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HomeMy WebLinkAbout99-06962s; •,. L d ?s 1 MARTSO.4 DEARDORFF WILLIAMS .t[ OTTO MID, - 11-"11111• AIM4•A1111,T CA=, I . un AN. 17013 DENNIS A. TRIMMER, Plaintiff V. TRACY L. TRIMMER, Defendant NOV 1 9 199? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- Lq&.Z CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this_l day ofd, , 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before theconciliator,at' r U ? rbi(cv(lrr6 I 6 6k)k1_1Z_ on the 13 day of -t999 at !Q • x? Ctm. for aPre -Hearing Custody Conference. At such conference, an effort wl c 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 [T?j \ The Court of Common Pleas of Cumberland County is required by law to comply with the 1 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 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 i? a, 47 ij99 DENNIS A. TRIMMER, Plaintiff V. TRACY L. TRIMMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.99 !'`CIVIL ACTION LAW IN CUSTODY PLAINTIFF'S COMPLAINT TO CONFIRM CUSTODY Plaintiff is Dennis A. Trimmer, an adult individual currently residing at 29 Watson Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant isTracy L. Trimmer, an adult individual, currently residing at 7 Pine Road, Apt. 305, Mt. Holly Springs, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the child, Dennis J. Trimmer, who :vas bom on August 4, 1996. The child was not born out of wedlock. Since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: Since his birth, the child resided with the parties at the marital residence, along with his half-brother. For a brief period of time, he resided with the Defendant at the Defendant's parents' home, but both returned to the marital residence in the summer of 1998 and the child has resided there since then. 4. The relationship ofthe Plaintiff to the child is that of father. He is married and living separately. The Plaintiff currently resides with the following: Name Relationship Dennis J. Trimmer Son 5. The relationship of the Defendant to the child is that of mother. She is married and living separately. The Defendant currently resides with the following: Name Austin Sheller Relationship Son 6. Plaintiff filed a prior Custody Complaint to docket number 98-4526 on August 5, 1998, but the parties reconciled and the Complaint was withdrawn prior to a conciliation conference. The Plaintiff has no information of a custody proceeding concerning the child pending in any other court. 7. The best interest and permanent welfare of the child will be served by granting custodytoPlaintiffbecause: Plaintiff is best able to providea stable and nurturing home forhis son. 8. Plaintiff does not know of any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff requests your Honorable Court to set a time and place fora hearing at which Plaintiff requests the Court to grant him the Custody Order. Pending said hearing, Plaintiff requests temporary custody. MARTSON, DEARDORFF, WILLIAMS & OTTO Thomas J. Wil ms, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: November 17, 1999 N VERIFICATION The foregoing Custody Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswor falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Dennis A. Trimmer v C j. 11 (?? L ~ Cl) C; L'7 0 1 169- IC rz, J ?l JHtr -uuu .t DENNIS A. TRIMMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TRACEY L. TRIMMER, : NO. 99-6962 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this alb day of January, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The Mother, Tracey L. Trimmer, and the Father, Dennis A. Trimmer, shall enjoy shared legal custody of Dennis A. Trimmer, born August 4, 1996. 2. The Father shall have primary physical custody of the minor child. 3. The Mother shall enjoy temporary physical custody of the minor child as follows: A. On alternating weekends from Friday evening to Sunday evening with the time of exchange to be agreed upon by the parties. B. One night during the week as agreed upon by the parties, this to be simply an evening period of time with the child to be returned to the Father's custody prior to going to bed. C. At such other times as to be agreed, with the understanding that both parties will be able to have time on holidays and have vacation time. 4. This order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event either party desires to modify this order and the parties are unable to reach an agreement between themselves on modification of the order, either party may petition the court to have the case again scheduled with a Custody Conciliator for a Conference. cc: Thomas J. Williams, Esquire Tracy L. Trimmer 7 Pine Road, Apt. 305 Mt. Holly Springs. PA 17065 BY T OU J. .t `/ 0 Vs (. C:.2:? DENNIS A. TRIMMER, Plaintiff v TRACEY L. TRIMMER, Defendant Prior Judge: IN TI4E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 99-6962 CIVIL : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Dennis A. Trimmer, born August 4, 1996. 2. A Conciliation Conference was held on January 13, 2000, with the following individuals in attendance: The Father, Dennis A. Trimmer, with his counsel, Thomas J. Williams, Esquire; and the Mother, Tracy L. Trimmer, who appeared without legal counsel. 