Loading...
HomeMy WebLinkAbout07-2361ALYCIA KNOLL, IN THE COURT OF COMMOM PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. WILLIAM HERSH, JR, Defendant CIVIL ACTION - LAW DIVORCE No. 07 0?2 (,/ C NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 Lawyer Referral Service 32 South Bedford Street Carlisle, Pa 17013 (717) 249-2663 ALYCIA KNOLL, IN THE COURT OF COMMOM PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DIVORCE WILLIAM HERSH, JR, Defendant No. COMPLAINT IN DIVORCE 1. Plaintiff is Alycia Knoll who currently resides at 418 Plum Street, Lemoyne, Pennsylvania, Cumberland County. 2. Defendant is William Hersh, Jr. who currently resides at 418 Plum Street, Lemoyne, Pennsylvania, Cumberland County. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on October 21, 2001, in Towson, Maryland. 5. One child, Tivin Kail Hersh DOB 5/1/03 was born of this marriage. 6. Neither Plaintiff nor Defendant is in the military or naval service of United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. 7. There have been no prior actions of divorce or for annulment between parties. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 10. Plaintiff requests the court to enter a Decree of Divorce divorcing Plaintiff and Defendant. WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce permanently severing the matrimonial bonds between Plaintiff and Defendant and other such Orders as are just and appropriate. COUNT II EQUITABLE DISTRIBUTION 11. The averments of paragraphs 1-10 are incorporated herein by reference. 12. During the marriage the Parties acquired marital property, assets and debts which Plaintiff requests the Court equitably distribute and assign. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce permanently severing the matrimonial bonds Plaintiff and Defendant, enter an Order equitably distributing marital property and such other orders as may be just and appropriate. COUNT III CUSTODY 13. The averments of paragraphs 1-10 are incorporated herein by reference. 14. Plaintiff seeks primary custody of the following child: Name Present Residence -Age Tivin Kail Hersh 418 Plum Street, Lemoyne 4 The child was born to the marriage. The child is presently in the physical custody of plaintiff mother, who resides at the address in paragraph 1 in Cumberland County, Pennsylvania and has resided in Lemoyne, Pennsylvania for the past year. During the past five years, the child has resided with the following persons and at the following addresses: 1. Mother Lemoyne, PA Birth to present Father The mother of the child is Alycia Knoll, Plaintiff, currently residing at the address in Paragraph 1. She is not living separately from Defendant. The father of the child is William Hersh, Jr., Defendant, currently residing at the address in Paragraph 2. He is not living separately from Plaintiff. 15. The relationship of defendant to the child is that of father. The defendant currently resides with Plaintiff and the minor child. 16. The relationship of the plaintiff to the child is that of mother. The Plaintiff currently resides with Defendant and the minor child. 17. Neither party has participated as a party in a custody action concerning the custody of the child in any other jurisdiction. 18. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiff does not know of any 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. 19. The best interest and permanent welfare of the child will be served by granting plaintiff primary physical custody and shared legal custody of said minor child with appropriate periods of partial custody to father. 20. 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, plaintiff respectfully requests your Honorable Court to grant primary physical and shared legal custody rights to Plaintiff. Respe lly sub itte , AUSAN K. P O , ESQ. Attorney ID No 093 3344 Trindle Road Camp Hill, PA 17011 (717) 612-1660 Date: April 18, 2007 Attorney for Plaintiff VERIFICATION I, Alycia Knoll, verify that the statements made in the foregoing COMPLAINT in DIVORCE and CUSTODY are true and correct to the best of my knowledge, information, and belief. 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: Alycia Knoll d a ? -Zv Q a N) C) CO Q2 C = i?l tai ALYCIA KNOLL IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIAM HERSH, JR. DEFENDANT 07-2361 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, _ _ _ _`Thursday, April 26, 2007 _ upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr,, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, May 16, 2007 at 2:00 PM 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; ls/ john J. Mankan, Jr., Esq. 14 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ov ?.o Bey 'emu' ?o ?P.h eZ via 9z X81 al 4 '%, Jeffrey B. Engle, Esquire SHAFFER & ENGLE LAW OFFICES 129 Market Street Millersburg, PA 17061 717-692-2345 *phone 717-692-3554 *fax jeff@shafferengle. com ALYCIA KNOLL Plaintiff vs. WILLIAM HERSH, JR. