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LISA M. SNYER, : IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V.
JAMIE LEE HENDRICKS,
DEFENDANT : 99-6154 CIVIL TERM
ORDER OF COURT
AND NOW, this Tl+h day of October, 1999, a hearing on the
plaintiffs petition for special relief shall be conducted in Courtroom Number 2,
Cumberland County Courthouse, Carlisle, Pennsylvania at 8:45 a.m., Friday, October
15, 1999. The father shall have Taylor M. Hendricks, born February 9, 1995, present at
the hearing.
By the Court,
Edgar B. Bayley"
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LISA M. SNYDER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO.99-615q CIVIL TERM
JAMIE LEE HENDRICKS. :CUSTODY
Defendant
AND NOW, this _ day of October, 1999, upon consideration of the attached Petition
for Special Relief filed on behalf of the Plaintiff, Lisa M. Snyder, the following Temporary
Custody Order is entered regarding Taylor M. Hendricks. DOB 2/9/95.
1) Plaintiff, Lisa M. Snyder, hercinafter referred to as the mother, shall have primary
physical custody and legal custody of the child.
2) Defendant, Jamie Lee Hendricks, hereinafter referred to as the father, shall have
supervised visitation with the child at times agreed upon by the mother and father.
3) The father shall immediately return the child to the custody of the mother.
4) The police and other appropriate law enforcement agencies shall facilitate the transfer
of custody to the mother.
5) The father shall not remove the child from Cumberland County and this court's
jurisdiction.
This Temporary Custody Order shall remain in effect pending further Order of the Court
after the Conciliation Conference.
This Order is entered without prejudice to either party to request a hearing.
This Order shall be docketed in the office of the Prothonotary, but the Prothonotary shall
not send a copy of this Order to Defendant by mail.
By the Court,
J.
Joan Carey,
Legal Services, Inc.
g Irvine Row
Carlisle, PA 17013
(717) 243-9400
Attorney for Plaintiff
LISA M. SNYDER,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
VS.
JAMIE LEE HENDRICKS,
Defendant
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- 4/5"1 CIVIL TERM
:CUSTODY
The plaintiff/petitioner, Lisa M. Snyder, by and through her attorney, Joan Carey of Legal
Services, Inc., represents the following:
1. The plaintiff/petitioner, Lisa M. Snyder, hereinafter referred to as the mother, resides
at 6 Links Mobile Home Park, Lot 63, Mechanicsburg, Pennsylvania 17055.
2. The defendant, Jamie Lee Hendricks, hereinafter referred to as the father, resides at
145 Richard Riggs Road, Swansboro, North Carolina, Onslow County.
3. The parties are the parents of Taylor M. Hendricks, bom 2/9/95, hereinafter referred to
as the child.
4. The mother requests an order granting her primary custody of the child for reasons
including the following:
a) The mother has been the primary caretaker of the child since her birth, and the
sole caretaker since the father moved from the residence in October 1998 and then
relocated to North Carolina in May, 1998.
b) By agreement of the mother and father, the child and her half-sister, Megan
Snyder, went to visit the father on August 14, 1999, and were to be returned to the
mother on August 27. 1999, in time for the beginning of school and daycare.
c) In or about the last week of the agreed upon visit, the father contacted the
mother saying his vehicle was broken down and that he would not be returning the
children on the scheduled date.
d) Fearing for her children's safety because a hurricane was expected to hit North
Carolina, and thinking that the father had no transportation, the mother drove to
North Carolina to pick up the children on approximately August 25, 1999. The
father refused to return the child to the mother and only let her take her older
daughter, Megan, with her.
e) The father informed the mother that he would return the child the week of
September 6, 1999, but as of the date of the filing of this petition, he has not done
so.
0 The father has denied the mother all contact, including telephone calls, since
approximately September 12, 1999, in spite of the mother's repeated attempts to
speak with the child. Prior to this, the mother had been speaking with her child
about every other day, exacerbating the mother's fear for the child's well being.
g) During the mother's last conversation with the child, her daughter was crying
and saying she wanted to come home.
h) On approximately September 16, 1999, Hurricane Floyd hit the North Carolina
coast, and the father did not evacuate the area with the child as the authorities had
advised since the eye of the hurricane was approximately 20 miles away from the
father's mobile home.
i) As a result of Hurricane Floyd, there was severe flooding and contamination
problems in the area of the father's mobile home, and he informed the mother that
he could not bring the child home and did not know when he would return the
child.
j) The father's residence has no running water or operational bathroom which
causes the mother concern for the child's well being.
k) On several occasions, the father has told the mother that he would flee with the
child, saying that he has relatives living all over the country. The mother's fear
that he will do this is exacerbated since his mother, with whom he currently
resides, fled with him and his siblings when they were young, resulting in their
fathers being denied all contact with them.
