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HomeMy WebLinkAbout99-03765'?' ?a? o? h 1 Nov $ 310 bl,2 ROBERT L. FISHER, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW DANIELLE E. FISHER, NO. 99-3765 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this -04 day of November, 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: A hearing is scheduled in Courtroo t . 2 of the Cumberland County Courthouse on the ? day of , A4 ?_10 at /. ?.M. at which time testimony will be taken in the above case. AU is hearing, the Mother, Danielle E. Fisher, shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the court and opposing counsel a memorandum setting forth the history of custody in this case, a detailed listing of the issues currently before this court, a procedural history of this custody case, a list of witnesses who will testify on behalf of that party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least 5 days prior to the mentioned hearing date. 2. Pending further order of this court, this Court's prior order of August 1999 shall remain in effect subject to the following modifications: A. When the child is in the custody of the Father, Father shall ensure that Mother enjoys reasonable telephone contact with the minor child. The Father is encouraged to initiate phone calls himself so that the minor child can talk to the Mother during times when Father is available and during times when the Father anticipates the Mother will be available. The parties should exchange suggested times for telephone calls. B. Pending a hearing in this case and in the event Mother's work schedule requires her to request a modification of the nine day limitation on when she exercises custody with the child each month, counsel for the Mother can contact the Conciliator in the event the parties are unable to reach an agreement and the Conciliator can conduct another Custody Conciliation Conference via telephone with the attorneys for the parties to address any issues to modify the existing order pending the hearing. BYUCOUAA cc: James M. Bach, Esquire Edgar B. Bayley Gregory Hazlett, Esquire " LLI ::7 F . d 2 O ? U ROBERT L. FISHER, JR., Plaintiff DANIELLE E. FISHER, Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3765 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Shelby L. Fisher, born October 19, 1995. 2. A Conciliation Conference was held on November 16, 1999, with the following individuals in attendance: The Father, Robert L. Fisher, Jr., with his counsel, Gregory Hazlett, Esquire; and the Mother, Danielle E. Fisher, with her counsel, James M. Bach, Esquire. 3. The parties have previously appeared before the Conciliator in August at which time they agreed upon a temporary order with a provision that the parties would meet again in February for a second Conciliation Conference. The temporary order provided Mother with nine days of custody per month and the Father with the remaining time. Mother is in Virginia having relocated from Pennsylvania earlier this year. 4. At the request of the Attorney for the Mother, the Conciliator conducted a special Conciliation Conference. Mother asserts that Father is not being flexible with respect to modification of the custody schedule nor has Father been cooperative with respect to telephone communications between Mother and the child. Mother requests that the February Conciliation date be cancelled and that the Court set a hearing so that Mother may proceed with requesting primary physical custody. 5. The Conciliator had worked out an arrangement in August whereby the parties agreed to a temporary order subject to a second Conciliation. It was the parties hope and the Conciliator's intent that the parties would try to work things out and that a permanent order could be reached in February. It is clear that the parties are at odds and that a hearing is required before a permanent order of custody can be entered. Accordingly, the Conciliator will refer this case to the Court for a hearing. 6. Mother's counsel suggests that the existing order should be modified. The Conciliator is not prepared to recommend a modification of the existing order since it was agreed to in August. However, Mother's counsel may file a petition for special relief with the court if Mother desires to pursue that issue. 7. The Conciliator recommends the entry of an order in the form as attached. 23 9 DATE CG/L` -eA - Hubert X. Gilroy, Es irc Custody Conciliar AUG 12 199q ? ROBERT L. FISHER, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DANIEL E. FISHER, NO. 99-3765 CIVIL Defendant IN CUSTODY COURTORDER AND NOW, this day of August, 1999, upon consideration of the attached Custody Conciliation Report, i is ordered and directed as follows: This Court's prior order of June 22, 1999 is vacated. 2. The Father, Robert L. Fisher, Jr., and the Mother, Daniel E. Fisher, shall enjoy shared legal custody of Shelby L. Fisher, bom October 19, 1995. 