3. The parties agree to the entry of an order in the form as attached. 4 TE MARTSON DEARDDXRFFF WILLIAMS ?& OTTO *R 24 2000 TEN STREET ' CARLISLE. SLE. PENNSYLVANIA 17013 DENNIS A. TRIMMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-6962 CIVIL ACTION LAW TRACY L. TRIMMER, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ,adayof?(, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before iVY-("k- X • &Vo--1 ,theconciliator, at 1 }" r\Cr"A f c-V -,c t o on the 12" day of /tlI , 2000, at _ :30 A .m-for a Pre-Hearing Custody Conference. At such nference, an effort will be made fo 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: UVl a:k \.4• Custody Conciliator U (N) 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 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 r:.. y ? •aU L? ?' /? /Zj;"?6 /J ',,o F IFILLWIATAFILGGa V<u X014ye bldg CmnN O&OP 09 3128 AM Noi,nl OjgO W U 13 4l P\I 96914 DENNIS A. TRIMMER, Plaintiff V. TRACY L. TRIMMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6962 CIVIL ACTION LAW IN CUSTODY PLAINTIFF'S PETITION TO MODIFY CUSTODY AND NOW, comes Plaintiff, Dennis A. Trimmer, by and through his attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and moves the Court to modify the Custody Order entered January 21, 2000 as follows and for the following reasons: Father is Plaintiff, Dennis A. Trimmer, ("Father") who resides at 29 Watson Drive, Carlisle, Cumberland County, Pennsylvania. 2. Mother is Defendant, Tracy L. Trimmer, ("Mother") who resides at 7 Pine Road, Apt. 305, Mt. Holly Springs, Cumberland County, Pennsylvania. 3. The subject of this Petition is Dennis J. Trimmer, bom August 4, 1996 who resides with Father. 4. On January 13, 2000, both parties attended a custody conciliation conference and agreed to the entryof an Order granting primary physical custody to the Father subject to the Mother having periods of temporary physical custody every other weekend and one night during the week. 5. A Custody Order was entered pursuant to this agreement on January 21, 2000 by the Honorable Edward E. Guido. A copy of this Order is attached hereto and marked as Exhibit "A." 6. Mother has never fully exercised her periods of temporary custody, causing uncertainty in Father and child as to what was going to happen during those times. 7. Mother and Father have agreed that full custody of the child should be given to Father with Mother having the child for such times as the parties may agree. WHEREFORE, Father (Petitioner) prays Your Honorable court to modify the Order of January 21, 2000 giving him full legal and physical custody of Dennis J. Trimmer, subject to such periods of temporary custody with Mother as the parties may agree. Respectfully submitted, MARTSON, DEARDORFF, WILLIAMS & OTTO 13 X42+ a o. y Esquire Thomas J. Williams, Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: -7l J I/ co Exhibit A _ JAN 2 0 20Qp 1 DENNIS A. TRIMMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW TRACEY L. TRIMMER, : NO. 99-6962 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this -21#7 of January, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Tracey L. Trimmer, and the Father, Dennis A. Trimmer, shall enjoy shared legal custody of Dennis A. Trimmer, born August 4, 1996. 2. The Father shall have primary physical custody of the minor child. 3. The Mother shall enjoy temporary physical custody of the minor child as follows: A. On alternating weekends from Friday evening to Sunday evening with the time of exchange to be agreed upon by the parties. B. One night during the week as agreed upon by the parties, this to be simply an evening period of time with the child to be returned to the Father's custody prior to going to bed. C. At such other times as to be agreed, with the understanding that both parties will be able to have time on holidays and have vacation time. 4. This order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event either parry desires to modify this order and the parties are unable to reach an agreement between themselves on modification of the order, either parry may petition the court to have the case again scheduled with a Custody Conciliator for a Conference. BY THE COURT, cc: Thomas J. Williams, Esquire Tracy L. Trimmer 7 Pine Road, Apt. 305 Mt. Holly Springs, PA 17065 EXHIBIT "A" TFMr COPY iT .i P.£COR? CIrlisle. Pa. Nrothonotr:ry??? V. . DENNIS A. TRIMMER, Plaintiff v TRACEY L. TRIMMER, Defendant Prior Judge: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6962 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: I. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Dennis A. Trimmer, born August 4, 1996. 