Loading...
HomeMy WebLinkAbout99-04961 (2) r7 i:$ yy?? C ,'n V i AUG 1 7 199 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA MEADE BUFFINGTON III., Civil Action at Law No. , Civil 1999 Plaintiff, CUSTODY VISITATION VS. KAREN GAULT, : qq - 496' Defendant, ORDER OF COURT And now, this ?la? 1aa upon consideration of the attached complaint, it is hereby directed that the above parties and their respective counsel appear before e-n Pennsylvania, on the a? , day of ?r?sbCmtir'r , 1999, at 1; .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: 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. CUMBERLAND COUNTY COURT ADMINISTRATOR 2 Liberty Avenue CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 1-800-990-9108 99 A(!G 2S P,'; is 4 CUhPLIV1?3YLVi?? U;?rfy 'v"CIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA MEADE BUFFINGTON III, Civil Action At Law Plaintiff, Case No. 99- Vfti KAREN GAULT, Defendant, 1. The plaintiff is Meade Buffington III, an adult individual sui juris, who currently •esides at 408 West Dauphin Street, in the town of Enola 17025 County of Cumberland ;ommonwealth of Pennsylvania. The defendant is Karen Gault, an adult individual sui juris who currently resides at 2206 F Cedar Run, in the town of Camp Hill, 17011 , County of Cumberland Commonwealth of Pennsylvania. . Plaintiff seeks custody of the following children. Kyla McKay Gault 2206 F Cedar Run Camp Hill, PA. 17011 4. The children were born outside of the bonds of matrimony. 3 months Brithdate: 5/28/99 5. The child is presently in the custody of Karen Gault, who resides at 2206 F. Cedar Run Camp Hill, Pa. 17011 in the County of Cumberland. 6. During the past 3 months the child has resided with Karen Gault at the following address: 2206 F. Cedar Run Camp Hill, PA. 17011 in the County of Cumberland. 7. The biological mother of the child is Karen Gault who currently resides at 2206 F. Cedar Run Camp Hill, PA. 17011 in County of Cumberland 8. The mother is separated from the father, and has been since October 1998, and is currently unmarried. 9. The father of the children is Meade Buffington III, who is currently residing at 408 West Dauphin Street, Enola, PA. 17025 County of Cumberland, 10. The father has been separated from the mother for approximately 10 months and he currently remains unmarred to the mother. 11. The relationship of the plaintiff to the children is that of biological father. 12. The Plaintiff currently resides with the following persons: Name Relationship Cheston Zimmerman mother 13 . 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 any other court within or outside the boundaries of Pennsylvania. 14. The plaintiff has no other information of a custody proceeding concerning the child Pending in a Court of this Commonwealth. 15. 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. 16. The best interest of the child and permanent welfare of the child will be served by Granting the relief requested because: (a) The plaintiff mother, although she has been the primary caretaker of the children she has exemplified an unwillingness and open defiance towards the plaintiff father in her efforts to exclude the father from being with his child for several months despite his repeated and diligent efforts to foster and maintain an ongoing relationship with his child. (b) The father has only recently had one opportunity to see his child since her birth. ( c) Plaintiff, believes and therefore avers that he can and will strive if presented with the opportunity, to be a stabilizing force in the children's lives and in doing so assume an active role as a primary caretaker and caregiver to the children. (d) The defendant mother has no legitimate basis in fact or in law for restricting and circumscribing father's interchange with his children. WHEREFORE, The Plaintiff, Meade Buffington III, respectfully requests for the aforementioned reasons, that the court grants and awards him joint physical custody of his child Kyla McKay Gault. HAZLETT & OESTERLING 21YSouth Market Street echanicsburg, PA. 17055 717-790-0490 I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. & 4904 relating to unsworn falsification to authorities Date: 0 ?? AMERICAN WITH DISABILITIES 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 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. BY THE COURT: Date: J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA MEADE BUFFINGTON III, Civil Action at Law Plaintiff, Case No. VS. KAREN GAULT, Defendant, 1, Gregory S. Hazlett, Esquire, hereby certify that service of the foregoing Complaint For Child Custody was made upon defendant, KAREN GAULT by mailing, certified mail, postage prepaid, a true copy to defendant, at 2206 F. Cedar Run, Camp Hill PA. 17011 on the , day of August 1999. A,Korney for Meade Buffington 0 South Market Street Mechanicsburg, PA. 17055 717-790-0490 i4 1 ?Lu Ul °i ? m U M I w ;? (?J. CL CJ n MEADE BUFFINGTON, III, Plaintiff vs. KAREN GAULT, Defendant ri : IN THE COURT OF COMM PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4961 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this _ L- J day of Ll ocog , 1999, upon Sonsid0ation of the attached custody Conciliation Report, it is ordered and df{Ftcted as follows: c: b. The Father, Meade Buffington, III, and the Mother, Karen Gault, ihalt'have shared legal custody of Kyla McKay Gault, born May 28, 1999. 