3. The parties shall enjoy physical custody with the minor child as follows: A. Effective as of August 10, 1999, the Mother shall have ten (10) consecutive days with the minor child after which she shall have an additional 14 consecutive vacation days with the minor child. B. Commencing in September, Mother shall enjoy a period of nine (9) consecutive days with the minor child from Friday after her work on one weekend until the following Sunday evening. Mother shall pick up the child from Father's residence on Friday and shall return the child to Father's residence on Sunday. The parties shall communicate between themselves with respect to designating the specific days on exchange of custody. C. The Father shall enjoy physical custody at times the minor child is not with the Mother as set forth above. D. The parties may by agreement modify this schedule in any manner that they deem appropriate. In the event the parties cannot agree on any modification, the schedule set forth above shall control. 4. The parties shall meet with the Custody Conciliator again for a Conciliation Conference on Thursday, February 3, 1999 at 8:30 a.m.. In the event the parties have reached an agreement on a permanent order prior to the Conciliation Conference, the parties may notify the Conciliator to have the Conciliation Conference cancelled. AUG 12 199*> ROBERT L. FISHER, JR., IN THE COURT' OI-'COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL, ACTION - LAW DANIEL E. FISHER, NO. 99-3765 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this day of August, 1999, upon consideration of the attached Custody Conciliation Report, i is ordered and directed as follows; 1. This Court's prior order of June 22, 1999 is vacated, 2. The Father, Robert L. Fisher, Jr., and the Mather, Daniel E. Fisher, shall enjoy shared legal custody of Shclhy L. Fisher, Iwm October 19, 1995. 3. The parties shall enjoy physical custody with the minor child as follows: A. Effective as of August 10, 1999. the Mother shall have ten (10) consecutive days with the minor child after which she shall have an additional 14 consecutive vacation days with the minor child. B. Commencing in September, Mother shall enjoy a period of rune (9) consecutive days with the minor child from Friday after her work on one weekend until the lidlowing Sunday evening. Mother shall pick up the child from Father's residence on Friday and shall return the child to Father's residence on Sunday, The parties shall communicate between themselves with respect to designating the specific days on exchange of custody. C. The Father shall enjoy physical custody at times the minor child is not with [lie Mother its set forth above. D. 'Ile parties may by agreement modify this schedule in any manner that they deem appropriate. In the event the parties cannot agree on tiny modification, the schedule set forth above shall control. 4. The parties shall meet with the Custody Conciliator again for a Conciliation Conference on Thursday. February 3, 1999 at 8:30 a.m.. In the event the parties have reached an agreement on a permanent order prior to the Conciliation Conference, the parties may notify the Conciliator to have the Conciliation Conference cancelled. 5. This order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event the parties are unable to reach an agreement on a permanent custody order and in the event a hearing is required, the parties agreement to the custody schedule as set forth above shall not be binding on the parties with resect to a status quo involving custody of the minor child. 6. The parties shall keep each other advised with respect to phone numbers at home, home addresses, locations of any vacations where they take the child where the child will be away from that parents home for more than two (2) consecutive nights, all medical matters relating to the child and any other matters of importance. Additionally, both parties shall afford the other parent reasonable telephone contact with the minor child when the child is in that parents custody. BY THE Edgar B. Bayley\, cc: Gregory S. Hazlett, Esq. uo rn.ca? 8//b/4y James M. Bach, Esq. 14, p t•. r? ,g ? ? O ? y;;%_ y `? ???. ._ ' c: : ' i1 ?j cq p?o- ? ?, , u- ,,_ ;? ,rs `' c*+ v u ? ROBERT L. FISHER, JR., Plaintiff DANIEL E. FISHER, Defendant Prior Judge: Edgar B. Bayley M THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3765 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Shelby L. Fisher, bom October 19, 1995. 2. A Conciliation Conference was held on August 10, 1999, with the following individuals in attendance: The Father, Robert L. Fisher, Jr., with his counsel, Gregory S. Hazlett, Esquire; and the Mother, Daniel E. Fisher, with her counsel James M. Bach, Esquire. 3. The parties agree to the entry of an order in the form as attached. rs I(aL gI _Q1 V/ DATE Hubert X. Gil y, Esquire Custody Conciliator ROBERT L. FISHER, JR. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DANIEL E. FISHER : 99-3765 CIVIL TERM ORDER OF COURT AND NOW, this 22nd day of June, 1999, pending a further order of court, on the complaint of the father, Robert L. Fisher, Jr., for primary physical custody of Shelby L. Fisher, which is being referred to a conciliator, neither the father nor the mother Daniel E. Fisher shall remove Shelby L. Fisher from the State of Pennsylvania. By the Gregory S. Hazlett, Esquire For Petitioner Edgar B. Bayley, mid Daniel E. Fisher, Pro se 443 Whiskey Run Road Newville, PA 17241 :sea N- ii c:: ;i rt ) 7 4 JUN221999? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT L. FISHER, JR. n C A Plaintiff / Petitioner, No. 9N - 3 7?S i? V. DANIEL E. FISHER Civil Action \ Custody Defendant/ Respondent AND NOW, this day of , 1999, upon consideration of Petitioner's Emergency Petition for Custody, Respondent is hereby ordered to show cause, if any, why the requested relief should not be granted. Rule Returnable: BY THE COURT, J. E; M IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA Civil Action-Emergency Petition ROBERT L. FISHER JR., for Custody Petitioner, Case No. DANIEL E. FISHER, Respondent, 1. The petitioner is Robert L. Fisher Junior, an adult individual sui juris, who currently resides at 325 North Street, in the town of Boiling Springs, 17007 County of Cumberland Commonwealth of Pennsylvania. 2. The Respondent is Daniel E. Fisher, an adult individual sui juris who currently resides at 443 Whiskey Run Road in the town of Newville, 17242 County of Cumberland Commonwealth of Pennsylvania. 3. The parties were married on the 4' , day of April, 1996. 4. The parties have one child born outside of the bonds of matrimony of the name of Shelby L. Fisher, and of the age of three years. 5 Petitioner has filed a Complaint for Custody simultaneously with the filing of this petition and incorporates by reference thereto the averments in the complaint. 6. The parties were separated on or about May 17, 1999 and since that time have not entered into an agreement as to custody. 7. Respondent has informed the Petitioner that she will be relocating to the State of Virginia with the child on or about Thursday June 24, 1999. 8. The child's immediate family and friends reside within the county of Cumberland with whom the child has formed a close bond and alliance. 4 9. The child's medical and dental providers are located within this county, with whom the child feels comfortable. 10. Petitioner has had significant contacts with his child since m her birth and has provided substantially to her care and nurturing. 11. Respondent's move will isolate the child from contact with her father as well as the environment for which she has become accustomed and will inevitably disrupt and interrupt her life. 12. Respondent, heretofore has not sought permission or consent from the Honorable Court to remove the child from the Commonwealth of Pennsylvania. 13. The removal of the child is not in the bests interests and welfare of the child. 14. Petitioner, will be irreparably harmed should respondent be permitted to remove the child from the jurisdiction. WHEREFORE, petitioner respectfully requests that temporary and permanent injunctions be issued restraining respondent from relocating the child to a new residence until further Order of the Court and further requests that physical custody of the child be awarded to him. 20 ?afith l(dtket Street echanicsburg, PA. 17055 (717) 790-0490 Petitioner verifies that the statements made in this Emergency Petition to Prevent Removal of Children from Jurisdiction Pursuant to PA. R. Civ. P. 1915.13 and Request for Immediate Hearing are true and correct to the best of his knowledge, information and belief. Petitioner understands that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Section 4904, relating to unworn falsification to authorities. Date:-'L7-/& - 9 /Petitioner JUN 2 g 19IVi IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA ROBERT L. FISHER JR., Civil Action at Law No. 99.37b? Civil 1999 Plaintiff, CUSTODY VISITATION VS. DANIEL E. FISHER, Defendant, And now, this 9 upon consideration of the attached complaint, it is hereby directed that the bov parties and their respective counsel appear before Esquire, the conciliator, a ' th I:UJl1. d 1100 kgz Pennsylvania, on the th day of?Qp?irMn1 , 1999, at .M P.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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By: l `1 Custody Conciliator h v, b 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 COURT ADMINISTRATOR 2 Liberty Avenue CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 1-800-990-9108 99 JUL 13 hN 11: 09 PENNSYLN,IA 7•i3.99 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA ROBERT L. FISHER JR. Civil Action At Law Plaintiff, Case No. VS. DANIEL E. FISHER, Defendant, 1. The plaintiff is Robert L. Fisher Jr. , residing at 325 North Street Boiling Springs 17007 County of Cumberland, Commonwealth of Pennsylvania 2. The defendant is Daniel E. Fisher, currently residing at 443 Whiskey Run Road Newville, 17242 County of Cumberland, Commonwealth of Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Address Age Shelby L. Fisher 325 North Street, Boiling Springs _ 3 4. The child was bom out of wedlock. 5. The child is presently in the custody of Robert L. Fisher Jr., who resides at 325 North Street Boiling Springs 17007 County of Cumberland, Commonwealth of Pennsylvania 6. During the past three years the child has resided with both parents at 325 North Street Boiling Springs 17007 County of Cumberland, Commonwealth of Pennsylvania 7. The biological mother of the child is Daniel Fisher, currently residing at 443 0 Whiskey Run Road Newville, 17242 County of Cumberland, Commonwealth of Pennsylvania. 8. The mother is separated from he father, and defendant and is currently married. 9. The father of the children is Robert L. Fisher Jr. and is currently residing at 325 North Street Boiling Springs 17007 County of Cumberland, Commonwealth of Pennsylvania The father is separated but currently remains married to the mother, and Defendant. 