Loading...
HomeMy WebLinkAbout99-05755?}q>r 7?.' , t, jj1f I sib>. ti y?FF r,l2,?Y ? J Y ! ` F$ . I el c,?r ?x.E s yn , , -144 { 191, dh r u YIP ( ` F{tf ? i? Y ?. kp y pFff L R Y?q Ma tR ,F tY rP wa 5 M1 y G lA, ] ,I I it f ' i? !f. r ]? f Rai yy, sr ,. r 6'. ti T p? y; Y. 7r r t?;r< :YCI 4 a t is r, at c?'4 i. n! r i% I r^q GERALD K. BUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,FENNSYLVANIA V. CIVIL ACTION - LAW DEBORAH HADLEY-BUSH, NO. qQ- TISS CIVIL Defendant IN CUSTODY ORDER OF COURT AND NOW, this @'8 day of Lfy%bec _, 1999, upon consideration of the attached Custody Compla', it is hereby directed that the parties and their respective counsel shall appear before the Conciliator, at3q \.l Nn%rn S t C ?rS N_ nthe _ day of ocATJl Cr 1999 at O o'clocIp. m., or a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five or older may also be present at the Conference. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, BY: s Custody Conciliator f r0 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 OF r ????FD,.OfFlu 9g SI p 29 411 r; ?. 8 YLV/IIV,M 90.99 ? ? ?ei ti 9•x9.99 ?o, ?"? ? GERALD K. BUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. CIIVEL ACTION - LAW DEBORAH H&DLEY-BUSH, : NO. 99- 97,55 CIVIL Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the plaintiff; Gerald K Bush, by and through his attorney, Jacqueline M. Verney, Esquire and represents the following: 1. The Plaintiff is Gerald K Bush, residing at 4 Hunter Lane, Camp Hill, Cumberland County, Pennsylvania, 17013. 2. The Defendant is Deborah Hadley-Bush, residing at 4173 Grouse Court, #102, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff seeks custody of the following children: NAME PRESENT ADDRESS AGE Jeremy M. Bush 4 Hunter Lane DOB 3/22/83 Camp Hill, PA 17011 Kyle A. Bush same as above, and 4173 Grouse Ct. DOB 5/24/94 Mechanicsburg, PA 17055 The children were not born out of wedlock. The children are presently in the custody of the plaintiff, Gerald K. Bush, who resides at 4 Hunter Lane, Camp Hill, PA 17011, although defendant insists that Kyle A. Bush alternate weeks with the parents. During the past five years, the children have resided with the following persons and at the following addresses: S Ai L PERSONS AMMSM DATES Gerald K. Bush, 380 East Avenue 1993-Dec. 1999 Deborah Hadley-Bush Lockport, MY 14094 Gerald K. Bush 4 Hunter Lane Jan. 1999-present Deborah Hadley-Bush Camp Hill, PA 17011 The mother of the children is Deborah Hadley-Bush currently residing at 4173 Grouse Court, #102, Mechanicsburg, Pa 17055. She is married. The father of the children is Gerald K. Bush currently residing at 4 Hunter Lane, Camp Hill, Pennsylvania. He is married. 4. The relationship of Plaintiff to the child is father. The Plaintiff currently resides with the following persons: NAME RELATIONS Jeremy M. Bush son Kyle A. Bush son 5. The relationship of Defendant to the child is mother. The Defendant currently resides with the following persons: NAME RELATIONSIR Kyle A. Bush (alternating weeks only) son 6. Plaintiff has not participated as a party or witness, or in another capacity, in other S r litigation concerning the custody of the minor children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Mother moved from the family residence on September 4, 1999. Immediately prior to the move, Mother's behavior became erratic and irrational. She has become secretive and deceitful, lying to her older son and to Plaintiff. Father is concerned that Mother is considering an alternative lifestyle, is unstable and unable to properly supervise and care for the children. b. Father can provide a stable, nurturing, loving environment for the children. Jeremy has indicated a preference to live with his Father. The siblings have a close relationship and should not be separated. c. Father is willing to cooperate with Mother to arrange liberal partial physical custody. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: NONE. WHEREFORE, Plaintiff requests this court to grant shared legal and primary physical custody of the children to Plaintiff. Respectfully submitted, Date: 9112619y gh. /4 line M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Supreme Ct. ID 23167 Attorney for Plaintiff VERIFICATION I verify that the statements made in the within Complaint are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S.A. § 4904 relating to unworn falsification to authorities. Dated: 2/ a o? K Bush •-a F O o ?C+- 4 o N w ft A L r• O N ? 