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2361 CIVIL ACTION LAW IN CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Jeffrey B. Engle, Esquire, as attorney on behalf of the Defendant, William Hersh, Jr., in the above-referenced mater. DATED: May15, 2007 Jeffre e, I.D 644 Offices 129 Market S/rot Millersburg ,,AA 17061 (717) 692-2345 i ALYCIA KNOLL IN THE COURT OF COMMON PLEAS Plaintiff DAUPHIN COUNTY, PENNSYLVANIA VS. NO. 07-2361 CIVIL ACTION LAW WILLIAM HERSH, JR. IN CUSTODY Defendant CERTIFICATE OF SERVICE I, JEFFREY B. ENGLE, ESQUIRE, hereby certify that a true and correct copy of the foregoing Praecipe to Enter Appearance was sent by first class U.S. Mail to the following: Susan K. Pickford, Esquire 3344 Trindle Road Camp Hill, PA 17011 Attorney for Plaintiff Mr. William H. Hersh, Jr. 2525 N. 7th Street Harrisburg, PA 17110 Date: May IS, 2007 Millersburg, PA 17061 (717) 692-2345 71 ...,:.. .- VTl r sEP iozom'? ALYCIA KNOLL, IN THE COURT OF COMMOM PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW IN CUSTODY WILLIAM HERSH, JR, Defendant No. 07-2361 COURT ORDER AND NOW, this i/' day of September, 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. The Father and Mother shall share legal custody of their child, 2. The Mother and Father shall have shared physical custody of the minor child. Mother shall have primary custody and Father shall have partial custody as follows: (a) Father shall pick up the minor child every Wednesday from day care before 5:45pm and return him home at 8:00 pm. Father shall also have the minor child from 10:00 am on Saturday until 5:001 on Sunday on alternating weekends. Parties are to review this arrangement after 2 months to determine if extending Father's weekend to Fridays is appropriate for the minor child. (b) Each party may take a one week vacation with Tivin over the summer months. Each party is to provide the other with dates, location, phone numbers and itinerary two weeks prior to the vacation. The vacationing parent shall provide for phone contact between the child and non-vacationing parent during the vacation week. (c) Beginning August 3'd, 2007, if parties are in agreement, Father shall have the minor child from Friday at 6:30 pm to Sunday at 5:00 pm on alternating weekends with Father's weekend beginning on August 3`d. 3. Regarding holidays: In light of the fact that Father's family traditionally celebrates major holidays before or after the holiday and Mother's family traditionally celebrates major holidays on'the holiday, the parties will arrange custody by mutual agreement for all holidays. !ONWIASNN3d ALV)G") n`Y?,r7,1?3,9Ndno 8Z t Nd t 1 d3S IOOZ Aft do V 4. Neither parent shall leave-the minor child with a non-relative other than the agreed upon daycare facility for more than 2 hours at any one time. If for any reason a parent needs to leave the child for longer than 2 hours, the other parent must be notified and have the option of picking the child up for that period of time. 5. Neither parent shall remove the child from the state without prior written or electronic notice to and consent from the other parent. 6. Each parent shall have equal access to the child's school facility, records and personnel as well as health and school records. Each parent shall insure that the other parent's name is on any list of persons permitted to see and/or pick up the child from any school. 7. The parties will keep each other advised immediately relative to any emergencies concerning the minor-child and shall, further, take any necessary steps to ensure that the health and wellbeing of the minor child is protected. Each parent shall notify the other within 24 hours of illness, injury. Doctor visits shall be reported to the other parent within 24 hours. 8. The parties agree that there shall be reasonable telephone contact with the child during periods whenthe children are not in the custody of that party. Mother will have minor child call Father before bed in the evenings on days that they do not see each other. 9. Neither party shall do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love and affection for the other party. Nor shall either parent permit other relatives or friends to speak or act in such a manner in the presence of the child. 