9. The relationship of the plaintiff to the children is that of a biological father. The Plaintiff currently resides with the following persons: Name Relationship Shelby Fisher son 10. The 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. 11. The plaintiff has no other information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 12. 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. 13. The best interest of the child and permanent welfare of the child will be served by Granting the relief requested because: (a) The defendant to this action is threatening to leave for the state of Virginia and take with her the party's biological child without first seeking Court Approval prior to her departure. r (b) The child currently resides with his father in the home where he has been raised since his birth and within which he feels a sense of comfort, permanency, and familiarity. (c) Plaintiff, believes and therefore avers that he can continue to provide a predictable and stable lifestyle of which, the child has become accustomed that will be in the best interest of the child during its formative years and throughout its life. WHEREFORE, Plaintiff, Robert L. Fisher Jr., respectfully requests for the aforementioned reasons, that the court grant and award primary physical custody of the child to plaintiff. HAZLETT & OESTERLING 22 th Market Street echanicsburg, PA. 17055 (717) 790-0490 Petitioner verifies that the statements made in this Emergency Petition to Prevent Removal of Children from Jurisdiction Pursuant to PA. R. Civ. P. 1915.13 and Request for Immediate Hearing are true and correct to the best of his knowledge, information and belief. Petitioner understands that false statements herein are made subject to the penalties of 18 Pa. Cons. Star. Section 4904, relating to unworn falsification to authorities. Date: -/&- 9 . /'h. _ . z ? /Petitioner t,, r L: f ! L ) f 4 C: T ?o yJ 1^ JO r6 v d - 2 2000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY a COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION--LAW Robert L. Fisher, Jr. Plaintiff No. 99-3765 In Custody Vs. Danielle E. Fisher Defendant QRDJE$ 3000. in response to the AND NOW, this , day, of enclosed Motion for Continuance it is hereby ORDERED that the Custody Hearing scheduled for February 14, 2000 at 1:30 p.m. shall be continued to, and held on. 2000, al'4- 1,30 BY THE COURT Date: r. L ? ). ?., ;: iC.?L <:? ?/? IN THE, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA Robert L. Fisher, Jr. CIVIL ACTION---LAW Plaintiff No. 99-3765 Vs. In Custody Danielle E. Fisher Defendant AND NOW, comes the Plaintiffs attorney Gregory S. Hazlett, Esquire and states the following in support of his Motion for Continuance. 1. Plaintiff is Robert L. Fisher Jr. the biological father and primary custodian of Shelby L. Fisher. 2. Defendant is Daniel E. Fisher, the biological mother of Shelby Fisher. 3. On the 17' day of September 1999 and the 14' day of November 1999 the aforementioned parties appeared before Hubert Gilroy for a Conciliation Conference. 4. The parties are scheduled to have a Custody Hearing on February 14, 2000 before the Honorable, Judge Bailey. 5. Counsel for Plaintiff, Robert Fisher, has a Non-Dischargeability Hearing scheduled for February 14" 2000 at 1:15 p.m. of the same day at the bankruptcy court, before the Honorable Judge Woodside in the Middle District of Pennsylvania. 6. Plaintiffs counsel is unable to reschedule the aforementioned hearing before Judge Woodside and is therefore unable to attend the Custody Hearing scheduled on the same day due to this conflict. 7. This is counsel's first request for a continuance relative to this custody proceeding. 8. Plaintiffs attorney sought the consent from opposing counsel, James Bach, Esquire but received neither a consent nor a refusal to continue the matter. ?? ,? :., -:: - ' ?_ ; ?: ?_ - .--, - ?., 9. For the aforementioned reasons counsel for Plaintiff requests that the Honorable Court grant a continuance and reschedule the custody Hearing scheduled for February 14, at 1:30 to an alternative day and time. WHEREFORE, plaintiffs attorney Gregory S. Hazlett respectfully request that Honorable Court continue the Custody Hearing scheduled for February 14, 2000 to an alternate day and time. Date: 2/ I /00 Respectfully Submitted, 20 S th Market Street echanicsburg, PA. 17055 717-790-0490 ED Q 4 2000 ROBERT L. FISHER, JR- IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA v CIVIL ACTION - LAW DANIELLE F. FISHER, NO. 99-3765 CIVIL Defendant IN CUSTODY Prior Judge: Edgar B. Bayley COURT ORDER AND NOW this ?(f day of February, 2000, the conciliator being advised by the parties that they desire the conciliation cancelled. the conciliation scheduled for February 3 is cancelled and the conciliator relinquishes jurisdiction. /uert X. GiU' ,Esquire O 14 LL r M >- ? 