00 pm. 3. During the school year, the parties agree that the Child shall take the bus to school from day care in the morning and return on the bus after school to the Mother's residence, from which the Father shall pick up the Child during his weeks of custody. 4. The parties shall share or alternate having custody ofthe Child on holidays as arranged by agreement. 5. The parties shall schedule vacation periods during his or her regular weeks of custody to the extent possible. The parties shall cooperate in making adjustments to the regular schedule to accommodate both parties' vacation schedules when necessary. \lINVII1ASNN3d I I 'Ir",'~ ."" .." ,-r;'^'n'" I\.Li",i., :",:".F,,~ V 0": '"' : I ~ :, '1i C I !","o, r";.':j \J ",;,.J '+' _ .~ }':'I 6. Unless otherwise agreed, the party relinquishing custody of the Child shall be responsible to provide transportation for the exchange of custody. 7. In the event either party is unavailable to provide care for the Child during his or her period of custody for three or more hours or for any period of time after 10:00 pm, that party shall first contact the other party to offer the opportunity to provide care for the Child before making other arrangements for the Child's care. 8. Neither party 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 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. After following the alternating weekly custody schedule set forth in this Order for a period of at least two full months, counsel for either party may contact the conciliator to schedule an additional conciliation conference to review the arrangements if necessary. 10. 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. BY THE COURT, .AtL J. cc: Robert B. Lieberman, Esquire - Counsel for Father Michael J. Whare, Esquire - Counsel for Mother .~ ~ (,,-/ ~ .():) Cf-. RICHARD P. BROWN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-1866 CIVIL ACTION LAW SHIRLEY A. LEFEVRE 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 Samuel R. Brown January 9, 1997 MotherlFather 2. A Conciliation Conference was held on June 12, 2003, with the following individuals in attendance: The Father, Richard P. Brown, with his counsel, Robert B. Lieberman, Esquire and the Mother, Shirley A. Lefevre, with her counsel, Michael J. Whare, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~e... I d-, ;)003 D,!6;ft:u Custody Conciliator Date . ~ RICHARD P. BROWN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 03-1866 SHIRLEY A. LEFEVRE, Defendant : IN CUSTODY COMPLAINT TO MODIFY CUSTODY AND NOW, comes the Plaintiff, RICHARD P. BROWN, by and through his attorney, ROBERT B. LIEBERMAN, ESQUIRE and respectfully represents as follows: I. The Plaintiff is RICHARD P. BROWN residing at 101 Orchard Crest Court, ] Gardeners, Cumberland County, Pennsylvania. 2. The Defendant is SHIRLEY A. LEFEVRE residing at 26 East Street, Mount Holly Springs, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Age Name Residence Samuel R, Brown 101 Orchard Crest Court Gardeners, Pennsylvania 8 years 26 East Street Mount Holly Springs, Pennsylvania The child was born out of wedlock to Plaintiff and Defendant. The child is presently in the custody of Defendant, SHIRLEY A. LEFEVRE, who resides ~t 26 East Street, Mount Holly Springs, Cumberland County, Pennsylvania and Plaintiff, . RICHARD P. BROWN, who resides at lOl Orchard Crest Court, Gardeners, Cumberland County, Pennsylvania. The parties are sharing custody on a week on/week off basis. The child has resided with the following persons and at the following addresses: Persons Addresses Dates Plaintiff and Defendant 101 Orchard Crest Court January 1997 to August 200 I Gardeners, Pennsylvania Plaintiff 101 Orchard Crest Court August 2001 to August 2002 Gardeners, Pennsylvania (Shared Custody) Defendant 26 East Street August 2001 to August 2002 Amanda M. Lefevre and Mount Holly Springs, (Shared Custody) William R. Lefevre Pennsylvania Plaintiff 101 Orchard Crest Court August 2002 to April 2003 Gardeners, Pennsylvania (Shared Custody) Defendant and 820 Torway Road August 2002 to April 2003 Amanda M. Lefevre, Gardeners, Pennsylvania (Shared Custody) William R. Lefevre and Daniel Albright Plaintiff lO I Orchard Crest Court April 2003 to April 2004 Gardeners, Pennsylvania (Shared Custody) Defendant and 833 West Louther Street April 2003 to April 2004 William R. Lefevre Carlisle, Pennsylvania (Shared Custody) Defendant and 541 North Bedford Street April 2004 to April 2005 William R. Lefevre Carlisle, Pennsylvania (Shared Custody) Plaintiff 101 Orchard Crest Court April 2004 to April 2005 Gardeners, Pennsylvania (Shared Custody) -2- .' Defendant and William R. Lefevre 26 East Street April 2005 to Present Mount Holly Springs, Pennsylvania (shared custody) Plaintiff 101 Orchard Crest Court Gardeners, Pennsylvania April 2005 to Present The mother of the child is SHIRLEY A. LEFEVRE, currently residing at 26 East Street Mount Holly Springs, Cumberland County, Pennsylvania. She is single. The father ofthe child is RICHARD P. BROWN, currently residing at 101 Orchard Crest Court, Gardeners, Cumberland County, Pennsylvania. He is single. 