I) The father attempted suicided in May 1999, after the parties had separated.
m) On approximately September 21, 1999?the mother contacted the father and
told him she was coming to pick up the child and the father said, "Don't bother;
I'm not giving her back." \
5. The father has not acted in the best interest of the child by denying the mother physical
contact with the child since approximately August 25, 1999, and telephone contact since
approximately September 12, 1999, and by keeping the child separate from her siblings with
to
whom she has been raised.
6. The mother is the parent who can best provide for the child; she has the child enrolled
in daycare, and the Childcare Network is currently holding a place for the child in their
subsidized program.
7. Without this court granting the mother Temporary Custody, the mother will suffer
irreparable harm since, without a custody order, no law enforcement agencies will assist her
mother in regaining custody of her child, whom she feels is in danger in the father's custody.
WHEREFORE, the plaintiff requests that this court enter a Temporary Order granting her
primary physical and legal custody of the child, ordering that the father not take the child from
the jurisdiction of Cumberland County, and ordering the police or other law enforcement
officials to facilitate the transfer of custody to the mother.
The plaintiff further asks that the Court schedule a Conciliation Conference regarding the
matter of long term custody.
Additionally, the Plaintiff requests any other relief which is just and proper.
Respectfully submitted,
Joan Carey
Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
The above-named Plaintiff, Lisa M. Snyder, verifies that the statements
made In the above Petition are true and correct. Plaintiff understands that false
statements herein are made subject to the penalties of 18 Pa. C.S. §4904,
relating to unsworn falsification to authorities.
S(3o1??
Date:
Lisa M. Snyder, Plaints
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LISA M. SNYDER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
JAMIE LEE HENDRICKS,
Defendant
NO.99-615q CIVILTERM
: CUSTODY
AND NOW, upon consideration of the attached com laint, it is hereby directed that the
panics and their r ?et?ocRS set appear before nfl, ttlcacl'T, V?
the conciliator, at on the 11 day of Q tJ , 1999, at J?¢.m., for
a Pre-Hearing Custody Confer nce. 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. Failure to appear at the conference may provide grounds for
entry of a temporary or permanent order.
By the Court,
IU11-319cy cV:z t.t(k ?\ Ai mAn , 4
Date Custody Conciliator [lJ ?1
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 OR (800) 990-9108
SABIL
The Court of Common Plcas 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.
99 rr7 I F:1 z: F, 3
-43
10-13-9,P
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LISA M. SNYDER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
Vs. : NO. 99- CIVIL TERM
JAMIE LEE HENDRICKS, :CUSTODY
Defendant
1. The plaintiff is Lisa M. Snyder, residing at 6 Links Mobile Home Park,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The defendant is Jamie Lee Hendricks, residing at 145 Richard Riggs Road,
Swansboro, Onslow County, North Carolina.
3. The plaintiff seeks custody of the following child:
Name Present Residence Age
Taylor M. Hendricks 145 Richard Riggs Road 4
Swansboro, NC
The child was born out of wedlock.
The child is presently in the custody of Jamie Lee Hendricks, who resides at 145 Richard
Riggs Road, Swansboro, North Carolina.
During the child's lifetime, she has resided with the following persons and at the
following addresses:
Lisa Snyder 6 Links Mobile Home Park 2/9/95 - 8/14/99
Lot 63
Mechanicsburg, PA 17055
Jamie Lee Hendricks 145 Richard Riggs Road 8/14/99 - present
Swansboro, NC
The mother of the child is Lisa Snyder, currently residing at 6 Links Mobile Home Park,
Lot 63, Mechanicsburg, Pennsylvania, 17055.
She is single.
The father of the child is Jamie Lee Hendricks, currently residing at 145 Richard Riggs
Road, Swansboro, North Carolina.
He is marred.
4. The relationship of plaintiff to the child is that of mother.
The plaintiff currently is residing at 6 Links Mobile Home Park, Lot 63, Mechanicsburg,
PA 17055.
5. The relationship of defendant to the child is that of father.
The defendant currently resides with the following persons:
Rosemary Elui mother
Taylor Hendricks daughter
6. 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.
7. The plaintiff has no information of a custody proceeding concerning the child pending
in a court of this Commonwealth.
8. The 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.
9. The best interest and permanent welfare of the child will be served by granting the
relief requested for reasons including the following:
a) The mother is the parent who can best provide for the child; she has the child
enrolled in daycare, and the Childcare Network is currently holding a place for the
child in their subsidized program.
b) The father has not acted in the best interest of the child by denying the mother
physical contact with the child since approximately August 25, 1999, and
telephone contact since approximately September 12, 1999, and by keeping the
child separate from her siblings with whom she has been raised.
c) The father's behavior, as delineated in paragraph 4 of the Petition for Special
Relief field this date in the above-captioned case and incorporated herein by
reference, has not been in the child's best interest and has adversely affected the
child.