2. A Conciliation Conference was held on January 13, 2000, with the following individuals in attendance: The Father, Dennis A. Trimmer, with his counsel, Thomas J. Williams, Esquire; and the Mother, Tracy L. Trimmer, who appeared without legal counsel. IF, 3. The parties agree to the entry of an order in the form as attached. /W 4 0 L/ '? ATE Hubert X. Custody C !'t ti 1 l { VERIFICATION The foregoing Petition to Modify Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. ennis A. Trimmer CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Manson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Plaintiffs Petition to Modify Custody was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Tracy L. Trimmer 7 Pine Road, Apt. 305 Mt. Holly Springs, PA, 17065 MARTSON DEARDORFF WILLIAMS & OTTO y Tricia D. Eckenroad en East High Street Carlisle, PA 17013 (717) 243-3341 Dated: ??VOW6 tT t - F. U . L'J ?: ? lS . i.: fJ C, C. ?i ?I I 4lu : CJ cv CJ MAY 2 2 2000 DENNIS A. TRIMMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TRACEY L. McGOUGH, NO. 99-6962 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this A 3 A day of May, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's Order of January 21, 2000 shall remain in effect. Either party may petition the court any time in the future to have the existing order modified at which time the case will again be referred to the Custody Conciliator. 7;;, J. Edward E. Guido cc: Thomas J. Williams, Esquire Tracey L. McGough -60 7 Pine Road, Apt. 305 J K -3 Mt. Holly Springs, PA 17065 i DENNIS A. TRIMMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff' : CUMBERLAND COUNTY, PENNSYLVANIA v TRACEY L. McGOUGH, Defendant Prior Judge: Edward E. Guido CIVIL ACTION - LAW NO. 99-6962 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The Conciliation Conference was held with the Mother, Tracey L. McGough, and the Father, Dennis A. Trimmer and his counsel Thomas J. Williams, Esquire. After discussion with the parties, it was determined that the existing order would remain in effect. Accordingly, the Conciliator recommends an order in the form as attached. ob 51) T D Hubert X. Gilroy, quire Custody Concil' or DENNIS A. TRIMMER PLAINTIFF V. TRACY L. MCGOUGH F/K/A TRACY L. TRIMMER DEFENDANT • IN THE COURT OP COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 99-6962 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 17TH day of AUGUST , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on the 20th day of October , 2000, at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Isl Hubert X. Gilroy. Esq.10 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 HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 CU:. V MARTSON DFARDORFF WILLIAMS & OTTO Iv w&CD INIORPR?W •AIMIi•AIntMAY TEN EAST 1-11611 STREET CARLISLE, PENNSYLVANIA 17013 DENNIS A. TRIMMER, Petitioner/Plaintiff V. TRACY L. McGOUGH, 9Wa TRACY L. TRIMMER, Respondent/Defendant AUG 15 2000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6962 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT ANDNOW,this_dayof 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the _ day of 2000, at 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. FOR THE COURT, 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 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 F IILMGATAFILEGMJ cuM69I4 M=1& CIW[d W0980831 29A81 Kni" O&MM084646AM 96914 DENNIS A. TRIMMER, Petitioner/Plainti ff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. TRACY L. McGOUGH, f/k/a TRACY L. TRIMMER, Respondent/Defendant NO. 99-6962 CIVIL ACTION LAW IN CUSTODY PLAINTIFF'S PETITION TO MODIFY CUSTODY ORDER AND NOW, comes Petitioner, Dennis A. Trimmer, by and through his attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and avers as follows: 1. Petitioner is the natural father of Dennis J. Trimmer, bom August 4, 1996. Petitioner 1 _1. II! resides at 29 Watson Drive, Carlisle, Cumberland County, Pennsylvania with his son, Dennis J. Trimmer, and his wife, Amy Trimmer. 2. Respondent is Tracy L.Trimmer-McGough, the natural motherofDennisJ.Trimmer, whose address is presently unknown. Petitioner does not believe that Respondent has a permanent address. Respondent has advised us to serve papers c/o Pearl McGough, her mother, 5 Cooper Circle, Carlisle, Pennsylvania 17013. 3. The present Custody Order with regard to Dennis J. Trimmer was issued on May 23, 2000 and is attached hereto and marked as Exhibit "A." Essentially, it gives Petitioner primary custody of Dennis J. Trimmer and Respondent temporary custody on alternate weekends and one 4. Since the Order has been entered, Respondent's custody rights have primarily been exercised by and through her parents, James and Pearl McGough. 5. The parties wish to formalize those arrangements in a revised Custody Order, awarding custody of Dennis J. Trimmer to his maternal grandparents, James and Pearl McGough, every other weekend from 3:00 p.m. on Saturday until 3:00 p.m. on Sunday and every Wednesday from 4:00 p.m. until 7:30 p.m. The parties have agreed that transportation between the homes of Petitioner, Dennis A. Trimmer, and James and Pearl McGough, both noted above, will be divided equally. Custody of Dennis J. Trimmer by his mother, Respondent Tracy L. Trimmer-McGough, shall be arranged through her parents, James and Pearl McGough, during the time they have custody. night during the week. 6. The parties agree that the prior Custody Order will continue in effect, except as modified as noted above. WHEREFORE, Petitioner prays Your Honorable Court to grant full legal and physical custody of Dennis J. Trimmer to himself and custody of Dennis J. Trimmer by his mother, Respondent Tracy L. Trimmer-McGough, shall be arranged through her parents, James and Pearl McGough, during their time of custody. Respectfully submitted, MARTSON, DEARDORFF, WQILLIAMS & OTTO By.s.. w cQ-?