4. The relationship of Plaintiff to the child is that of Father. The Plaintiff currently resides with his son. 5. The relationship of Defendant to the child is that of Mother. The Defendant currently resides with the following persons: Name Relationship Samual R. Brown Son William R. Lefevre Son 6. Plaintiff and Defendant have previously participated as parties in litigation concerning custody ofthe child in this court. See Order dated June 18, 2003 which is attached hereto. -3- Plaintiff has no information of a custody proceeding concerning the child pending in a court ofthis Commonwealth or any other state. 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. 7. The best interests and permanent welfare of the child will be served by granting the relief requested because Plaintiff is ready, willing and able to provide a stable home environment for the child. 8. Each party whose parental rights to the child have not been terminated and the person !who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests this Honorable Court to grant him joint legal and (primary physical custody of the subject minor child. Respectfully submitted, pATED: ~. / b . () f ~+~.~ /~B. LIEBERMAN, ESQUIRE 500 North 3rd Street, 12th Floor P.O. Box 1004 Harrisburg, P A 17108-1004 (717) 236-1485 Attorney for Plaintiff -4- VERIFICATION I verify that the statements made in the foregoing Motion for Conference are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. DATED: J I Ie lor , I (dt/~ Richard P. Brown, Plaintiff JUN I ( LUuv ~ RlCHARD P. BROWN, Plaintiff I . CElVED \BY~UH : 9 l003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-1866 CIVIL ACTION LAW SHIRLEY A. LEFEVRE Defendant IN CUSTODY ORDER OF COURT AND NOW, this / f e day of C , 2003, upon consideration of the attached Custody Conciliation R ort, it is ordered and directed as follows: I. The Father, Richard P. Brown, and the Mother, Shirley A. Lefevre, shall have shared legal custody of Samuel R. Brown, born January 9, 1997. 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. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The parties shall share having physical custody of the Child on an alternating weekly schedule, with the exchange to take place every week on Saturday at 5:00 pm. The parties shall cooperate in making arrangements for a mid-week period of custody for the noncustodial parent as necessary to serve the Child's needs. The alternating weekly schedule shall begin with the Father having custody of the Child on Saturday, June 14, 2003 at 5:00 pm. 3. During the school year, the parties agree that the Child shall take the bus to school from day care in the morning and return on the bus after school to the Mother's residence, from which the Father shall pick up the Child during his weeks of custody. 4. The parties shall share or alternate having custody of the Child on holidays as arranged by agreement. 5. The parties shall schedule vacation periods during his or her regular weeks of custody to the extent possible. The parties shall cooperate in making adjustments to the regular schedule to accommodate both parties' vacation schedules when necessary. 6. Unless otherwise agreed, the party relinquishing custody of the Child shall be responsible to provide transportation for the exchange of custody. 7. In the event either party is unavailable to provide care for the Child during his or her period of custody for three or more hours or for any period of time after 10:00 pm, that party shall first contact the other party to offer the opportunity to provide care for the Child before making other arrangements for the Child's care. 8. Neither party shall do or say anything which may estrange the Child from the other parent, ipjure the opinion of the Child as to the other parent, or hamper the free and natural development of the qhild'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. After following the alternating weekly custody schedule set forth in this Order for a period of at least two full months, counsel for either party may contact the conciliator to schedule an additional cbnciliation conference to review the arrangements if necessary. 10. This Order is entered pursuant to an agreement of the parties at a custody conciliation c~nference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms ofthis Order shall control. BY THE COURT, /~ / 1!u~ Dc I~ I I J. cc Robert B. Lieberman, Esquire - Counsel for Father Michael J. Whare, Esquire.. Counsel for Mother r~1tJ~ (~(:';,:e :,~' g:~r~c,:'.;~ t~~Et;or~D In r~tt#f..'O]H" ~:;;', ~:<, j n:'j:!~~ Uit~~ ',~~ Ifry :t:;nd "'!/ &.iI ~e.,,';:. ."" at C...;~, !'fd.. ",< II/~, "';' ~fC ~ ..