10. Each parent whose parental rights to the child have not been terminated and the person
who has physical custody of the child have been named as parties to this action.
WHEREFORE, the plaintiff requests this Court to grant primary physical custody of the
child to the plaintiff.
Respectfully submitted,
Doan Carey,
Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
The above-named Plaintiff, Lisa M. Snyder, verifies that the statements
made In the above Complaint are true and correct. Plaintiff understands that
false statements herein are made subject to the penalties of 18 Pa. C.S. §4904,
relating to unsworn falsification to authorities.
Date: Ciao
JLC( \
Lisa M. Snyder, Plaintiff
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LISA M. SNYDER,
Plaintiff
VS.
JAMIE LEE HENDRICKS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAN,D/ COUNTY, PENNSYLVANIA
: NO. 99- G IS V CIVIL TERM
:CUSTODY
To the Prothonotary:
Kindly allow, Lisa M. Snyder, Plaintiff, to proceed in fQ= pauceris.
1, Joan Carey, attorney for the party proceeding in forma pauncris, certify that 1 believe
the party is unable to pay the costs and that 1 am providing free legal services to the party. The
party's affidavit showing inability to pay the costs of litigation is attached hereto.
J
Joan Carey
Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
V
LISA M. SNYDER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
VS.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-
CIVIL TERM
JAMIE LEE HENDRICKS,
Defendant
:CUSTODY
AFFIDAVIT IN SUPPORT OF PETITION
LEAVE TO PROCEED IN FORMA PAUPERIS
1. 1 am the plaintiff in the above matter and because of my financial condition am unable
to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay
the costs of litigation.
3. 1 represent that the information below relating to my ability to pay the fees and costs is
true and correct.
(a) Name: Lisa M. Snyder
Address: 6 Links Mobile Home Park. Lot 63
Mechanicsburg. PA 17055
Social Security Number: 210-64-5704
(b) If you are presently employed, state
Employer: Bob Evans Restaurant
Address: 135 Sheraton Drive
New Cumberland. PA 17070
Salary or wages per month: $1080/month
Type of work: Waitress
If you are presently unemployed, state
Date of last employment:
Salary or wages per month:
Type of work:
(c) Other income within the past twelve months
Business or profession: _N/A
Other self-employment: N/A
Interest: N/A
Dividends: N/A
Pension and annuities: N/A
Social Security benefits: N/A
Support payments: 5460/mo
Disability payments: N/A
Unemployment compensation and
supplemental benefits: N/A
Worker's compensation: N/A
Public Assistance: N/A
Other: Friendly's Restaurant- only January, 1999- S I So total for Jan.
(d) Other contributions to household support
Name:
If your (husband) (wife) is employed, state
Employer:
Salary or wages per month: _
Type of work:
Contributions from children:
(e) Property owned
Cash: _ $20
Checking Account: 550
Savings Account: N/A
Certificates of Deposit: N/A
Real Estate (including home): mobile home - (55.000)
Motor vehicle: Make Toyota Tercel Year 1991
Cost 596/mo. Amount owed $2200
Stocks; bonds: N/A
Other:
(f) Debts and obligations
Mortgage: 5129/mo. (Home) 5171 mo. Condo.
Rent: $3051mo.
Loans: 5130/mo.-consolidation. Van loan 5370/mo.. PNC bank loan
- $190/mo.
Monthly Expenses: credit cards 5180/mo.. propane 590/mo.. electric 5201m.
Phone 520/mo.. babysitting 5240/mo.. school lunch 560/mo.. food 5300/mo..
clothing 5501mo.. Insurance S59/mo.
(g) Persons dependent upon you for support
(Wife) (Husband) Name:
Children, if any:
Name: Candice Snyder Age: 12
4. 1 understand that I have a continuing obligation to inform the court of improvement in
my financial circumstances which would permit me to pay the costs incurred herein.
5. 1 verify that the statements made in this affidavit are true and correct. 1 understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to
unswom falsification to authorities.
Dawam f R m- ? ?`.? ?l J-?
Lisa Snyder, Plaintiff
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LISA M. SNYDER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
VS.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 99-6154 CIVIL TERM
JAMIE LEE HENDRICKS,
Defendant :CUSTODY
AND NOW, this 101'r' day of October, 1999, I, ,? ?v I n(?14
hereby certify that I served a copy of the Petition for Special Relief and the Order of
Court dated October 7, 1999, in the above-captioned case, by handing a copy to the
defendant, Jamie Lee Hendricks, on the 1 & day of October, 1999, at
Ns?fure
TRUE COPY FROM REOORD
to Testimony mite W. I ham we aet my Nana
and dta teal of UM Court at CarMab, Pa.