4 -t 7 U 2 Z a J 7 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA Robert L. Fisher, Jr. Plaintiff Vs. Danielle E. Fisher Defendant CIVIL ACTION---LAW No. 99-3765 In Custody AND NOW, this tj , day, of OK`tg , 2000, in response to the Request for a Continuance it is hereby ORDERED that the Custody Hearing scheduled for March 22, 2000 at 1:30 p.m. shall be continued to, and held on, April 5'", 2000 at 1:30 p.m. ? J Date: BY THE COURT 00 ?o c? Pv vp F O ?j.. N)TRY 001?p I7 PH 2: 46 CU?;? Ru;'d COJNTY PciVNSYLVANiA RORERT L. FISHER, JR. PLAINTIFF V. DANIELLE E. FISHER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-3765 CIVIL TERM ORDER OF COURT AND NOW, this L_day of March, 2000, a Rule is entered against Robert L. Fisher, Jr., and Danielle E. Fisher, to show cause why the relief requested herein should not be granted. Rule returnable ten (10) days after service. Any answer filed by plaintiff or defendant shall be forwarded by the Prothonotary to chambers. Gregory S. Hazlett, Esquire For Plaintiff James M. Bach, Esquire For Defendant Robert L. Fisher, Jr. 325 North Street Boiling Springs, PA 17007 i By the Co i Edgar B. Bayley, J. 3'00 W15 :saa Ii 71j ` 21r„i„?v1? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA Robert L. Fisher, Jr. CIVIL ACTION----LAW Plaintiff Vs. Danielle E. Fisher, Defendant NO. 99-3765 IN CUSTODY Upon consideration of the Motion to Withdraw as Counsel of Robert L. Fisher Jr. it is hereby ORDERED, that the Motion is GRANTED; and Gregory S, Hazlett, Esquire is authorized to withdraw his representation of the aforementioned individual relative to the Respondent's Child Custody Hearing. IT IS SO ORDERED, this , day of 2000 J. r d+ ?s U C- i 4 CL 1 0-- Y ? LJJ ro O C3 U HAZLETT & OESTERLING =• 20 SOUTH MARKET STREET MECHANICSBURG, PA 17055 (717) 790-0490 `"'? ? 9 200p 'i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA Robert L. Fisher, Jr. CIVIL ACTION---LAW Plaintiff Vs. NO. 99-3765 IN CUSTODY Danielle E. Fisher, Defendant MOTION TO WITHDRAW A COUNSEL Gregory S. Hazlett, Esquire, hereby moves this court for the entry of an Order authorizing his withdrawal as counsel for Robert L. Fisher, JR. plaintiff in the aforementioned action. In support thereof, Counsel respectfully represents: 1. Counsel represents Plaintiff relative to a Child Custody matter that was initiated by plaintiff against the foregoing defendant. 2. Counsel attended two separate conciliation hearings on the matter of custody before Hubert Gilroy whereupon primary custody remained with plaintiff. 3. Plaintiff has a court hearing before the Honorable Judge Bailey on March 22, 2000 at 1:30 p.m. to decide the issue of custody. 4. Plaintiff was advised repeatedly by counsel at his last conciliation hearing held on November 30, 1999 that counsel had to be paid prior to his attendance at the custody hearing or counsel will not attend the hearing. 5. Plaintiff was aware of the requirement that all attorneys' fees with regard to his custody hearing had to be paid in full or the attorney would not attend. 6. Plaintiff after having been advised repeatedly to pay the attorney's fees has not heretofore complied with these requests nor has attorney received any fee to date. 7. Plaintiff had both adequate time and notice to make payment to the attorney but has failed to fulfill his financial obligation 8. The attorney's quality of representation will be severely compromised due to the level of time and effort that needs to be expended in the absence of any financial remuneration. 7. Plaintiff had both adequate time and notice to make payment to the attorney but has failed to fulfill his financial obligation 8. The attorney's quality of representation will be severely compromised due to the level of time and effort that needs to be expended in the absence of any financial renumeration. WHEREFORE, Counsel respectfully requests that the Court enter an Order authorizing Counsel to withdraw from representing the Plaintiff in this case, and granting such other and further relief as is just and proper. RESPECTFULLY, HAZLETT&OESTERLING ATTORNEYS AT LAW Me6hanicsburg, PA. 17055 Atty I.D. 69528 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA Robert L. Fisher, Jr. Plaintiff Vs. Danielle E. Fisher, CIVIL ACTION--Law No. 99-3765 IN CUSTODY I, Gregory S. Hazlett, Esquire, hereby certify that a true and correct copy of the foregoing Motion to Withdraw as Counsel, was made upon the interested parties attached hereto by, first class mail postage prepaid, a true copy on the 24-d, day of March, 2000. Robert L. Fisher, Jr. 325 North Street Boiling Springs, PA. 17007 Date: 2/29/2000 717-790-0490 ROBERT L. FISHER, JR., PLAINTIFF IN '11 IE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. DANIELLE E. FISHER, DEFENDANT' 99-3765 CIVIL TERM ANSWER OF DEFENDANT DANIELLE E. FISHER 1.0 MQ11ON OF ATTORNEY GREGORY S f- AZLETT IO X1111DRAWAS I FGAt O NSEL AND NOW, comes Danielle E. Fisher defended by her Attorney, JAMES M. BACH, and files the within ANSWER TO A MOTION TO WITHDRAW AS LEGAL COUNSEL: 1. The motion to withdraw as legal counsel has been properly served upon Attorney James M. Bach 2. The Defendant herein, does not oppose this motion to withdraw. 3. This motion will not interfere with the administration of justice, and the parties have stipulated and agreed to a trial on the 5"' day of April, 2000 at 1:30 p.m. before the Honorable Edgar Bayley, Judge of the Court of Common Pleas of Cumberland County. Respectfully Submitted, ?a tes M. Bach Attomeyyat-Cam > 11) #18727 352 South Sporting 1 fill Road Mechanicsburg, PA 17055 ?