10. Each party shall be entitled to complete and full information from any doctor, dentist, teacher or other similar authority and have copies of any reports given to them as a parent. Such documents include, but are not limited to, medical reports, academic and school report cards and birth certificates. 11. Any permanent modification or waiver of the provisions of this Order must be in writing and shall be affective only if made in writing and executed with the formality of a Stipulation and Agreement. y 12. This Order is entered pursuant to 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 CO , J. Cc: Susan Oickford, Esquire nn ? ! Jeffrey Engle, Esquire t?o? t'as M y. c l?cE .? John J. Mangan, Esquire 9111 j/07 . r- ;t 1 ALYCIA KNOLL, Plaintiff VS. WILLIAM HERSH JR, Defendant IN THE COURT OF COMMOM PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY No. 07-2361 CONCIIdATION CONFERENCE SUI4 M"Y 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 litgation`is as follows:. Tivin Hersh, born 5/l/03, currently in the primary physical custody of the Mother. 2. A Conciliation Conference was held on May 25, 2007 with the following individuals 'in attendance: The Father, William Hersh, with his counsel, Jeffrey Engle, Esquire The Mother, Alycia Knoll, with her counsel. Susan Pickford, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date: John . M gan, Esquir Custody C-onciliator Jeffrey B. Engle, Esquire SHAFFER & ENGLE LAW OFFICES 129 Market Street Millersburg, PA 17061 717-692-2345 * phone 717-692-3554 * fax jell@shafferengle.com ALYCIA KNOLL, PlaintifflRespondent VS. WILLIAM HERSH, JR., Defendant/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 07-2361 : IN CUSTODY PETITION TO MODIFY CUSTODY ORDER AND NOW, this day of August, 2008, the following Petition to Modify Custody Order by Petitioner, William Hersh, Jr., by and through his attorney, Jeffrey B. Engle, Esquire, and respectfully requests This Honorable Court grant a Custody Conciliation, and in support thereof, the following is averred: 1. Petitioner is WILLIAM HERSH, JR., an adult individual currently residing at 133 Stanford Court, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Respondent is ALYCIA KNOLL, an adult individual currently residing at 418 Plum Street, Lemoyne, Cumberland County, Pennsylvania, 17043. 3. The Petitioner is the natural father of subject minor child, Tivin Kail. Hersh, age 5, DOB 05/01/2003. 4. The Respondent is the natural mother of the subject minor child. 5. The subject minor child currently resides with Respondent. 6. Petitioner requests modification of the existing Custody Order for the following reasons: a. Respondent has failed to keep Petitioner informed at all times regarding the minor child's health and education in violation of the Custody Order and despite Petitioner's repeated requests that he remain informed. b. Respondent has failed to keep Petitioner informed regarding the minor child's extracurricular activities, which effectively prevents Petitioner from staying active in the minor child's life, despite Petitioner's repeated requests that he remain informed. c. Respondent owns six cats at her current residence despite the minor child's allergy. As a result, the minor child has required allergy medication for his symptoms for approximately one year. Mother fails to have the minor child tested by an allergist, despite Father's requests. d. Respondent allows the minor child to keep a regular bedtime between 9:30 and 10:00 p.m. on school nights. e. Respondent allows the maternal grandparents to baby-sit the minor child when she is unavailable despite an agreement between Petitioner and Respondent that Respondent will give Petitioner first opportunity to care for the minor child during these periods. 7. Petitioner 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. Petitioner has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. Petitioner does not know of a person not a party to the proceeding 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. WHEREFORE, the Petitioner, William Hersh, Jr., respectfully requests that This Honorable Court grant his request for shared physical and legal custody in this matter. Respectfully submitted, Dated: Z?M Jeffrle s it LAW OFFICES 129'Mar t Str Millersb , A 17061 (717) 692-2345 Attorney for Petitioner VERIFICATION I verify that the averments in this Petition to Modify Custody Order are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unworn falsification to authorities. Dated: 6 P 6?