Thts_L. ' __ e U+er6 1p 09
a othonetary
LISA M. SNYDER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 99-6154 CIVIL TERM
JAMIE LEE HENDRICKS,
Defendant :CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this Il?? day of October, 1999, 1, r,? l L-
hereby certify that I served a copy of the Petition for Special Relief and the Order of
Court dated October 7, 1999, in the above-captioned case, by handing a copy to the
defendant, Jamie Lee Hendricks, on the 1d" day of October, 1999, at
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LISA M. SNYDER,
Plaintiff
V.
JAMIE LEE HENDRICKS,
Defendant
. IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-6154 CIVIL TERM
ORDER OF COURT
AND NOW, this 15th day of October, 1999, this matter
having been called on a petition for special relief filed by
Lisa M. Snyder, regarding the custody of Taylor M. Hendricks,
born February 9, 1995, and the father, Jamie Lee Hendricks,
appearing, IT IS ORDERED:
1. Temporary primary physical custody of Taylor is
awarded to the mother.
2. The case is referred to conciliation on November
11, 1999.
3. Following the conciliation conference, an order
shall be forwarded to this Court setting forth the rights of
the parties.
Philip C. Briganti, Esquire
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
For Plaintiff
Jamie Lee Hendricks, Pro se
145 Richard Riggs Road
Swansboro, NC 28584
Defendant
Sheriff
prs
LISA M. SNYDER,
Plaintiff
vs.
JAMIE LEE HENDRICKS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6154 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CRDER OF COURT
AMID NOW, this I b day of , 1999, upon
consideration of the attached Custody Conciliation Report, t is ordered
and directed as follows:
1. The Mother, Lisa M. Snyder, and the Father, Jamie Lee Hendricks,
shall have shared legal custody of Taylor M. Hendricks, born February 9,
1995. Each parent shall have an equal right, to be exercised jointly with
the other parent, to make all major non-emergency cacisions 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 for 2
weeks each month in June, July and August each year, with the specific
dates and times to be arranged by agreement of the parties. The Father
shall have custody of the Child for 2 three day weekends each year, based
upon school holidays, with the times and dates to be arranged by agreement
of the parties. The Father shall also have custody of the Child at any
additional times when the Father travels to the local area as arranged
between the parties.
4. The parties shall alternate having custody of the Child on
holidays as follows:
A. CHRISTMAS: The Father shall have custody of the Child for 2
weeks over the Christmas holiday and school break in odd
numbered years. The Mother shall have custody of the Child
over the Christmas holiday and school break in even numbered
years.
B. In even numbered years, the Father shall
have custody of the Child for 1 week over the Thanksgiving
holiday/school break and the Easter holiday/Spring break. The
Mother shall have custody of the Child over Thanksgiving and
Easter in odd nmunbered years.
5. The party receiving custody of the Child shall be responsible to
provide transportation for the exchange of custody.
6. The parties are prohibited from drinking alcohol to the point of
intoxication or using illegal drugs during his or her periods of custody
with the Child. Both parties shall ensure that any 3rd parties, who are
providing care for the Child, refrain from using alcohol or illegal drugs.
7. The non-custodial parent shall have liberal telephone contact with
the Child.
B. Both parties shall ensure that the other party has his or her
current home address and telephone number.
9. Both parties shall ensure that the other party has a telephone
number where the Child can be reached in the event of an emergency when
that party removes the Child from the residence for an extended period.
10. This order is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of
this order by mutual consent. In the absence of mutual consent, the terms
of this order shall control. i"I
cc: Joan Carey# Esquire - Counsel for Mother
Kristen Goddard Donsenr Esquire - Counsel for Father
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LISA M. SNYDER,
Plaintiff
vs.
JAMIE LEE HENDRICKS,
Defendant
PRICK JUDGE: Edgar B. Bayley
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6154 CIVIL TERM
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:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Taylor M. Hendricks February 91 1995 Mother
2. A Custody Conciliation Conference was held on November 11, 1999,
with the following individuals in attendance: The Mother, Lisa M. Snyder,
with her counsel, Joan Carey, Esquire, and Sonya Lawrence, paralegal, and
the Father, Jamie Lee Hendricks, with his counsel, Kristen Goddard Donsen,
Esquire.
3. The parties agreed to entry of an order in the form as attached.
/? wem 4?.r !lr l 4 f 9 ,a,?u-Y
Date Dawn S. Sunday, Esquire
Custody Conciliator
D W 0
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NOV 1 5 199,