- a G N O ?? a N JZ _ O O U IN TIM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA Robert L. Fisher, Jr. CIVIL ACTION-LAW Plaintiff Vs. Danielle E. Fisher, Defendant NO. 99-3765 IN CUSTODY AND NOW, Us Z day of ^ r x,2000 upon consideration of the Motion to Make the Rule to Show Cause Absolute it is hereby ORDERED, that the Motion is GRANTED; and the rule is hereby made absolute and the relief requested is granted. It is further ORDERED, that Gregory S, Hazlett, Esquire attomey for plaintiff, is herebyallowed to withdraw his representation of Robert E. Fisher, relative to the Plaintiffs Child Custody Hearing. i '?U?;q- .IAA. ,,r /' ?'/ NCB , /.^" a HH & OESTERLING 20 SOUTH MARKET STREET MECHANICSBURG, PA 17055 ' (717) 790-0490 3-2H-o? Cr O f J _ t ` + t ' r ] J y IL I:. CV _' _ ?:I1J v 0 o ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA Robert L. Fisher, Jr. CIVIL ACTION-LAW Plaintiff NO. 99-3765 Vs. IN CUSTODY Danielle E. Fisher, Defendant NOW comes Gregory S. Hazlett, Esquire, and hereby moves this court for the entry of an Order Making a Rule to Show Cause Absolute issued by the Court in response to a Motion to Withdraw as Counsel for failure to pay attorney's fees and in support thereof, Counsel respectfully represents: 1. Counsel filed a Motion to Withdraw as Counsel against Plaintiff Robert Fisher on March 2, 2000 with the Court of Common Pleas of Cumberland County for his failure to pay attorney's fees towards a Custody Hearing which was scheduled to take place on March 22, 2000 and was later continued to April 5, 2000. 2. A Rule to Show Cause was filed on March 2, 2000 with the Honorable Court relative to attorney's Motion to Withdraw as Counsel. 3. The Rule to Show Cause was signed by the Honorable, Judge Bayley on March 13, 2000 allowing 10 days from this date to plaintiff Robert Fisher to respond contest the withdrawal of counsel from his custody case due to non-payment of attorney's fees. 4. Plaintiff' Robert Fisher, has not contested the withdrawal of counsel from his case within the 10 day period as prescribed by the Honorable Judge Bailey. 5. Defendant's attorney, James Bach, Esquire has granted his consent to Gregory S. Hazlett, Esquire to withdraw as counsel. WHEREFORE, Counsel respectfully requests that the Court enter an Order making the Rule Absolute relative to Counsel's Motion to Withdraw as Counsel for Plaintiff Robert Fisher and such other and further relief as is just and proper. 3/-2 3100 RESPECTFULLY, HAZLETT&OESTERLING ATTORNEYS AT LAW Market Street esbure. PA. 17055 Atty I.D. 69528 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA Robert L. Fisher CIVIL ACTION-LAW Plaintiff Vs. NO. 99-3765 IN CUSTODY Danielle E. Fisher, Defendant I, Gregory S. Hazlett, Esquire, hereby certify that a true and correct copy of the foregoing Motion to Make Rule Absolute, was made upon the interested parties listed hereunder by, first class mail postage prepaid, a true copy on the 24' , day of March, 2000. Robert Fisher 325 North Street Boiling Springs, PA. 17007 James Bach, Esquire 325 S. Sporting Hill Road Mechanicsburg, PA. 17055 Date: 2/24/2000 717-790-0490 Joasph A. Cincotta, M.D. fo,Wf. ClnceNa, M.D. DesRrey M. Jams, M.D. DAY M. SChWI M.D. DWd R. Wenner, D.O. 8wN Setur, M.D. Iabi A. Alealm, C.R.N.P. Denhle J. Hough, C.R.N.P. Teas DN2, C.R.N.P. Mary E. Poleon, C.R.N.P. TOWN L. Johnson, PAC Lc rc!?7 'A:7 IH 02:3E.F'M W LICI MO.O1B341•E (PA) LICO MD-017634•E (PA) LICO MD-0221NII (PA) LICI MD-030532•E (PA) BOWMANSDALE FAMILY PRACTICE LICI 08-005403-1. (PA) 1 KACEY COURT, SUITE 101 LICI MD-0E2206-1. (PA) MECHANICSBURG, PA 17055 LICO VP-001525•B (PA) (717) 591.0961 LICO SP-0030968 (PA) LICI SP401038•B (PA) LICO SP-MO53•C (PA) LICI MA-0007341. (PA) Appt Time CURRENT INS. - C GUAR 17 El's,HEPHERDSTOWN FAMILY PRACTICE 2140 FISHER ROAD A23249 MECHANICSBURG, PA 17055 (717) 766-1795 a s,1• PATIENT NAME ACCOUNT CODE PCP REFERRING DR. DOB 8EX J e.. )y '1k; l7'l l'L_ 1 1, ! '.1 IIC: rl .rl-1 I it S., f11 .1 INSURANCE COMPANY NAME I.D. NUMBER GROUP NUMBER REL. TO INS. 991 a 1; IL7!i 577777: R L:,L'df 1'l. d.! 1 41,:: 9 .d?I 1 . O CAS 02 H G (o co ?? NEW OFFICE VMna ESTA?1jHED IMMUNIINJ: i?1112 PERFORMEDBY: ?HW3 OSKBL DRIVEN ?IBH 99099 ANN Howe __ 99211 , , 52 ne non. Fee J Bw24 ? caC D C11 s pm 99Mt Lme4d 99212 UmIMd DTap '\ --- 80019 But kNewasc 992x2 Miami W213 InNmatl -'I TOPV X713)(IPV soo54 Oaegremenene these9M 99943 EmMea 99214 Eslenpld MR 80051 Electrdyle POW MU CPnpl 99215 Conexenen _ K744 Hope.251010ym, 80081 Lipp Phalle, 088 OMON Em4q. 90882 Med Mp. W745 He,D 5 l11.19 yrn 84703 HCGBna OL 9740 GYN (1188) _ X5741 GYN (BSI X746 Hip 6101,20 yrs) 83038 H;b AtC NEW PREVENTIVE ESTABUSHED X720 OPLHIa U701 HIV Screening NOW Gen Med(MA) EPSDT X716 Varicelia auto Phemnpn Time MOST Under 1 V. Urger t yr. X718 a 90702 : Pad dT 84153 PEA 99382 NM. N3M 4yn. ----- X724 InAUenae 115651 Sad Rare, Wenner am 5.11 Yrs. 93 5I I yn X732 Pneum9m99al 84443 TSH 00]8/ 12.17 yu. _ N394 1217 yH 86585 Tine Test -- 99305 1809 Yrs. 99395 18-my" 95115 Allergy _JI - 8204] Unnp Micro ABMNn MR 4081 Yn 99396 4084 yrs. 95117 Allergy :'. 