- a, - Wi13iam Hersh, J ., edtioner . ALYCIA KNOLL, Plaintiff/Respondent Vs. WILLIAM HERSH, JR., Defendant/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 07-2361 IN CUSTODY CERTIFICATE OF SERVICE I, JEFFREY B. ENGLE, ESQUIRE, hereby certify that a true and correct copy of the foregoing Petition to Modify Custody Order was sent First Class U.S. Mail to the following: Samuel L. Andes 535 North Twelfth Street P.O. Box 168 Lemoyne, PA 17043 Date: Melissa Wise, Paralegal for Jeffrey B. Engle, Esquire SHAFFER & ENGLE LAW OFFICES 129 Market Street Millersburg, PA 17061 (717) 692-2345 -Ail c rl SLY a ALYCIA KNOLL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIAM HERSH, JR. DEFENDANT 2007-2361 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, September 02, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, October 01, 2008 at 1:00 PM 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: Is/ John-1. Mangan, Jr., 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 HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 PY4 k -*0- 411V g a. ?-. ? `?'`? ysM t 4s fJVVU f 1 WUV c U ?Uud ALYCIA KNOLL, Plaintiff IN THE COURT OF COMMOM PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. WILLIAM HERSH, JR, Defendant Prior Judge: Kevin A. Hess, J. CIVIL ACTION - LAW IN CUSTODY No. 07-2361 COURT ORDER AND NOW, this 2 ' - day of November 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: The prior Order of Court dated September 11, 2007 is hereby VACATED and replaced with this Order. 2. The Father and Mother shall share legal custody of their child. 3. The Mother and Father shall have shared physical custody of the minor child. Mother shall have primary custody and Father shall have partial custody as follows: (a) Father shall pick up the minor child every Wednesday from school or some other mutually agreeable location before 5:45pm and return him to Mother's residence by 8:00 pm. (b) Beginning August P, 2007, Father shall have the minor child from Friday at 6:30 pm to Sunday at 5:00 pm on alternating weekends. (c) Each party may take a one week vacation with Tivin over the summer months. Each party is to provide the other with dates, location, phone numbers and itinerary two weeks prior to the vacation. The vacationing parent shall provide for phone contact between the child and non-vacationing parent during the vacation week. 4. Regarding holidays: In light of the fact that Father's family traditionally celebrates major holidays before or after the holiday and Mother's family traditionally celebrates major holidays on the holiday, the parties will arrange custody by mutual agreement for all holidays. 5. Neither parent shall leave the minor child with a non-relative other than the agreed upon day care facility for more than 2 hours at any one time. If for any reason a parent needs to leave the child for longer than 2 hours, the other parent must be notified and have the option of picking the child up for that period of time. 6. Neither parent shall remove the child from the state without prior written or electronic notice to and consent from the other parent. 7. Each parent shall have equal access to the child's school facility, records and personnel as well as health and school records. Each parent shall insure that the other parent's name is on any list of persons permitted to see and/or pick up the child from any school. 8. The parties will keep each other advised immediately relative to any emergencies concerning the minor child and shall, further, take any necessary steps to ensure that the health and wellbeing of the minor child is protected. Each parent shall notify the other within 24 hours of illness, injury. Doctor visits shall be reported to the other parent within 24 hours. 9. The parties agree that there shall be reasonable telephone contact with the child during periods when the children are not in the custody of that party. Mother will have minor child call Father before bed in the evenings on days that they do not see each other. 10. Neither party shall do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love and affection for the other party. Nor shall either parent permit other relatives or friends to speak or act in such a manner in the presence of the child. 11. Each party shall be entitled to complete and full information from any doctor, dentist, teacher or other similar authority and have copies of any reports given to them as a parent. Such documents include, but are not limited to, medical reports, academic and school report cards and birth certificates. 12. Any permanent modification or waiver of the provisions of this Order must be in writing and shall be affective only if made in writing and executed with the formality of a Stipulation and Agreement. 13. This Order is entered pursuant to 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, J. +.L t twt :.?