1 F ? GERALD K BUSH, Plaintiff V. DEBORAH HADLEY-BUSH, Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5755 CIVIL : IN CUSTODY Please enter the appearance of LUTHER E. MILSPAW, JR., Esquire, as counsel for Defendant in the above captioned matter. Dated: I BY: Respectfully submitted, MILSPA* & BESHORE Luther E. MIlspaw,?Jr., Esquire 130 State Street P.O. Box 946 Harrisburg, PA 17108 (717) 236-0781 Supreme Court ID 19226 Attorney for Defendant GERALD IC. BUSH, V. Plaintiff DEBORAH HADLEY-BUSH, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 99-5755 CIVIL IN CUSTODY AND NOW, this 30th day of September, 1999, I, Elizabeth M. Gable, Legal Assistant to Luther E. Milspaw, Jr., Esquire, do hereby certify that I this day served the foregoing Entry of Appearance, by depositing the same in the U.S. mail, postage pre-paid, at Harrisburg, Pennsylvania addressed as follows: Jacqueline M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 MILSPAW & BESHORE Dated: 1,?qq9 By: Elizabeth M. Gable Legal Assistant to Luther E. Milspaw, Jr. (mil LO cli w v-, U 0 W n Ix Q m n U) 3 W m > W < N m N m W W% Z N 0 W W Q z a n 3 a U! O 7 W a s 0 a o V)¢- m a J_ ¢ E a 2 rw'wuY•AOCaiw• •luu•. zsiu g111Y01 W ALMA I1Y19' 1 GERALD K. BUSH, Plaintiff VS. DEBORAH HADLEY-BUSH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5755 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AMID NOW, this /4 day of , 1999, upon consideration of the attached Custody Concil anon Pe rt, t is ordered and directed as follows: 1. The Father, Gerald K. Bush, and the Mother, Deborah Hadley-Bush, shall have shared legal custody of Jeremy M. Bush, born March 22, 1983, and Kyle A. Bush, born May 24, 1994. The parties shall jointly make, after discussion and consultation with each other, all major decisions affecting the Children's growth and development including, but not limited to, choice of day care provider, medical and dental treatment. psychotherapy, psychoanalysis or like treatment, decisions relating to actual or potential litigation involving the children (directly or as beneficiary, other than custody litigation), education (both secular and religious), choice of camp, athletic pursuits and extracurricular activities. 2. The Father shall have primary physical custody of Jeremy. The Mother shall have partial physical custody of Jeremy as arranged by agreement between the parties and Jeremy. 3. The parties shall share having physical custody of Kyle on an alternating weekly basis with the exchange of custody to take place each week on Monday afternoon at the close of school. However, the parties agree to modify the alternating weekly schedule so that the rather shall have custody of Kyle from November It 1999 through November 10, 1999, the Mother shall have custody from November 10, 1999 through November 19, 1999, and the Father shall have custody from November 19, 1999 through November 29, 1999. Thereafter the alternating schedule shall resume. Both parents shall accommodate each other's schedules to the fullest extent possible when either work or schooling requires a parent to be out of town overnight. 4. The parties shall have custody of the Children on holidays as follows: A. CRRISIM: The Father shall have custody of the Children on Chrltmas Eve and Christmas Day in 1999. in future years, the parties shall make arrangements for custody of the Children over the Christmas holiday by agreement. B. THANKSGIVING: The Father shall have custody of the Children on Thanksg ving in 1999. The parties shall make arrangements for custody on Thanksgiving in future years by agreement. C. REMAINING HOLIDAYS: The party who has custody of Kyle under the regular custody schedule on each of the remaining holidays shall have custody of both Children over those holidays. D. MCTBBRIS DAY/FATHER'S DAY: The Mother shall have custody of the Ch ldren every year on mother's Day and the Father shall have custody of the Children every year on Father's Day. 5. Both parties shall be entitled to have custody of the Children for 3 uninterrupted weeks each year. Neither party shall have custody for more than 2 consecutive weeks (including that party's regular periods of custody) unless otherwise agreed between the parties. The parties agree that each week scheduled under this paragraph shall include 7 days. Each party shall provide the other with 30 days advance notice of his or her intention to exercise the right to an extended period of custody under this paragraph. 