2 1 3 1 4 MM7 OE" 19397 1558over 96580 Mantow -- MOSPITU SERVICES:I 1 HSH. Camp Hill 1 1 HBO Hap PATHOLOGY TO: ', 9005E D PSM [I WIN Dow T. -_____ -__ PROCEDURES: 117797 Gen Props, 1922- In4W 99431 NS 92552 Aw4nelry Rim PAP 99231 Subseglent 99435 Ia IN4 PGwI___ 57454 Colposcopy Tissue DIRM S bsink nl 99433 NBSO Deeluulon (Wam) _ N233 Slbepuent _ 59100 Endemelnal Mcinnon _ 9B23e DNmege -- 93000 EKG eM his, -- tl_ 6nswn lLespnl un IN OFFICE LABORATORY: NUR8M0 NOME: NWSE CALL9 82270 Hempaun II x 3 38415 Vempurlnure M- 9935 -- - 10 IMA Diane, B2947 Glucose Mw/DME: 206- - Inleceon.A, t 85018 Hemoglobin W799 Peak Fpa 84703 Pregnancy - Unne -'-- Uses Pulmanage _ 87220 KOH Prp. 120 Face Owner. rn 87210 Saline 45230 Slgmi. 87M0 Find Sept 94010 Spmmetry 81003 DUA 81001 D UA w.Meq Abdominal Pain 789.00 Cervical Strain 847.0 IDDM NIDDM Hemorrhoids, Ext 455.3 Peripheral Vas. Dis. 443.9 Vaginitis, Candidal 112.1 Adrormal PAP 795.0 Chest Pain 786.50 Controlled 250.01 250.00 High Risk Med V58.69 Pneumonia 486 Vital syndrome 079.99 Arne 706.1 CAD 414.9 Uncontrolled 250.03 250.02 Hypelfipidamia 272.4 Post Menopausal 627.2 Warts 078.10 ADD 314.00 / ADHD 314.01 CHIP 428.0 Neuro 250.61 250.60 Hypertension 401.1 Rectal Bleeding 569.3 N.M.I. P.E. wRorm V70.3 Allerglc Reaction 99513 C.O.P.D. 496 Ophthalmic 250.51 250.50 Hyperthyroa ism 242.90 Shonness of Breath 786.09 Routine P 8 P V72.3 Allergic Rhinitis 477.9 Conjunctivitis 372.00 Renal 250.41 250.40 Hypothyroidism 244.9 Sinusitis - Acute 461.9 AtlulVAtldes. P.E. y78:q Anklery 3ODGIO Coumadin Therapy 286.9 Oys. Utenne Bleeding 626.8 Influenza 487.1 Sinusitis - Chronic 473.9 InfamVChild RE (?/20-0y0 Adh2l 716.90 Counseling V65.40 Fatigue 780.7 HIS 564.1 Situational Stress 308.0 Newborn RE. Asthma 493.90 Degen. Jt. Disease 715.90 Gastrula 535.00 Labyrinthitis 386.30 Smoker 305.1 Family HX: DM V18.0 Asthma • Extrinsic 493.00 Depresslon 296.20 Gastroentedlis - Van] OOB.B Manormagia 626.2 Sore Throat 462 Hypertension V17.4 Back Pain 724.5 Dermatitis 692.9 GE Reflux 530.81 Obesity 278.00 Strap Throat 034.0 CAD V17.3 BrarlohlAs • Acute 466.0 Dermatilis, Plant 692.6 Headache 784.0 Cateoyoaosis 733.00 U.R.I. 465.9 Colon CA V16.0 Bronchitis • Chronic 491.21 Diarrhea 78191 Headache, Migraine 346.00 Otitis Media 382.00 U.T.I. 599.0 Screen Cohn CA V78.41 Gammon Impadion 380.4 Dizziness 780.4 Hemorrhoids, Int 455.0 Olds Externa 380.10 Vaginilis 61fi.10 OTHER: -/-Yr. If Mo. Day Yr. CONSULT LIMITATIONS Mo. Day INSTRUCTIMS OK m retum to Work / / I I ( ) Shccol _ - Lie Mo. D Yr. ? TREAT (] SPEC SEW iiiiiiiiiiiiiiiiiLj 11 SRHE II fr-' I LIMITATIONS: Tic D STUDIES wu. n uns slunAl une ? UB RN REASON DAY DATE TIME Ake DAYS PM D SCREENING MAMMOGRAM D DIAGNOSTIC MAMMOGRAM WEEKJ. ? "ED se I MONTHS -,,,_,,. ,,..,wi,rv.,u.reonanit, yar aPporinwm Masser,, en apppne eM wF respn n an 0. wage INSURANCE COPY SFPAkFP FORM or her1 I I I .1 Dat$r!!e Fisher 102 Cherokee Coin! Thaxton VA 14174 O9r (-_ 1680 Fug In ?? r eo.en1 2313 Ih nrJrr n r o ?, •M?n?„bees 1$ PO. eo?b r nra ''?P"k'a^0. PA 1?0!! 23338224w16,30 23&353y775u9y ^\? .. . y M r r, r ROBERT L. FISHER, JR., Plaintiff V. DANIELLE E. FISHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3765 CIVIL TERM ORDER OF COURT AND NOW, this 5th day of April, 2000, this matter having been called to court this date on a hearing on the merits, the following order is entered: 1. All prior custody orders are vacated and replaced with this order. 2. Robert L. Fisher, Jr., and Danielle E. Fisher shall have shared legal custody of Shelby L. Fisher, born October 19, 1995. 3. The mother and father shall have shared physical custody of Shelby. 9. The residence at 5:00 5. The residence at noon 6. The residence at noon mother shall p.m. today, father shall on Saturday, mother shall on Saturday, pick up Shelby from the father's April 5, 2000. pick up Shelby at the mother's April 22, 2000. pick up Shelby from the father's May 6, 2000. 7. Thereafter the transfers will be on an every other Saturday basis with the parent getting the child being the parent who picks up the child at the residence of the other parent. 8. Each parent shall make arrangements for Shelby to have telephone access with the other during the period of time that Shelby is with that parent. 9. This court retains jurisdiction. James M. Bach, Esquire For Defendant Robert L. Fisher, Jr., pro se 325 North Street Boiling Springs, PA 17007 Sheriff 00 prs By the Court;-. (J /. L( i ? V???. CAROL SHARPLES, PLAINTIFF VS. ROBERT J. SHARPLES, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 3767 CIVIL TERM CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned as counsel of record for the Defendant Robert J. Sharples. BY: ti even owel , Esgwre 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Defendant Date: April 12, 2000 Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the following individuals by postage prepaid, first class United States Mail addressed as follows: Robert P. Kline, Esquire P.O. Box 461 New Cumberland, PA 17070-0461 E Date: April 12, 2000 ?, _-_ ?r -_ ?i ;?? ' i ? `t " 1 . _.. ?. 