~jm ~ "__L___" l i.l.... '>U-:in. ,~ ProthonC1lr<l RICHARD P. BROWN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-1866 CNIL ACTION LAW SHlRLEY A. LEFEVRE Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT : IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL P,OCEDURE 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 fol'ows: N~ Sa$uel R. Brown DATE OF BIRTH CURRENTLY IN CUSTODY OF January 9, 1997 MotherlFather I I 2. A Conciliation Conference was held on June 12, 2003, with the following individuals in I attepdance: The Father, Richard P. Brown, with his counsel, Robert B. Lieberman, Esquire and the Mother, Shirley A. Lefevre, with her counsel, Michael J. Whare, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~e... I ;;t, doo3 D~~~ Custody Conciliator Date =N ~, c~. (r-'; ~ '"::) '--'\ o 1"\' "t: s-- c>" c:-::-> '-'I J..A ~ o ~') ,,- r- ~ , r (", (," ,,' c:. _+__7 ~, c-:..., C::::' (:,,"1 Cl -'q :l-) n'i::J I lD \~} RICHARD P. BROWN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 03-1866 CIVIL ACTION LA W SHIRLEY A. LEFEVRE IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, May 13, 2005 __,' upon consideration of the attached Complaint. it is hcrcby directed that parties and their respective counsel appear before Dawn S. Snnday, Esq. at 39 West Mai~..S.!':,~et, Mechanic.bnrg, PA 17055 on Wednesday, June 08, 2005 . the conciliator, at tl:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will he made to resolve the issues in dispute; or if this cannot be accomplished. to detinc and narrow the issucs to bc 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. Custody Conciliator I lV ~ 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 disablcd 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 bet(lre 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 Bedford Street Carlisle, Pennsylvania 17013 Telephone (7 I 7) 249-3166 /f' a. '7?7pM:;::) JjV r (?(f','P"I{ ~ , ~ 7 ~ T~lL, ~rx ~ ~/iP~ M; ;:?,7) (J'" " I') t11 ,;,?, . ~') [ ,- j'i /;7 0.7 [/ s;' 50 L'/5- \ ('1, \ "J ;:,1 ~)'~; RICHARD P. BROWN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 03-1866 SHIRLEY A. LEFEVRE, Defendant : IN CUSTODY ACCEPTANCE OE.SERVICE I, Michael J. Whare, Esquire, Attorney for Defendant, Shirley A. Lefevre, this I h day of June, 2005 hereby accept service of the Complaint to Modify Custody and Order of Court, dated May 13, 2005 docketed to the above number and term. l/l /", 0 (!.,^ r v L ---c ~ '-..,/" .) I L..- J "- Michael J. Whare, E~quire 155 South Hanover Street Carlisle, P A 17013 Attorney for Defendant t-..) = = c..n C- c:: ::e: o .1 :i! n1:n -0 hi :06 ,::) ~--f ( ;:c :r~ .;:.2""- ~._ C) om '>! ~lj -< , \.0 > ::fC C:) N ..iRECEIVED JUL 252005 RICHARD P. BROWN Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-1866 CIVIL ACTION LAW SHIRLEY A. LEFEVRE Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~r day of 1i:t ' 2005, upon consideration of the attached Custody Conciliation Report, It is rdered and directed as follows: 1. The prior Order ofthis Court dated June 18, 2003 shall continue in effect as modified by this Order. 2. The regular weekly exchange of custody shall take place on Mondays at 5:00 p.m. unless otherwise agreed between the parties. 3. In the event either party is unable to provide care for the Child during his or her period of custody, that party shall notify the other at least 24 hours in advance to enable him or her to provide care for the Child during the custodial parent's unavailability. In the event the non-custodial parent is not able to provide care, the parties shall make arrangements by agreement for care by a third party. 4. The parties agree that the Child shall not be left in the sole care of the Mother's son, William. 5. The parties and their counsel shall attend an additional (:ustody conciliation conference in the office of the conciliator, Dawn S. Sunday, on Wednesday, September 21,2005, at 8:30 a.m. for the purpose of reviewing the custodial arrangements. 6. 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. BY THE COURT, . ~J J. M>f-.u4 ~ -7_:;l-f.,_b( cc: Robert B. Lieberman, Esquire - Counsel for Fathe Michael J. Whare, Esquire - Counsel for Mother C)- '- '. r;<I\;'/1/,! '~:\I\/,.:i,_/ 11\1(~,.,;,o,,:o::- ':;,:~."'),,, l\lIJli_i' -"'/"/;,\..1 as :8 ritl 92 tnr goaz O.r17'l('\\li~<;ii~'I'--;,J -JL.J. ..j,", /'.I.J 'C"', "-~'. ....;...,~""'J :':j"1-L.;;v j,'Jf:1,"fO'-O:J7/j RICHARD P. BROWN Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-1866 CIVIL ACTION LAW SHIRLEY A. LEFEVRE Defendant IN CUSTODY Prior Judge: Kevin A. Hess CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915,3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Samuel R. Brown January 9, 1997 Mother/Father 2. A conciliation conference was held on July 18, 2005, with the following individuals in attendance: The Father, Richard P. Brown, with his counsel, Robert B. Lieberman, Esquire, and the Mother, Shirley A. LeFevre, with her counsel, Michael J. Whare, Esquire. 3. The parties agreed to entry of an Order in the form as ailtached. ~ d;:),\ dCO) Date D,e~ Custody Conciliator RCCE"I!::n C"P ~ ~ 000< ,~ , . ,-.J v~, - _ ,.U ~ RICHARD P. BROWN Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-1866 CIVIL ACTION LAW SHIRLEY A. LEFEVRE Defendant IN CUSTODY ORDER AND NOW, this 21st day of September. 2005 , the conciliator, being advised by the parties that all custody issues have been resolved by agreement between the parties, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for today, September 21, 2005 is cancelled. FOR THE COURT, Dg~ Custody Conciliator 1:/j!\'V /\IA (~i\~p'~::td IJJ"I')',..,;, -, ,~c ,::c'^'n" f' "I ,I.,i,; , " ..I :'J:~,'/'~t~: v S lJ :2 Hd U d3S SUOZ AtNLONOi-ilOi::kJ 3Hl ;10 38WO-G311;l