• cz, as nr C7 Cc: / uel Andes, Esquire 17050 ?illiam Hersh, Jr., 112 Hill Lane, Mechanicsburg, PA ?hn J. Mangan, Esquire 41'es m1alLi-CL //At/o8 ALYCIA KNOLL, IN THE COURT OF COMMOM PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. WILLIAM HERSH, JR, Defendant Prior Judge: Kevin A. Hess, J. CIVIL ACTION - LAW IN CUSTODY No. 07-2361 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: Tivin Hersh, born 5/1/03, currently in the primary physical custody of the Mother. 2. A Conciliation Conference was held on May 25, 2007, an Order issued September 11, 2007 and a conference held November 19, 2008 with the following individuals in attendance: The Father, William Hersh, pro se The Mother, Alycia Knoll, with her counsel. Samuel Andes, Esquire. 3. The undersigned recommends the entry of an Order in the form as attached. Date: jzel-? John an , Esquire Custo y C ciliator = r ? Jeffrey B. Engle, Esquire SHAFFER & ENGLE LAW OFFICES 512 Market Street Millersburg, PA 17061 717-692-2345 *phone 717-692-3554 *fax jeff( Jshafferengle.coin ALYCIA KNOLL, Plaintiff VS. WILLIAM HERSH, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 07-2361 IN DIVORCE/CUSTODY PETITION FOR LEAVE TO WITHDRAW AS COUNSEL AND NOW, this 0/ day of ?AQCMJ?kpl, 2008, comes SHAFFER & ENGLE LAW OFFICES and files this following Motion for Leave to Withdraw as Counsel and in support thereof, avers as follows: Movant, Shaffer & Engle Law Offices, by and through Jeffrey B. Engle, Esquire, is presently counsel of record for the Defendant, William Hersh, Jr., in the above-captioned action. 2. Movant, Shaffer & Engle Law Offices, has represented the Defendant, William Hersh, Jr., at the above-docketed action since approximately May 15, 2007, when Shaffer & Engle Law Offices filed an Entry of Appearance at the above-captioned docket. 3. The Respondent has failed to abide by the conditions of his representation with the undersigned counsel. 4. Movant avers that Respondent will not be prejudiced by Movant's withdraw, as there are no scheduled hearings, conferences or court dates at this time. 5. Movant has advised Respondent of his intent to withdraw and will provide Respondent with copies of all relevant portions of his file and all original documents. 6. Movant's withdrawal as counsel for Respondent will have no material adverse affect on Respondent's interest pursuant to Pennsylvania Rule of Professional Conduct 1.16. 7. Movant, SHAFFER & ENGLE LAW OFFICES, by and through Jeffrey B. Engle, Esquire, respectfully request that he be allowed to withdraw as counsel for Respondent due to all the above. WHEREFORE, Movant respectfully requests that This Honorable Court permit SHAFFER & ENGLE LAW OFFICES, by and through Jeffrey B. Engle, Esquire, to withdraw as counsel for Respondent, William H. Hersh, Jr. Respectfully submitted, SHAFFER & ENGLE LAW OFFICES 717-692-2345 ALYCIA KNOLL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO. 07-2361 WILLIAM HERSH, JR., Defendant : IN DIVORCE/CUSTODY CERTIFICATE OF SERVICE I, JEFFREY B. ENGLE, ESQUIRE, hereby certify that a true and correct copy of the foregoing Petition for Leave to Withdraw as Counsel was sent by U.S. Mail first class to the following: Samuel L. Andes, Esquire 535 North Twelfth Street P.O. Box 168 Lemoyne, PA 17043 Attorney for Plaintiff Mr. William H. Hersh, Jr. 2525 N. 7th Street Harrisburg, PA 17110 Date: h-a?-O? Melissa Wise, Paralegal for Jeffrey B. Engle, Esquire SHAFFER & ENGLE LAW OFFICES 512 Market Street Millersburg, PA 17061 (717) 692-2345 ?._ •- ;;i ;? ?.., ., ,.. .?. C' EC 0 2 20006 ALYCIA KNOLL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO. 07-2361 WILLIAM HERSH, JR., Defendant : IN DIVORCE/CUSTODY RULE TO SHOW CAUSE AND NOW, this I/` day of , 2008, a rule is hereby issued upon both parties to show cause why the attached Petition for Leave to Withdraw as Counsel should not be granted. RULE RETURNABLE Z o DAYS FROM SERVICE. .Pistribution: Jeffrey B. Engle, Esq S uel L. Andes, Esq. William H. Hersh, Jr l??ll08 512 Market Street, Millersburg, PA 17061 * 717-692-2345 (P) 717-692-3554(F) * jeff@shafferengle.com P.O. Box 168, Lemoyne, PA 17043 2525 N. 7`h Street, Harrisburg, PA 17110 4 `} y. _vi` LJ.., i i' I. t,. ? L'.._ ~? Jeffrey B. Engle, Esquire SIMFFER & ENGLE LAW OFFICES 512 Market Street Millersburg, PA 17061 717-692-2345 *phone 717-692-3554 *fax jefj@,shafferengle.com ALYCIA KNOLL, Plaintiff VS. WILLIAM HERSH, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 07-2361 : IN DIVORCE/CUSTODY MOTION TO MAKE RULE ABSOLUTE AND NOW, this day of January, 2009, comes the SHAFFER & ENGLE LAW OFFICES and respectfully requests the Petition to Make Rule Absolute be granted and in support thereof, avers as follows: 1. Petitioner filed a Motion for Leave to Withdraw as Counsel on December 1, 2008. 