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 her health, education and religion. 2. The mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child in accordance with the following schedule: A. For 3 months, beginning Sunday, September 26, 1999, the Father shall have custody of the Child every Sunday from 12:00 noon until 6:30 p.m. B. After the 3 month period set forth in subparagraph A. of this provision, the Father's periods of partial custody shall increase to alternating weekends on both Saturday and Sunday from 12:00 noon until 6:30 p.m. and one weekday period of custody each week as agreed between the parties and at times and places arranged by agreenent of the parties. C. The parties agree that their mutual goal is for overnight periods of partial custody to begin when the Child reaches her first birthday. The parties shall cooperate in establishing an ongoing custody schedule with overnight periods for the Father by agreement. In the event the parties are not able to reach an agreement as to an ongoing custody schedule, counsel for either party may contact the Conciliator to schedule an additional Conference. 4. The parties shall alternate or share having custody of the Child on holidays as follows: A. CHRISTMAS: in 1999, the Father shall have custody of the Child on Christmas Eve from 9:00 a.m. until 7:00 p.m. and the Mother shall have custody of the Child from Christmas Eve at 7:00 p.m. through Christmas Day. The parties shall share or alternate having custody of the Child over the Christmas holiday in future years as arranged by agreement. B. TEANRSCUING: In every year, the Mother shall have custody of the Child on Thanksgiving Day from 8:00 a.m. until 2:00 p.m. and the Father shall have custody of the Child from 2:00 p.m. until 8:00 p.m. C. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day and the Father shall have custody of the Child every year on Father's Day. D. CHILD'S BIRTHDAY: Each party shall have a period of custody with the Child on the Child's birthday in each year with the specific times to be arranged by agreement of the parties. E. RHNAINING HOLIDAYS: The parties shall make arrangments for custody of the Child on the remaining holidays by mutual agreement. 5. In the event either party intends to remove the Child from the Commonwealth of Pennsylvania for an overnight period or longer, that party shall provide the other party with the address and telephone number where the Child can be reached. 6. Neither party shall use illegal drugs or consume alcohol to excess during his or her periods of custody with the Child. 7. In the event the Child is not available for a period of partial custody with the Father due to illness, the parties shall make arrangements for a makeup period of custody as soon as possible. 8. The Father shall be present to provide care for the Child during all of his periods of custody. 9. This order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the terms of this Order by mutual consent. In the absence of mutual consent, the terms of this order shall control. cc: Lee Oesterling, Esquire - Counsel for Father Joan Carey, Esquire - Counsel for Mother Av THR mrm2T. MEADE BUFFINGTON, III, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99-4961 CIVIL TERM KAREN GAULT, : CIVIL ACTION - LAW Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPM IN ACCORDANCE WITH CE14BERLAND 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 BIM CURRENTLY IN CUSTODY OF Kyla McKay Gault May 28, 1999 Mother 2. A Conciliation Conference was held on September 23, 1999, with the following individuals in attendance: The Father, Meade Buffington, III, with his counsel, Lee Oesterling, Esquire, and the Mother, Karen Gault, with her counsel, Joan Carey, Esquire and Sonya Lawrence. 3. The parties agreed to entry of an order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator > w 13 W @ 4 E? H g o ? N N 4 , 4 H'10 Ha ? ? ' EH U ° ? eo ?'a? ?y H A m ?3 a h SEP 3 0 199a MEADE BUFFINGTON, III IN T'IiE COURTOF COMMON PLEAS OF PLAINTIFF CUMI)EIZLAND C'OUNT'Y, PENNSYLVANIA V. KAREN GAULT 994961 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, _ Thursday February 09 2006 , 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, PA 17055 01 1. March 01, 2006 at 10:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Dawn S Sunday, E'sq Custody Conciliator O` 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 OF THE- rr, ,"v?;IAF'f 2005 FS 10 a •/D p?, ?! . ? .sae ? ? ??? a•iopG !l firms./ f d -/o eo- `?`' 4 °? , Y. MEADE BUFFINGTON,111, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO.: 99-4961 CIVIL TERM KAREN GAULT, Defendant/Petitioner : CIVIL ACTION - LAW :CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at 2006, at on the day of _ _. 