6. Every Tuesday evening between 9:00 p.m. and 9:30 p.m., the party who has custody of Kyle shall contact the other party for the purpose of discussing issues regarding the children only. 7. Each parent shall be entitled to have reasonable telephone contact with the Children when they are in the custody of the other parent. S. The party receiving custody of the Child or children shall be responsible to provide transportation for the exchange of custody. 9. In the event either party intends to relocate his or her residence beyond a 50 mile radius or in the event the relocation would necessitate a change in the custody schedule, that party shall provide a minimun of 60 days advance notice to the other party. The purpose of this provision is to afford the parties an opportunity to renegotiate the custodial arrangements or to have the matter resolved through the legal process if necessary. 10. Both parties shall refrain from making derogatory comments about the other party in the presence or hearing of the Children and, to the extent possible, shall prevent third parties from making such comments in the presence or hearing of the Children whether the Children are awake or asleep. 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, I /-.3 - 97 RL,?C cc: Jacqueline M. Verney, Esquire - Counsel for Mother Luther E. Milspaw, Jr., Esquire - Counsel for Father GERALD K. BUSH, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99-5755 CIVIL TERM DEBORAH HADLEY-BUSH, : CIVIL ACTION - LAW Defendant IN CUSTODY CUSTODY CONCILIATION 5U!l9ARY RBPCRT IN ACCORDANCE WITH CM*WRLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-81 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 CUMMY OF Jeremy M. Bush March 22, 1983 Father Kyle A. Bush May 24, 1994 Father/Mother 2. A Conciliation Conference was held on October 26, 1999, with the following individuals in attendance: The Father, Gerald K. Bush, with his counsel, Jacqueline M. Verney, Esquire, and the Mother, Deborah Hadley-Bush, with her counsel, Luther E. Milspaw, Jr., Esquire. 3. The parties agreed to entry of an Order in the form as attached. /'cApm . ?9g 9 D?61 ?-abt-i ate Dawn S. Sunday, Esquire Custody Conciliator tir 'iC... ?f .:gin OCT 2 9 looo QI N w 1 w sj Sb a 44 1 4 4 x 7-1 A GERALD K. BUSH IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. DEBORAH HADLEY-BUSH DEFENDANT 99-5755 CIVIL ACTION LAW IN CUSTODY AND NOW, this 3rd day of August , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on the 22nd day of August , 2000, at 3:00 p.m. for a Pre-Hearing Custody Conference. At such conference, an eftbrt will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By, Is/ Dawn S, Sunday. Esq\ Custody Conciliator ,N Custody Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 A ED-O CE OF TL:' ^r7IL.ICNOTARY 00 AIJG -1 PM 2: 5 CUMUERLAND COUN Y PENNSYLVANIA GERALD K. BUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW DEBORAH HADLEY-BUSH, : NO. 99-5755 Defendant : IN CUSTODY AND NOW, this consideration of the attar directed that the parties day of Conference. At such or if this cannot be ac Court, and to enter irk present at the Confer entry of a temporary, ?ush tC? ?S h 2000, upon r, it is hereby re ;onciliator, at fearing Custody ne issues in dispute; be heard by the r older may also be ?ibl- (Wp,i provide grounds for FOR?'t•e-rte .,.?,?:.,.._, BY: Custody Conciliator 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 GERALD K. BUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DEBORAH HADLEY-BUSH, NO. 99-5755 Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of 2000, upon consideration of the attached Petition for Modification of Custody Order, it is hereby directed that the parties and their respective counsel shall appear before , the Conciliator, at on the day of 2000 at o'clock . in., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five or older may also be present at the Conference. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, BY: Custody Conciliator 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 GERALD K. BUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY,PENNSYLVANIA V. CIVIL ACTION -LAW DEBORAH HADLEY-BUSH, NO. 99-5755 CIVIL TERM Defendant/Respondent IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes Petitioner, Gerald K. Bush, by and through his attorney, Jacqueline M. Verney, Esquire and respectfully represents the following 1. The Petitioner is Gerald K. Bush, whose address is 4 Hunter Lane, Camp Hill, Cumberland County, PA 17011. 2. The Respondent is Deborah Hadley-Bush, who resides at 4173 Grouse Court, Apartment 102, Mechanicsburg, Cumberland County, Pennsylvania, 17 055. 3. An Order of Court was entered on November 3, 1999 for legal and physical custody of Jeremy M. Bush, DOB 3/22/83; and Kyle A. Bush, DOB 5/24/94, a true and correct copy of which is attached hereto as Exhibit "A". 4. The Order provides for the parties to share legal custody of Kyle. A dispute has arisen between the parties concerning which school the child should attend for the 2000-2001 school year. 5. The child, for kindergarten, attended a private school in Harrisburg, St. Stephen's. Petitioner believes that Kyle should attend first grade in the East Pennsboro School District, said school being one mile from where both parties work. Petitioner lives in r It r ?d k the East Pennsboro School District; Respondent lives in Cumberland Valley School District. Respondent believes the child should continue to attend St, Stephen's. 6. Petitioner requests the Order be changed to provide for Kyle to attend East Pennsboro Schools.. WHEREFORE, Petitioner requests that the Court modify the existing Order for Custody because it will be in the best interest of the child. Respectfully submitted: Date: -?6 -o acq line .M. Verney, Supreme Ct. ID 23167 44 South Hanover Street Carlisle, PA 17013 Attorney for Petitioner VERIFICATION I verify that the statements made in the within Petition are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S.A. § 4904 relating to unswom falsification to authorities. Dated: '7/Z 5/00 e d K M Fa ='w r, 4 1? L?hg M>A ' EXHIBIT A '` . GERALD R. BUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND C LINTY, PQ,NMVANIA va. No. 99-5755 CIVIL TERM DRBCRAH HADLEY-BUSH# CIVIL ACTION - LAW Defendant : IN CUSTODY CIMM OF COURT AND NOW, this 3 rd day of . 19991 consideration of the attached Custody Conc and directed as follows: Iliation Report, it is ordered 1. The Father, Gerald R. Bush, and the Mother, Deborah Hadley-Sushi shall have shared legal custody of Jeremy M. Bush, born March 22, 1983, and Kyle A. Bush, born May 24, 1994. The parties shall jointly make, after discussion and consultation with each other, all major decisions affecting the Children's growth and development including, but not limited to, choice of day care provider, medical and dental treatment, psychotherapy, psychoanalysis or like treatment, decisions relating to actual cc potential litigation involving the Children (directly or as beneficiary, other than- custody litigation), education (both secular and religious), choice of camp, athletic pursuits and extracurricular activities. 2. The Father shall have primary physical custody of Jeremy. The Mother shall have partial physical custody of Jeremy as arranged by agreement between the parties and Jeremy. 3. The parties shall share having physical custody of Kyle on an alternating weekly basis with the exchange of custody to take place each week on Monday afternoon at the close of school. However, the Parties M?F?tody alternating weekly schedule so that the Father shall from November 1, 1999 through November 10, 1999, the from November 101 1999 through November 19, 19991 and the rather stall have custody from November 19, 1999 through November 29, 1999. Thereafter the alternating schedule shall resume. Both parents shall accommodate each other's schedules to the fullest extent possible when either work or schooling requires a parent to be out of town overnight. ' 4. The parties shall have custody of the Children on holidays as follows: A. CBRI8MM: The Father shall have custody of the children on tms rc?? Eve and Christmas Day in 1999. in future years, the parties shall make arrangements for custody of the Children over the Christmas holiday by agreement. B. TeANIOGiVING: The Father shall have custody of the Children on Thanksgiving in 1999. The parties shall make arrangements for custody on Thanksgiving in future years by agreement. C. REMkINM7G BOLMNM: The party who has custody of Kyle under the regular custody schedule on each of the remaining holidays shall have custody of both children over those holidays. D. 