2. A Rule to Show Cause was issued by This Honorable Court on December 4, 2008, granting Respondent seven (20) days from the date of service to show why the Petition for Relief should not be granted. 3. The Rule to Show Cause was distributed by the Court to Respondent on or about December 4, 2008. 4. As of the time of filing, no response has been filed by any party to this action. WHEREFORE, the undersigned counsel respectfully requests This Honorable Court enter an Order granting leave to withdraw from the Defendant's case. Respectfully submitted, SHAFFER & ENGLE LAW OFFICES Millersburg, PA 17061 717-692-2345 ALYCIA KNOLL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. :NO. 07-2361 WILLIAM HERSH, JR., Defendant : IN DIVORCE/CUSTODY CERTIFICATE OF SERVICE I, JEFFREY B. ENGLE, ESQUIRE, hereby certify that a true and correct copy of the foregoing Motion to Make Rule Absolute was sent by U.S. Mail first class to the following: Samuel L. Andes, Esquire 535 North Twelfth Street P.O. Box 168 Lemoyne, PA 17043 Attorney for Plaintiff Mr. William H. Hersh, Jr. 2525 N. 7th Street Harrisburg, PA 17110 Melissa Wise, Paralegal to Jeffrey B. Engle, Esquire SHAFFER & ENGLE LAW OFFICES 129 Market Street Millersburg, PA 17061 (717) 692-2345 Date: January 7, 2009 I . JAN 0 9 2009 61 ALYCIA KNOLL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. :NO. 07-2361 WILLIAM HERSH, JR., Defendant : IN DIVORCE/CUSTODY ORDER AND NOW, this 17,- day of January, 2009, it is hereby based upon the Motion for Leave to Withdraw as Counsel; IT IS HEREBY ORDERED AND DECREED that leave to withdraw from representation of the Defendant, William Hersh, Jr., is hereby granted. By the Court, Judge stribution: ?Jeffrey B. Engle, Esq. ? S4muel L. Andes, Esq. ?Mr. William H. Hersh, Jr (26 F S h't,a`t l l£ct, 512 Market Street, Millersburg, PA 17061 * 717-692-2345 (P) 717-692-3554(F) * jeff@shafferengle.com P.O. Box 168, Lemoyne, PA 17043 2525 N. 7t' Street, Harrisburg, PA 17110 i? V v!lWINNt d 6 C :Zl lid Z ! NVf AdViO Or40dd 3a 30HK' <t ALYCIA KNOLL, Plaintiff vs. WILLIAM HERSH, JR., Defendant PRAECIPE TO THE PROTHONOTARY; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2361 CIVIL TERM IN DIVORCE Please enter my appearance for the Plaintiff, Alycia Knoll. Please withdraw the claims for economic relief previously raised in the above matter by the Plaintiff including, without limitation, equitable distribution (Count II). Date: 2? S ?u9 el L. s Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 OF -I H= "'"i' F,''??OTARY 2009 OCT -8 AM 10: 4 0 Ic: v}: ?+l?i `+r ALYCIA KNOLL, Plaintiff vs. WILLIAM HERSH, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ) CIVIL ACTION - LAW } NO. 07-2361 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 24 April 2007 and served upon the Defendant on or about 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: ALYCIA KNOLL Ali.. L?F RCE OF *V,-- F"`. ? ? l-'->,'?n?TARY 2009 OCT -8 AM 10: 40 GU ' 4 1 ALYCIA KNOLL, Plaintiff VS. WILLIAM HERSH, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2361 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 24 April 2007 and served upon the Defendant on or about 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I . I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. t . f Dated: WILLIAM HbtSH, JR. {?.l ,J` ? ? , t?(`? 1(??,t {; ? ?? ?? ??rY?', ??? {?, { 5 ' ???h.l t f ALYCIA KNOLL, PLAINTIFF VS. WILLIAM HERSH, JR., DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007-2361 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I, WILLIAM HERSH, JR. hereby accept service of the original Complaint in Divorce and acknowledge receipt of a copy of the Complaint. Date: A WIL HE , JR. FILEL-01:FICE OF THE Ii-^a0TARY 2009 OCT -8 AM 10: 4 0 ALYCIA KNOLL, Plaintiff VS. WILLIAM HERSH, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2361 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under Section 3301(c). 2. Date and manner of service of the Complaint: Divorce Complaint was filed on 24 April 2007 and served upon the Defendant on 28 April 2007. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: 29 September 2009 by Defendant: 29 September 2009. (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 29 September 2009 and filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 29 September 2009 and filed contemporaneously herewith Date: zwc-t amueI L. An s Attorney for Plaintiff °:? OF THE 2004 OCT -8 AM IO: 4 0 ct.J v, IJIN? , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALYCIA KNOLL, V. By the Court, WILLIAM HERSH, JR., : NO. 07-2361 DIVORCE DECREE AND NOW, O&.