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. BY THE COURT, By: Custody Conciliator The Court of Common Pleas of Cmnberland 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 /? t r ,fit You must attend scheduled conference or hearing. 17?F Y Wdu? S n I r/ DUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA / r S? I? bEGd?c S>_T TELEPHONE THE OFFICE SET FORTH BELOW TO F11 J1310t, 4. IEFERRAL SERVICE BEDFORD STREET .ISLE, PA 17013 00) 990-9108 S rI MEADE BUFFINGTON, Ill, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO.: 99-4961 CIVIL TERM KAREN GAULT, Defendant/Petitioner :CIVIL ACTION - LAW :CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at 2006, at on the __ day of 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. BY THE COURT, By: Custody Conciliator The Court of Common Pleas ofCwnberland 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 scheduled conference or hearing. 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. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET S CARLISLE, PA 17013 (800) 99.,-9108 MEADE BUFFINGTON, III Plaintiff/Respondent Vs. KAREN GAULT, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4961 CIVIL TERM PETTITION TO MODIFY CUSTODY ORDER AND NOW, this day of February 2006, comes Karen Gault, by and through her attorney Michael D. Rentschler, Esquire, who files the within Petition seeking a modification of the existing custody order, by respectfully averring as follows: 1. The Petitioner is Karen Gault, an adult individual who is currently residing at an undisclosed address in Cumberland County, Pennsylvania 17062 (hereinafter referred to as "Petitioner"). Petitioner resides at that address with her Children Kyle McKay Gault and Ashlyn Jade Gault. 2. Respondent Meade Buffington, III (hereinafter referred to as 'Respondent) is an adult individual who is currently resides at 406 West Dauphin Street, Enola, Cumberland County, Pennsylvania 17025. 3. The subject children in this matter are Kyla McKay Gault, who was born on May 28, 1999 and Ashlyn Jade Gault, who was born on August 23, 2003 (hereinafter referred to as "the children"). 4. The relationship of Petitioner to the children is that of the natural mother. 5. The relationship of Respondent to the children is that of natural father. 6. On of about September 2, 2004 a final order of protection was entered against Respondent in Cumberland County, at docket number 04-3995. A true and correct COPY of that Protective Order is incorporated herein, made a part hereof and attached as Exhibit "A". 7. Exhibit A provides Plaintiff (Petitioner herein) with primary physical custody of the children and Defendant (respondent herein) was granted periods of supervised visitation the children on Wednesdays from 5:00 pm until 7:00 pm, on Fridays from 5:00 pm until 8:00 pm and on alternating Sundays from 9:00 am until 4:00 pm. The exchanges were ordered to take place at the Enola Municipal Building, in Enola. It was further ordered that the visitation for Defendant (Respondent) be at his mother's house. Respondent subsequently gave up the Wednesday visitation. 8. The Protective Order is scheduled to expire on March 3, 2006, and Petitioner is still fearful of Respondent. 9. On or about October 1, 1999, an Order of Court granted Defendant (Petitioner herein) with primary physical custody of Kyla McKay Gault. 10. The current order for custody provides Petitioner with primary physical and joint legal custody of one child, namely Kyla McKay Gault. However, since that order was in effect, the parties have another child together, being Ashlyn Jade Gault, who was born on August 23, 2003. 11. Since Ashlyn's birth, she has resided with Mother from birth to October 2003; with Mother and Father from October 2003 to December 2003; and with Mother from December 2003 to present. 12. It is in the best interest and permanent welfare of the children that Petitioner is granted primary physical custody and joint legal custody of the children and that visitation with the children by Respondent be supervised. This is based upon the fact that Mother can provide a stable and loving environment with the children; she has been the primary caregiver of the children; there are past incidents of abuse and threatened abuse of the children by Father; and that Father pled guilty to recklessly endangering another person with the victims being the Petitioner and the two children. 13. There is no rational basis for denying Petitioner's request. WHEREFORE, it is respectfully requested that this Honorable Court grant the within Petition and, therefore, grant Petitioner majority physical custody and joint legal custody of the Children and that visitation with the Children by the father, be supervised. Respectfully submitted, MICHAEL D. RENTSCHLER,ESQUIRE 28 North 32nd Street Camp Hill, PA 17011 (717) 975-9129 Attorney for Petitioner Up n 2 2004 Karen Lynn Gault on behalf of herself and : IN THE COURT OF COMMON minor children, Kyla McKay Gault and Ashlyn : : PLEAS OF CUMBERLAND COUNTY, Jade Gault ; PENNSYLVANIA Plaintiff V. No. 04-3995 Meade Myers Buffington III Defendant CIVIL ACTION - LAW PROTECTION FROM ABUSE FINAI. ORDER OF COURT Defendant's Name: Meade Myers Buffington III Defendant's Date of Birth: April 18) 1978 Defendant's Social Security Number: 177-604064 Names and Dates of Birth of All Protected Persons, including Plaintiff and minor children: Dates of Birth Names Karen Lynn Gault 1 March 21, 1978 . 