'IM h]AY/FAT?t'S DAY: The Mother shall have custody of en every year on Mother's Day and the rather shall have custody of the Children every year an Father's Day. 5. Both parties shall be entitled to have custody of the Children for 3 uninterrupted weeks each year. Neither party shall have custody for more than 2 consecutive weeks (including. that party's regular periods of custody) unless otherwise agreed between the parties. The parties agree that each week scheduled under' this paragraph shall include 7 days. Each party shall provide the other with 30 days advance notice of his or her intention to exercise the right to an extended period of custody under this paragraph. 6. Every Tuesday evening between 9:00 p.m. and 9:30 p.m., the party who has custody of Kyle shall contact the other peaty for the purpose of discussing issues regarding the Children only. 7. Each parent shall be entitled to have reasonable telephone contact with the Children when they are in the custody of the other parent. B. The party receiving custody of the Gild or Children shall be responsible to provide transportation for the exchange of custody. 9. In the event either party intends to relocate his or her residence beyond a 50 mile radius or in the event the relocation would necessitate a change in the custody schedule, that party shall provide a minimum of 60 days advance notice to the other party. The purpose of this provision is to afford the parties an opportunity to renegotiate the custodial arrangements or to have the matter resolved through the legal process if necessary. 10. Both parties shall refrain from making derogatory comments about the other party in the presence or hearing of the Children and, to the extent possible, shall prevent third parties from making such comments in the presence or hearing of the Children whether the Children are awake or asleep. 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 Oster shall control. 84 Tim COURT, J. cc: Jacqueline M. Verney, Esquire - counsel for Mother Luther E. Milspaw, Jr., Esquire - counsel for Father TRUE COPY in Tegamony Ir'T I RECOPID ? ?iaM sal mppY??? I (;Utiis? O? ? '1 GERALD K. BUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND CCUNPY, PENNSYLVANIA va. NO. 99-5755 CIVIL TERM DEBORAH HADLEH-BUSH, CIVIL ACTION - LAW Defendant IN CUSTODY CUSTODY CONCILIATION SU MlAW RBPCRT IN ACOMMANCB W= CQ1BERLRND CIODNTT RULE OF CIVII. PROCIDW 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. ibe pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH C[ LY IN CDSTODr Or Jeremy M. Bush March 22, 1983 Father Kyle A. Bush May 241 1994 Father/Mother 2. A Conciliation Conference was held on October 26, 19991 with the following individuals in attendance: The Father, Gerald K. Bush, with his counsel, Jacqueline M. Verney, Esquire, and the Mother, Deborah Hadley-Bush, with her counsel, Luther E. Milspaw, Jr., Esquire. 3. The parties agreed to entry of an Order in the form as attached. /0-11y' x.1949 ata'4 Date Dawn S. sun y, Esquire Custody Conciliator L: ..; LAW OFFICE OF Jacqueline M. Verney 44 S. HANOVER ST. • CARLISLE, PA 17013 • (717) 743-9190 • FAX (717) 243.3518 JUL 2 7 2000 SEP 5 21 GERALD K. BUSH, : IN THE COURT OF OOMMCN PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-5755 CIVIL TERM CIVIL ACTION - LAW DEBORAH HADLEY-BUSH, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 22nd day of August, 2000, the Conciliator, being advised by counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for August 22, 2000 is canceled. FOR THE COURT, aDawn S. Sunday, Esquire(j Custody Conciliator Cl) F; J L' . I 1 - l•- iG V':