11; ?'1 ?) a DANIELLE E. FISHER IN 77 [E COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT L. FISHER, IR. • 99-3765 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, March 30, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor Cumberland County Courthouse, Carlisle on Friday. April 27, 2001 at 8:30 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. The court hereby directs the parties to furnish any and all existing Protection front Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. C d![sgt, sue- `7 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 WIIERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 /;1G2? C? DANIELLE E. FISHER, Defendant/Petitioner V. ROBERT L. FISHER, JR., Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99-3765 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this day of 2001, in consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before Esquire, the conciliator, at on the _ day of 2001 at _.m. for a Pre-hearing Custody Conference. At such conference, 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 this conference may provide grounds for entry of a temporary or permanent order. By the Court, Custody Conciliator 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 Courthouse 1 Courthouse Square Carlisle, Pennsylvania 17013 (717) 240-6200 AMERICANS WITH DISABHdTIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. DANIELLE E. FISHER, IN THE COURT OF COMMON PLEAS OF Defendant/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 99-3765 CIVIL TERM ROBERT L. FISHER, JR., Plaintiff/Respondent IN CUSTODY PETITION FOR CUSTODY AND NOW comes the Petitioner, Danielle E. Fisher, by her attorneys, Irwin, McKnight & Hughes, and presents the following Petition for Custody. The Petitioner is Danielle E. Fisher, an adult individual residing at 106-B Lincoln Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent is Robert L. Fisher, Jr., an adult individual residing at 325 North Street, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. The parties are the natural parents of one child, namely, Shelby Linn Fisher, born October 19, 1995. 4. Petitioner desires primary physical custody of the child and joint legal custody with periods of visitation to respondent as the parties agree is appropriate and in the best interest of the child. 5. The best interest of the child requires that the court grant the petitioner's request as set forth above. WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking primary physical custody of the child and joint legal custody with periods of visitation to respondent as listed above. Respectfully submitted, & HUGHES Date: 2001 By: ?J-v Ma us Afor P. Mce , II, quire Atttey t' oner 60 West Pomfret Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I.D. No. 25476 VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by counsel and myself in the preparation of thir action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification to authorities. ??.,40. ?sllalt DANIELLE E. FISHER Date: , 2001 I :? r II. tj PJ I<. '? U v: A1' '71 00 rr / h C) 00 `TM'/Wl C?J V ' ?,< e N x V1 1 Lv m' c S?? t o .r i ?? vir ? ? E ?c ?`Y\ 'Q C r a gg s rY1 f °I 1 A ? I p r i? Fr, 4. K OC ?l r ? V? *? J p/ r'f [?yj I *'r"5 ?? ? ? ? ? Y J2Sltjyr c PWP4^4 p?yy {y a rpr?4Ap?a', t F, ? /41'fi? 1 T'^ ! 111"'?e??km t}S f 6? f,, vA n, 'LV?l vrt> P r h3•F "p+ A 4 1,A i' J rSS{.; }( 11 k `Fry, ?(j.? 1 r r ? ?Y nt N'"?wN v J ?kW 1 rp. ?•Y. ':'x r , _ - Y ' MAY 0 1 ROBERT L. FISHER, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DANIELLE E. FISHER, NO. 99-3765 CIVIL Defendant IN CUSTODY COURT ORDER V*MA AND NOW, this lb1Lday of April, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior custody order entered in this case is vacated. 2. The Father, Robert L. Fisher, Jr., and the Mother, Danielle E. Fisher, shall enjoy shared legal custody of Shelby Linn Fisher, bom October 19, 1995. 3. The parties shall share physical custody pursuant to the prior arrangement which was a two week on/two week off schedule. This arrangement is contingent upon the requirement that the child shall remain with the Father when the Father has custody, and that the parties shall cooperate with each other to attempt to obtain one daycare provider for the minor child to maintain the consistency of daycare. 4. Starting in late August or September when Shelby starts school, at that time the Mother shall have primary physical custody with the Father enjoying alternating weekends, alternating holidays, and other times as agreed upon by the parties. The parties will work with each other to attempt to obtain an agreement for physical custody of the minor child during the summer starting 2002. If the parties cannot reach an agreement, either party may petition the court to have this case again scheduled with the Custody Conciliator. 5. Arrangements with respect to transportation and other similar issues pertaining to exchange of custody shall continue as they have in the past. ,If BY T44E COURT cc: Marcus A. McKnight, III Robert L. Fisher, Jr. 325 North Street Boiling Springs, PA 17007 Edgar B. Bayley J. ti to ?; j o J ROBERT L. FISHER, JR., Plaintiff DANIELLE E. FISHER, Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.99-3765 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Shelby Linn Fisher, born October 19, 1995. 2. A Conciliation Conference was held on April 27, 2001, with the following individuals in attendance: The Mother, Danielle E. Fisher, with her counsel, Marcus A. McKnight, III, Esquire; and the Father, Robert L. Fisher, Jr., who appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. qI 34 v( (1 DATE Hubert X. Gilr, Esquire Custody Cop iator