2. Kyla McKay Gault May 28, 1999 August 23, 2003 3. Ashlyn Jade Gault Plaintiff or Protected Person(s) is/are: ( ] spouse or former spouse of Defendant [X] parent of a common child with Defendant [X] current or former sexual of intimate partner with Defendant [ ] child of Plaintiff (] child of Defendant Defendant (] family member related by blood (consanguinity) to (] family member related by marriage or affinity to Defendant (] sibling (person who shares biological parenthood) of Defendant t 1 current or former cohabitant (person who lives with) Defendant. Defendant was served in accordance with Pa. R.C.P. 1930.4 and provided notice of the time, date and location of the hearing scheduled in this matter. 3pearances by Parties and/or Counsel: . Plaintiff appeared personally and is represented by: Jessica Diamondstone . Defendant appeared personally and is represented by: Elizabeth Hoffman AND NOW, this 31st Day of August, 2004 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECRL'ED as follows: Plaintiffs request for a Final Protection order is granted, after hearing upon finding abuse within the PFA Act. Plaintiffs request for a final protection order is granted. 1. Defendant shall not abuse, stalk, harass, threaten or attempt to use physical force that would reasonably be expected to cause bodily injury to the Plaintiff or any other protected person in any place where they might be found. 2. Defendant is completely evicted and excluded from the residence at: 420 Third Street West Fairview, PA 17025 or any other residence where Plaintiff or any other person protected under this Order may live. Exclusive possession of the residence is granted to Plaintiff. Defendant shall have no right or privilege to enter or be present on the premises of Plaintiff or any other person protected under this Order. 3. Except as provided in Paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT with the Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiffs school, business, or place of employment. 4. Except as provided in Paragraph 5 of this order, Defendant shall not contact the Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 5. Custody of the following minor children: 1. Ashiyn Jade Gault 2. Kyla McKay Gault shall be as follows: . Plaintiff shall have primary physical custody of the children. Defendant shall have periods of supervised visitation with the children on Wednesdays from 5:00 p.m. until 7:00 p.m., on Fridays from 5:00 p.m. until 8:00 p.m. and on alternating Sundays from 9 a.m. until 4:00 p.m. Exchanges shall take place at the Enols Municipal Building on the corner of Wertzville Road and Enola Drive. The parties shall give each other a fifteen (15) minute grace period from the scheduled exchange times to allow for lateness. Defendant's periods of supervised visitation shall take place at his mother's home. The viisitation schedule shall begin Wednesday, September 1, 2004 and the first Sunday visit shall begin on Sunday, September 12, 2004. 6. The following additional relief is granted as authorized by §6108 of the Act: - Defendant is prohibited from having any contact with Plaintiff's relatives and Plaintiffs children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. - Defendant shall not contact Plaintiff at her place of employment: Highmark Center Street Camp Hill, PA 17011 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: East Pennsboro Township Police Department 8. THIS ORDER SUPERSEDES: 1. ANY PRIOR PFA ORDER 2. ANY PRIOR ORDER RELATING TO CHILD CUSTODY 9. All provisions of this order shall expire on: March 3, 2006 NOTICE TO THE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE r' CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH 1S PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. §6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. §2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C §§2261-2262. IF YOU POSSESS A FIREARM OR ANY AMMUNITION WHILE THIS ORDER IS IN EFFECT, YOU MAY BE CHARGED WITH A FEDERAL OFFENSE EVEN IF THIS PENNSYLVANIA ORDER DOES NOT EXPRESSLY PROHIBIT YOU FROM POSSESSING FIREARMS OR AMMUNITION. 