++i? Thomas J. W ' ms, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: August 10, 2000 7 Exhibit A MAY 2 2'20000. DENNIS A. TRIMMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW TRACEY L. McGOUGH, : NO.99-6962CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this -L3Ld day of May, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's Order of January 21, 2000 shall remain in effect. Either party may petition the court any time in the future to have the existing order modified at which time the case will again be referred to the Custody Conciliator. BY THE COURT, S J. Edward E. Guido cc: Thomas J. Williams, Esquire Tracey L. McGough 7 Pine Road, Apt. 305 Mt. Holly Springs, PA 17065 TRUE- -COP-' In .1 nand ald Z. rid 4,- EXHIBIT "A" DENNIS A. TRIMMER, Plaintiff TRACEY L. McGOUGH, Defendant Prior Judge: Edward E. Guido : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6962 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The Conciliation Conference was held with the Mother, Tracey L. McGough, and the Father, Dennis A. Trimmer and his counsel Thomas J. Williams, Esquire. After discussion with the parties, it was determined that the existing order would remain in effect. Accordingly, the Conciliator recommends an order in the form as attached. 5 I q f1bi` ?? DATE Hubert X. Gilroy, wire Custody Concil' or JAN 2 0 Z00? .? DENNIS A. TRIMMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW TRACEY L. TRIMMER, : NO. 99-6962 CIVIL Defendant : M CUSTODY COURT ORDER AND NOW, this -A#day of January, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Tracey L. Trimmer, and the Father, Dennis A. Trimmer, shall enjoy shared legal custody of Dennis A. Trimmer, bom August 4, 1996. 2. The Father shall have primary physical custody of the minor child. 3. The Mother shall enjoy temporary physical custody of the minor child as follows: A. On alternating weekends from Friday evening to Sunday evening with the time of exchange to be agreed upon by the parties. B. One night during the week as agreed upon by the parties, this to be simply an evening period of time with the child to be returned to the Father's custody prior to going to bed. C. At such other times as to be agreed, with the understanding that both parties will be able to have time on holidays and have vacation time. 4. This order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event either party desires to modify this order and the parties are unable to reach an agreement between themselves on modification of the order, either party may petition the court to have the case again scheduled with a Custody Conciliator for a Conference. BY THE COURT, cc: Thomas J. Williams, Esquire Tracy L. Trimmer 7 Pine Road, Apt. 305 Mt. Holly Springs, PA 17065 CG?Y FP r Pxcom 94(10r-, Cetl?sir.; i'a. , Yof. ? (' ?rothonofary I l VERIFICATION The foregoing Petition to Modify Custody Order is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. -2? 'Dennis A. Trimmer CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Plaintiff's Petition to Modify Custody was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Tracy L. McGough c/o Mrs. Pearl McGough Five Cooper Circle Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO ' I 0 y T ' is D. Eckenroad Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: August 10, 2000 ti ; CV ?, . U - w ' t 11 Q.. V O C> OCT 10 2o0 4 DENNIS A. TRIMMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TRACEY L. McGOUGH, NO. 99-6962 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this 3f?, day of October, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Custody Orders entered in this case are vacated. 2. The Father, Dennis A. Trimmer, shall enjoy legal and primary physical custody of Dennis J. Trimmer, bom August 4, 1996. 3. The Maternal Grandparents, James and Pearl McGough, shall enjoy periods of temporary physical custody with the minor child as follows: A. On alternating weekends from Saturday at 3:00 p.m. until Sunday at 3:00 p.m. B. Every Wednesday from 4:00 p.m. until 7:30 p.m. C. At such other times as the parties may agree. 4. The Mother, Tracey L. McGough, shall enjoy periods of custody with the minor child through her parents and also at times the parties may agree. 5. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event either party desires to modify this Order, that party may petition the court to have this case again scheduled with the Custody Conciliator for a conference. BY T COURT J. Edward E. Guido id •31 00 AKS 'IrIlRY C(i +, cCU?rY , nsrLt/Vvli; , ff. cc: Thomas J. Williams, Esquire Tracey L. McGough 1020 Wayne Avenue, Apt. 1 Carlisle, PA 17013 James and Pearl McGough 5 Cooper Circle Carlisle, PA 17013 DENNIS A. TRIMMER. Plaintiff TRACEY L. McGOUGH, Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6962 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Dennis J. Trimmer, born August 4, 1996. 2. A Conciliation Conference was held on October 20, 2000, with the following individuals in attendance: The Father, Dennis A. Trimmer, with his counsel, Thomas J. Williams, Esquire; and the Mother, Tracey L. McGough, who appeared without counsel and the Maternal Grandparents, Pearl and James McGough who also appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. /o a 1,106 ALA-S DATE Hubert X. Gilroy, Esqu' e Custody Conciliator