-v bk Zr I it is ordered and decreed that ALYCIA KNOLL, , plaintiff, and WILLIAM HERSH, JR., , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE J Attes S. Prothono ry !Q • .-)3 - Df /o - -X3 -of &;,,' - d9g, Al?? ./ 4 4,-? I?e r '0900VI. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WILLIAM H. HERSH, JR., ) Plaintiff ) V. ) No. ALYCIA J. KNOLL, ) Defendant ) COMPLAINT FOR PARTIAL CUSTODY 1. Plaintiff is WILLIAM H. HERSH, JR., who resides at 112 Hill Lane, Mechanicsburg, Cumberland County, PA 17050. 2. Defendant is ALYCIA J. KNOLL, who resides at 418 Plum Street, Lemoyne, Cumberland County, PA 17043. 3. Plaintiff seeks partial custody of the following child: Name Age Tivin K. Hersh 6 years Was child born out of wedlock? No 4. The child is presently in the custody of Defendant who resides at 418 Plum Street, Lemoyne, Cumberland County, PA 17043. 5. During the past five years, the child has resided with the following persons and at the following addresses: From To Address With whom MAY, 2003 (Still living 418 Plum Street Defendant, mother; None there) Lemoyne, PA 17043 6. The mother of the child is currently residing at 418 Plum Street, Lemoyne, PA 17043. She is divorced. 7. The father of the child is currently residing at 112 Hill Lane, Mechanicsburg, PA 17050. He is married. Complaint Page 3 of 5 8. The relationship of Plaintiff to the child is father. Plaintiff currently resides with the following persons: Name Victoria K. Hersh Jasmine D. Pavlot Andrea N. Pavlot Relationship to Plaintiff Wife Step-daughter Step-daughter 9. The relationship of Defendant to the child is mother. Defendant currently resides with the following persons: Name Tivin K. Hersh Relationship to Defendant child 10. Plaintiff has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. The court term and number and its relationship to this action are: Name of court: Cumberland County Docket number: 07-2361 Date of last order or hearing: 09-11-07 Type of case: Custody 11. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 13. The best interest and permanent welfare of the child will be served by granting the relief requested because the child is being denied equal time with his father. The child has spent no holidays with his father since the marriage dissolved in May of 2007. A Cumberland County conciliator advised Alycia J. Knoll that permitting additional visitation on an ad hoc basis would be in the best interests of the child; this recommendation has not been followed to any meaningful extent. 14. 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. Complaint Page 4 of 5 WHEREFORE, Plaintiff requests the Court to grant partial custody of the child to Plaintiff. WILLI .HERSH, JR., Plaintiff Verification I, WILLIAM H. HERSH, JR., Plaintiff, verify that the facts stated in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. ' 4904 relating to unsworn falsification to authorities. Date: WILLIAM H. HER , Plaintiff Complaint Page 5 of 5 f3t..C..D-'--+i 'RCE OF THE PRO""ONIOTARY 2009 DEC 16 PM 12; 4 9 xwl?iw 4m P?f# -?35-11 Ce WILLIAM H. HERSH, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ALYCIA J. KNOLL DEFENDANT 2007-2361 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, December 21, 2009 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, January 25, 2010 at 9:00 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. 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/ john . Man an r. Es q. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 2 0 9 9 0 C t8 111i"1 12: C li Z I00, 71- is - ?s y?v ?!'e lop, 0 IFEB 0 9 io ALYCIA KNOLL, IN THE COURT OF COMMOM PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW IN CUSTODY WILLIAM HERSH, JR, Defendant No. 07-2361 Prior Judge: Kevin A. Hess J. -- co y, r Z1. COURT ORDER AND NOW, this O day of February 2010, upon consideration of the 4?ached .; Custody Conciliation Report, it is ordered and directed that: M -c Effective April 01, 2010, the prior Order of Court dated November 21, 2008 is hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, William Hersh, Jr., and the Mother, Alycia Knoll, shall have shared legal custody of Tivin K. Hersh, born 05/01/2003. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: Mother shall have primary physical custody of the Child subject to Father's physical custody as follows: a. Father shall have physical custody of Tivin every Wednesday, picking him up from school, until Thursday morning, dropping him off at school. When there is no school, Father shall pick up Tivin at the day care provider after Father gets off of work Wednesday and returning Tivin to the provider Thursday morning. b. Father shall have physical custody of Tivin on alternating weekends from Friday until Sunday 7:00 pm. Father shall pick Tivin up from school on Friday and drop him off at Mother's residence on Sunday. When there is no school on Friday, Father shall pick Tivin up from the day care provider after Father gets off of work. c. Father shall have physical custody of the Child at such other times as the parties may mutually agree. 4. Holidays: The parents shall arrange the holiday schedule as attached unless otherwise mutually agreed upon. 5. Right of first refusal: In the event that the custodial parent should require a care- taker/babysitter for Tivin, when he is not in school, a period of time in excess of eight hours, the custodial party shall first offer said opportunity to the non- custodial parent. 6. Each parent shall have two non-consecutive weeks of vacation with the Child per summer. The parties may have vacation time during the school year by mutual agreement. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 7. Neither parent shall remove the child from the state without prior written or electronic notice to and consent from the other parent. 8. Each parent shall insure that the other parent's name is on any list of persons permitted to see and/or pick up the child from any school. 9. The parties will keep each other advised immediately relative to any emergencies concerning the minor child and shall, further, take any necessary steps to ensure that the health and wellbeing of the minor child is protected. Each parent shall notify the other within 24 hours of illness, injury. Doctor visits shall be reported to the other parent within 24 hours. 10. The parties agree that there shall be reasonable telephone contact with the child during periods when the children are not in the custody of that party. Mother will have minor child call Father before bed in the evenings on days that they do not see each other. 11. Neither party shall do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love and affection for the other party. Nor shall either parent permit other relatives or friends to speak or act in such a manner in the presence of the child. 12. Any permanent modification or waiver of the provisions of this Order must be in writing and shall be affective only if made in writing and executed with the formality of a Stipulation and Agreement. 13. This Order is entered pursuant to 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, !Ti c P. J. Cc: 3muel Andes, Esquire illiam Hersh, Jr., 112 Hill Lane, Mechanicsburg, PA 17050 John J. Mangan, Esquire 0 opres 1 a,/181ra ?Mryj TIMES EVEN ODD HOLIDAYS AND YEARS YEARS SPECIAL DAYS Easter Day 1" Half From the evening after school break Mother Father lets out until Easter Sunday at noon. Easter Day 2n Half From Easter Sunday at noon until 7 Father Mother pm the evening before school begins Memorial Day The custodial parent that had Tivin the previous weekend gets custody this Monday holiday Independence Day If this holiday falls on a Friday or Monday, the parent whose weekend it is to have custody of Tivin gets this holiday. If this holiday falls on a Tuesday or Thursday, Mother has this holiday. If this holiday occurs on a Wednesday, Father shall have this holiday. Labor Day The custodial parent that had Tivin the previous weekend gets custody this Monday holiday Thanksgiving 1St From noon on Wednesday before the Father Mother Half holiday until Thanksgiving Day at 4 pm Thanksgiving 2" From 4 pm Thanksgiving Day until Mother Father half Friday at 6 pm Christmas 1St Half From 10 am on 12/24 until 2 pm Mother Father 12/25 Christmas 2n Half From 2 m 12/25 until 6 pm 12/26 Father Mother Christmas break From 10 am 12/29 until 6 pm 01 /01 Father Father Mother's Day From 9 am until 9 m Mother Mother Father's Day From 9 am until 9 pm Father Father ALYCIA KNOLL, Plaintiff VS. WILLIAM HERSH, JR, Defendant Prior Judge: Kevin A. Hess, J. IN THE COURT OF COMMOM PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY No. 07-2361 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: Tivin Hersh, born 5/1/03, currently in the primary physical custody of the Mother. 2. A Conciliation Conference was held on May 25, 2007, an Order issued September 11, 2007, a conference held November 19, 2008, an Order issued November 21, 2008 and a conference was held February 05, 2010 with the following individuals in attendance: The Father, William Hersh, self represented party The Mother, Alycia Knoll, with her counsel. Samuel Andes, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date: J Mang an, Es re Concili r