18 U.S.C. §922(8)(8). NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located, shall enforce this order. An arrest for violation of Paragraphs I through 5 of this order may be without warrant, based solely on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S. §6113. Subsequent to arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the protection order or during prior incidents of abuse. The Cumberland County Sheriff s Office shall maintain possession of the weapons until further order of this Court. When the defendant is placed under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff. Plaintiffs presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond set and both parties given notice of the date of the hearing. BY THE COILR' , Kevin A. Hess -!QV zd f. _ - Date 0I le 4; ` ink Q 1 uM 17 VERIFICATION 1, Michael D. Rentschler, Esquire, do hereby swear and aftinn that the statements contained in this Petition to Modify Custody Order are true and correct based upon representations made to me by my client, the Petitioner herein. I further certify that I am authorized to sign this verification. I understand that any false statement may be prosecuted under Pa CSA Section 4904 which relates to unswom falsification to authorities. Date: 4 MICHAEL D. RENT'SCHLER, ESQ. CERTIFICATE OF SERVICE I, Michael D. Rentschler, Esquire, do hereby affirm that on the date stated herein, I served a true and correct copy of the foregoing document upon the following individual, by first class mail, postage prepaid addressed to: Elizabeth A. Hoffman, Esquire 106 Walnut Street Harrisburg, PA 17101 Michael D. Rentschler, Esquire ?- 28 N. 32"d Street Camp Hill, Pennsylvania 17011 Supreme Court ID # 45836 Attorney for Petitioner W o: O cr 0 W 0 N a U Izi cy MEADE BUFFINGTON, III Plaintiff VS. KAREN GAULT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-4961 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this to- day of ^44,h 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Meade Buffington, III, and the Mother, Karen Gault, shall have shared legal custody of Kyla McKay Gault, born May 28, 1999, and Ashlyn Jade Gault, born August 23, 2003. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody of the Children. 3. Until March 31, 2006, the Father shall have partial physical custody of the Children every Friday from 5:00 p.m. until 8:00 p.m. and on alternating Sundays, beginning March 12, 2006, from 8:00 a.m. until 4:00 p.m. Beginning on March 31, 2006, the Father shall have custody of the Children on alternating weekends from Friday at 5:30 p.m. through Saturday at 5:30 p.m. and for an additional period during the interim week on the day arranged by agreement between the parties. 4. The parties shall share having custody of the Children on holidays as arranged by agreement. 5. Each party shall be entitled to have custody of the Children for up to one week each summer for vacation upon providing at least 30 days advance notice to the other party. The parent providing notice first under this provision shall be entitled to preference on his or her selection of vacation dates. 6. The parties shall participate in therapeutic family counseling with a professional selected by agreement between the parties. The purpose of the counseling shall be to assist the parties in establishing a co-parenting relationship with sufficient communication and cooperation to enable them to effectively co-parent their Children. The parties shall attend a minimum of four sessions. All costs of counseling which are not covered by insurance shall be shared equally between the parties. The parties shall select the counselor and contact the counselor's office within two weeks of the date of the custody conciliation conference in order to schedule their first counseling session. h.4 6n< RECEIVED MAR 0 9 7 r :C t't t.4 M . 7. The parties shall make arrangements for their Daughter, Kyla, to participate in counseling with a professional to be selected by agreement between the parties. The purpose of the counseling shall be to facilitate the Child's adjustment to the custodial arrangements and to address any issues of concern with regard to the Child's emotional well being. The parties shall select the Child's counselor and contact the counselor's office within two weeks of the date of the custody conciliation conference to schedule the Child's initial session. Any costs ofcounscling which are not covered by insurance shall be shared equally between the parties. g. Each parent shall provide the other parent with information, including address and telephone number, concerning non-liunily third party caregivers for the Children. 9. Each parent shall ensure that the other parent has his or her current address and telephone number. 10. Unless otherwise agreed between the parties, all exchanges of custody shall take place at the McDonald's in Camp [fill. 11. This Order is enteral pursuant to an agreenncnt 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 terns ol'this Order shall control. BY THE COURT, -?? xl??- cvin A. Hess J. M/lizabeth A. Iloffman, Esquire - Counsel for Rather ,,Achacl D. Rentschler, Esquire - Counsel for Mother O? MEADE BUFFINGTON, III Plaintiff VS. KAREN GAULT Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-4961 CIVIL ACTION LAW 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: follows: 1. The pertinent information concerning the Children who are the subjects of this litigation is as NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyla McKay Gault May 28, 1999 Mother Ashlyn Jade Gault August 23, 2003 Mother 2. A custody conciliation conference was held on March 7, 2006, with the following individuals in attendance: The Father, Meade Buffington, III, with his counsel, Elizabeth A. Hoffman, Esquire, and the Mother, Karen Gault, with her counsel, Michael D. Rentschler, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator All NO, 1999 /-/961 3ti?Ttin?+on vs, C6??OlQ,.1-f Y';Ir,1c{S ?jlls?,t- D,? - D( -66 60 -01+ ((.)-S -1001/ fU a e Ao-" SCOLA n ed, MEADE BUFFINGTON, 111 Plaintiff/Respondent Vs. KAREN GAULT, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4961 CIVIL TERM PETTITION TO MODIFY CUSTODY ORDER AND NOW, this day of February 2006, comes Karen Gault, by and through her attorney Michael D. Rentschler, Esquire, who files the within Petition seeking a modification of the existing custody order, by respectfully averring as follows: 1. The Petitioner is Karen Gault, an adult individual who is currently residing at an undisclosed address in Cumberland County, Pennsylvania 17062 (hereinafter referred to as "Petitioner"). Petitioner resides at that address with her Children Kyla McKay Gault and Ashlyn Jade Gault, 2. Respondent Meade Buffington, III (hereinafter referred to as "Respondent) is an adult individual who is currently resides at 408 West Dauphin Street, Enola, Cumberland County, Pennsylvania 17025. 3. The subject children in this matter are Kyla McKay Gault, who was born on May 28, 1999 and Ashlyn Jade Gault, who was born on August 23, 2003 (hereinafter referred to as "the children"). 4. The relationship of Petitioner to the children is that of the natural mother. 5. The relationship of Respondent to the children is that of natural father. 6. On of about September 2, 2004 a final order of protection was entered against Respondent in Cumberland County, at docket number 04-3995. A true and correct copy of that Protective Order is incorporated herein, made a part hereof and attached as Exhibit "A". 7. Exhibit A provides Plaintiff (Petitioner herein) with primary physical custody of the children and Defendant (respondent herein) was granted periods of supervised visitation the children on Wednesdays from 5:00 pm until 7:00 pm, on Fridays from 5:00 pm until 8:00 pm and on alternating Sundays from 9:00 am until 4:00 pm. The exchanges were ordered to take place at the Enola Municipal Building, in Enola. It was further ordered that the visitation for Defendant (Respondent) be at his mother's house. Respondent subsequently gave up the Wednesday visitation. 8. The Protective Order is scheduled to expire on March 3, 2006, and Petitioner is still fearful of Respondent. 9. On or about October 1, 1999, an Order of Court granted Defendant (Petitioner herein) with primary physical custody of Kyla McKay Gault. 10. The current order for custody provides Petitioner with primary physical and joint legal custody of one child, namely Kyla McKay Gault. However, since that order was in effect, the parties have another child together, being Ashlyn Jade Gault, who was born on August 23, 2003. 11. Since Ashlyn's birth, she has resided with Mother from birth to October 2003; with Mother and Father from October 2003 to December 2003; and with Mother from December 2003 to present. 12. It is in the best interest and permanent welfare of the children that Petitioner is granted primary physical custody and joint legal custody of the children and that visitation with the children by Respondent be supervised. This is based upon the fact that Mother can provide a stable and loving environment with the children; she has been the primary caregiver of the children; there are past incidents of abuse and threatened abuse of the children by Father; and that Father pled guilty to recklessly endangering another person with the victims being the Petitioner and the two children. 13. There is no rational basis for denying Petitioner's request. WHEREFORE, it is respectfully requested that this Honorable Court grant the within Petition and, therefore, grant Petitioner majority physical custody and joint legal custody of the Children and that visitation with the Children by the father, be supervised. Respectfully submitted, MICHAEL D. RENTSCHLER, ESQUIRE 28 North 32"d Street Camp Hill, PA 17011 (717) 975-9129 Attorney for Petitioner UP n 2 2nnA Karen Lynn Gault on behalf of herself and : IN THE COURT OF COMMON minor children, Kyla McKay Gault and Asblyn : PLEAS OF Jade Gault : CUMBERLAND COUNTY, :PENNSYLVANIA Plaintiff V. No. 04-3995 Meade Myers Buffington III CIVIL ACTION - LAW PROTECTION FROM ABUSE Defendant FINAL ORDER OF COURT Defendant's Name: Meade Myers Buffington III Defendant's Date of Birth: April 18, 1978 Defendant's Social Security Number: 177-60-4064 Names and Dates of Birth of All Protected Persons, including Plaintiff and minor children: Names Dates of Birth 1. Karen Lynn Gault March 21,1978 2. Kyla McKay Gault May 28,1999 3. Ashlyn Jade Gault August 23, 2003 Plaintiff or Protected Person(s) is/are: [ ] spouse or former spouse of Defendant [X] parent of a common child with Defendant [X] current or former sexual or intimate partner with Defendant [ j child of Plaintiff [ ] child of Defendant [ ] family member related by blood (consanguinity) to Defendant [ ] family member related by marriage or affinity to Defendant [ ] sibling (person who shares biological parenthood) of Defendant ( ] current or former cohabitant (person who lives with) Defendant. Defendant was served in accordance with Pa. R.C.P. 1930.4 and provided notice of the time, date and location of the hearing scheduled in this matter. Appearances by Parties and/or Counsel: . Plaintiff appeared personally and is represented by: Jessica Diamondstone • Defendant appeared personally and is represented by: Elizabeth Hoffman AND NOW, this 31st Day of August, 2004 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Plaintiffs request for a Final Protection Order is granted, after hearing upon finding abuse within the PFA Act. Plaintiffs request for a final protection order is granted. 1. Defendant shall not abuse, stalk, harass, threaten or attempt to use physical force that would reasonably be expected to cause bodily injury to the Plaintiff or any other protected person in any place where they might be found. 2. Defendant is completely evicted and excluded from the residence at: 420 Third Street West Fairview, PA 17025 or any other residence where Plaintiff or any other person protected under this Order may live. Exclusive possession of the residence is granted to Plaintiff. Defendant shall have no right or privilege to enter or be present on the premises of Plaintiff or any other person protected under this Order. 3. Except as provided in Paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT with the Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiffs school, business, or place of employment. 4. Except as provided in Paragraph 5 of this Order, Defendant shall not contact the Plaintiff. or any other person protected under this Order, by telephone or by any other means, including through third persons. 5. Custody of the following minor children: 1. Ashlyn Jade Gault 2. Kyla McKay Gault shall be as follows: . Plaintiff shall have primary physical custody of the children. Defendant shall have periods of supervised visitation with the children on Wednesdays from 5:00 p.m. until 7:00 p.m., on Fridays from 5:00 p.m. until 5:00 p.m. and on alternating Sundays from 9 a.m. until 4:00 p.m. Exchanges shall take place at the Enola Municipal Building on the corner of Wertzville Road and Enola Drive. The parties shall give each other a fifteen (15) minute grace period from the scheduled exchange times to allow for lateness. Defendant's periods of supervised visitation shall take place at his mother's home. The visitation schedule shall begin Wednesday, September 1, 2004 and the first Sunday visit shall begin on Sunday, September 12, 2004. 6. The following additional relief is granted as authorized by §6108 of the Act: - Defendant is prohibited from having any contact with Plaintiffs relatives and Plaintiffs children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. - Defendant shall not contact Plaintiff at her place of employment: Highmark Center Street Camp Hill, PA 17011 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: East Pennsboro Township Police Department 8. THIS ORDER SUPERSEDES: 1. ANY PRIOR PFA ORDER 2. ANY PRIOR ORDER RELATING TO CHILD CUSTODY 9. All provisions of this order shall expire on: March 3, 2006 NOTICE TO THE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH 1S PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. §6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. §2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. I8 U.S.C §§2261-2262. IF YOU POSSESS A FIREARM OR ANY AMMUNITION WHILE THIS ORDER IS IN EFFECT, YOU MAY BE CHARGED WITH A FEDERAL OFFENSE EVEN IF THIS PENNSYLVANIA ORDER DOES NOT EXPRESSLY PROHIBIT YOU FROM POSSESSING FIREARMS OR AMMUNITION. 18 U.S.C. §922(g)(8). NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located, shall enforce this order. An arrest for violation of Paragraphs 1 through 5 of this order may be without warrant, based solely on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S. §6113. Subsequent to arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the protection order or during prior incidents of abuse. The Cumberland County Sheriff's Office shall maintain possession of the weapons until further order of this Court. When the defendant is placed under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff. Plaintiffs presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond set and both parties given notice of the date of the hearing. "a 'dll ve n e ? O?(ncn??.iTG' n ?3 BY THE COURT: Kevin A. Hess Date VERIFICATION 1, Michael D. Rentschler, Esquire, do hereby swear and affirm that the statements contained in this Petition to Modify Custody Order are true and correct based upon representations made to me by my client, the Petitioner herein. I further certify that I am authorized to sign this verification. I understand that any false statement may be prosecuted under Pa CSA Section 4904 which relates to unsworn falsification to authorities. Date: MICHAEL D. RENTSCHLER, ESQ CERTIFICATE OF SERVICE I, Michael D. Rentschler, Esquire, do hereby affirm that on the date stated herein, I served a true and correct copy of the foregoing document upon the following individual, by first class mail, postage prepaid addressed to: Elizabeth A. Hoffman, Esquire 106 Walnut Street Harrisburg, PA 17101 Michael D. Rentschler, Esquire 28 N. 32' Street Camp Hill, Pennsylvania 17011 Supreme Court ID # 45836 Attorney for Petitioner "? ? O '?- ,, ?.. ? 1 [? q ? 1 ((^'^' lid n c ? ?. ?.. '->., ?^ ? .? ? , ?? n t m ? ,> ,' _? s J^ ?` ?? r, MEADE BUFFINGTON, III IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KAREN GAULT DEFENDANT 99-4961 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, February 09, 2006 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, PA 17055 on Wednesday, March 01, 2006 _ at 10:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order, The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ _ Dawn S. Sunday, Esq_ _ `1 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 FIELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 fk -tZ,;71 Z V' w, -° MEADE BUFFINGTON, III Plaintiff VS. KAREN GAULT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-4961 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this to- day of /tip , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Meade Buffington, III, and the Mother, Karen Gault, shall have shared legal custody of Kyla McKay Gault, born May 28, 1999, and Ashlyn Jade Gault, born August 23, 2003. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody of the Children. 3. Until March 31, 2006, the Father shall have partial physical custody of the Children every Friday from 5:00 p.m. until 8:00 p.m. and on alternating Sundays, beginning March 12, 2006, from 8:00 a.m. until 4:00 p.m. Beginning on March 31, 2006, the Father shall have custody of the Children on alternating weekends from Friday at 5:30 p.m. through Saturday at 5:30 p.m. and for an additional period during the interim week on the day arranged by agreement between the parties. 4. The parties shall share having custody of the Children on holidays as arranged by agreement. 5. Each party shall be entitled to have custody of the Children for up to one week each summer for vacation upon providing at least 30 days advance notice to the other party. The parent providing notice first under this provision shall be entitled to preference on his or her selection of vacation dates. 6. The parties shall participate in therapeutic family counseling with a professional selected by agreement between the parties. The purpose of the counseling shall be to assist the parties in establishing a co-parenting relationship with sufficient communication and cooperation to enable them to effectively co-parent their Children. The parties shall attend a minimum of four sessions. All costs of counseling which are not covered by insurance shall be shared equally between the parties. The parties shall select the counselor and contact the counselor's office within two weeks of the date of the custody conciliation conference in order to schedule their first counseling session. R-_C_iVED M° 0 0 vi ,.,, ? ,, 7. The parties shall make arrangements for their Daughter, Kyla, to participate in counseling with a professional to be selected by agreement between the parties. The purpose of the counseling shall be to facilitate the Child's adjustment to the custodial arrangements and to address any issues of concern with regard to the Child's emotional well being. The parties shall select the Child's counselor and contact the counselor's office within two weeks of the date of the custody conciliation conference to schedule the Child's initial session. Any costs of counseling which are not covered by insurance shall be shared equally between the parties. 8. Each parent shall provide the other parent with information, including address and telephone number, concerning non-family third party caregivers for the Children. 9. Each parent shall ensure that the other parent has his or her current address and telephone number. 10. Unless otherwise agreed between the parties, all exchanges of custody shall take place at the McDonald's in Camp Hill. 11. 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, A/ A. Hess J. cc: /lizabeth A, Hoffman, Esquire - Counsel for Father ,olichael D. Rentschler, Esquire - Counsel for Mother IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEADE BUFFINGTON, III Plaintiff 99-4961 CIVIL ACTION LAW vs. KAREN GAULT IN CUSTODY Defendant 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: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyla McKay Gault May 28, 1999 Ashlyn Jade Gault August 23, 2003 Mother Mother 2. A custody conciliation conference was held on March 7, 2006, with the following individuals in attendance: The Father, Meade Buffington, III, with his counsel, Elizabeth A. Hoffman, Esquire, and the Mother, Karen Gault, with her counsel, Michael D. Rentschler, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator