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HomeMy WebLinkAbout03-3900KAREN L. CONRAD : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 03 - .3904 ?w `L?' l WILLIAM P. CONRAD : CIVIL ACTION - LAW Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Karen L. Conrad, residing at 108 Sgrignoli Lane, Enola, Cumberland County, Pennsylvania. 2. The Defendant is William P. Conrad, residing at 138 Wyoming Avenue, Enola, Cumberland County, Pennsylvania. 3. Plaintiff seeks primary custody of the following children: NAME PRESENT RESIDENCE (Shared Custody) Kate] yn M. Conrad 108 Sgrignoli Lance Enola, PA (Mother) Nathan P. Conrad Spencer N. Conrad and 138 Wyoming Avenue Enola, PA (Father) Natalie I. Conrad The children were not bom out of wedlock. D.O.B April 28, 1991 February 14, 1993 May 20, 1994 September 28, 2000 The parents of the children are presently sharing custody at the following addresses: 108 Sgrignoli Lane, Enola, Pennsylvania (Mother) and 138 Wyoming Avenue, Enola, Pennsylvania (Father). During the past five years, the children have resided with the following persons and at the following addresses: NAME RESIDENCE DATE Karen L. Conrad (mother), 73 Crreenmont Drive 12/04/91 William P. Conrad (father) and Enola, PA Heather and Zackery Mayberry Karen L. Conrad (mother), 108 Sgrignoli Lane 2003 -present John Lewis, Heather and Zackery Enola, PA Mayberry and Victoria The mother of the children is Karen L. Conrad, currently residing at 108 Sgrignoli Lane, Enola, Pennsylvania. She is married. The father of the children is William P. Conrad, currently residing at 138 Wyoming Avenue, Enola, Pennsylvania. He is married. 4. The relationship of Plaintiff to the children is that of mother. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP John Lewis Katelyn, Nathan, Spencer Children And Natalie Conrad (shared custody) Heather and Zackery Mayberry Children (shared custody) Victoria Daughter 5. The relationship of Defendant to the children is that of father. The Defendant currently resides with the following persons: NAME RELATIONSHIP Katelyn, Nathan, Spencer Children And Natalie Conrad (shared custody) Heather and Zackery Mayberry Children (shared custody) 6. Plaintiff has not participated as a parry or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested. The parties are currently sharing custody which your Plaintiff believes is not in the children's best interest. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, the Plaintiff requests that she be awarded primary custody of the minor children. JAMES, SMITH, DIETTERICK & CONNELLY LLP Date: 0 3-OS"O3 By: Hershey, PA 17033 (717) 533-3280 PA I.D. No. 15615 VERIFICATION I verify that the statements made in this Pleading 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. Date: 0 - O - 03 4-x • l 11') J?-(t r ? a R KAREN L. CONRAD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-3900 CIVIL ACTION LAW WILLIAM P. CONRAD IN CUSTODY DEFENDANT ORDER OF COURT Thursda , August 14, 2003 upon consideration of the attached Complaint, AND NOW, Pawn S. Sundav, Esq., the conciliator, before it is hereby directed that parties and their respective counsel appear Thursday, September 11, 2003 at 8:30 AM at 39, West Main Street, Mechanicsbur , PA 17055 on a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or for 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 permanent 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, ls/ Dawn S S:sndav Fsa By: 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 umberland County B Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 PSI r/8 i KAREN L. CONRAD, Plaintiff VS. WILLIAM P. CONRAD Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3900 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this z z 4 day of 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall submit themselves, their minor Children, and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by Arnold Shienvold, PhD. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best serve the needs and. interests of the Children. The parties shall sign all authorizations requested by the evaluator to obtain additional information pertaining to the parties and the Children. The Mother shall pay all costs of the evaluation initially but reserves the right to request that the Court allocate the costs between the parties in future proceedings. 2. Pending completion of the custody evaluation and agreement of the parties or further Order of Court, the parties shall share having legal and physical custody of Katelyn M. Conrad, born April 28, 1991, Nathan P. Conrad , born February 14, 1993, Spencer N. Conrad, born May 20, 1994, and Natalie I. Conrad, born September 28, 2003. The parties shall continue to follow the existing shared custody schedule under which the parties alternate having custody of the Children on weekends from Friday through Sunday, from Sunday through Tuesday and from Tuesday through Friday each week. 3. Within sixty days of receipt of the evaluator's custody recommendations, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary to assist the parties in establish ongoing custody arrangements. 4. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, A. Hess J. cc: John J. Connelly, Jr., Esquire - Counsel for Mother?? tea{ q 3 -03 Elizabeth S. Beckley, Esquire - Counsel for Father It R• j Q !7 . lJ ?) U KAREN L. CONRAD, Plaintiff vs. WILLIAM P. CONRAD Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3900 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: L The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Katelyn M. Conrad April 28, 1991 Mother / Father Nathan P. Conrad February 14, 1993 Mother / Father Spencer N. Conrad May 20, 1994 Mother / Father Natalie I. Conrad September 28, 2000 Mother / Father 2. A Conciliation Conference was held on September 11, 2003 with the following individuals in attendance: The Mother, Karen L. Conrad, with her counsel, John J. Connelly, Jr., Esquire, and the Father, William P. Conrad, and his counsel, Elizabeth S. Beckley, Esquire. 3. The parties agreed to entry of an Order in the form as attached. 4. Although this is a newly filed custody matter, counsel advised the conciliator that Judge Hess has previously been involved in a related matter concerning the Mother's children from a prior marriage. Therefore counsel requested that this matter also be forwarded to Judge Hess due to his familiarity with the background of this family. r?br Date l I1 )no-i iCOti Dawn S. Sunday, Esquire Custody Conciliator KAREN L. CONRAD, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW :1N CUSTODY WILLIAM P. CONRAD, Defendant :NO. 03-3900 PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW comes the Plaintiff, William P. Conrad, who, by and through his attorneys, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Petition for Modification of Custody, in which he avers that: 1. Plaintiff, William P. Conrad, is an adult individual residing at 138 Wyoming Avenue, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant, Karen Conrad, is an adult individual residing at 108 Scrignoli Lane, Enola, Cumberland County, Pennsylvania 17025. 3. On September 22, 2003, the Honorable Kevin A. Hess entered a custody order giving the parties shared legal and physical custody of their 4 children: Katelyn M. Conrad born April 28, 1991, Nathan P. Conrad, born February 14, 1993, Spencer N. Conrad, born May 20, 1994, and Natalie I. Conrad, born September 28, 2003. A true and correct copy of the Court's September 22, 2003, Order is attached hereto marked as Exhibit A and incorporated herein. 4. Since the entry of said Order, there has been a significant change in circumstances in that: the parties participated in a custody evaluation in which Dr. 1 Shienvold recommend that the parties' oldest daughter, Katelyn, be placed in her Father's primary care. Katelyn has also indicated a very strong preference to live primarily with her Father. 5. The best interest of the children will be served by the Court in modifying said Order as follows: the parties will share legal custody of all the children. Katelyn M. Conrad will reside primarily with her Father and the parties will continue to share physical custody of Nathan P. Conrad, Spencer N. Conrad and Natalie I. Conrad. WHEREFORE, Defendant respectfully requests that the Court grant him joint legal custody of the parties' minor children, primary physical custody of Katelyn M. Conrad and shared physical custody of Nathan P. Conrad, Spencer N. Conrad and Natalie 1. Conrad. DATED: ID r I ? I of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233-7691 Respectfully submitted, homas A. Beckley izabdth S. Bec ev 2 EXHIBIT A • KAREN L. CONRAD, Plaintiff vs. WILLIAM P. CONR.AD Defendant (0 py SEP 19 2003 ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3900 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ?1c day of 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall submit themselves, their minor Children, and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by Arnold Shienvold, PhD. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best serve the needs and interests of the Children. The parties shall sign all authorizations requested by the evaluator to obtain additional information pertaining to the parties and the Children. The Mother shall pay all costs of the evaluation initially but reserves the right to request that the Court allocate the costs between the parties in future proceedings. 2. Pending completion of the custody evaluation and agreement of the parties or further Order of Court, the parties shall share having legal and physical custody of K.atelyn M. Conrad, born April 28, 1991, Nathan P. Conrad , born February 14, 1993, Spencer N. Conrad, born May 20, 1994, and Natalie I. Conrad, born September 28, 2003. The parties shall continue to follow the existing shared custody schedule under which the parties alternate having custody of the Children on weekends from Friday through Sunday, from Sunday through Tuesday and from Tuesday through Friday each week. 3. Within sixty days of receipt of the evaluator's custody recommendations, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary to assist the parties in establish ongoing custody arrangements. 4. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, in A. Hess J. cc: John J. Connelly, Jr., Esquire - Counsel for Mother Elizabeth S. Beckley, Esquire - Counsel for Father TRUE COPY FROM RECORD in Testimony whue a, l tiere unto set my hand and the seal of uW CoV at Cmilsle, PL #rss 2a Prothonoi KAREN L. CONRAD, Plaintiff VS. WILLIAM P. CONRAD Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3900 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 Children who are the subjects of this litigation is as follows: NAME Katelyn M. Conrad Nathan P. Conrad Spencer N. Conrad Natalie I. Conrad DATE OF BIRTH April 28, 1991 February 14, 1993 May 20, 1994 September 28, 2000 CURRENTLY IN CUSTODY OF Mother / Father Mother / Father Mother / Father Mother / Father 2. A Conciliation Conference was held on September 11, 2003 with the following individuals in attendance: The Mother, Karen L. Conrad, with her counsel, John J. Connelly, Jr., Esquire, and the Father, William P. Conrad, and his counsel, Elizabeth S. Beckley, Esquire. 3. The parties agreed to entry of an Order in the form as attached. 4. Although this is a newly filed custody matter, counsel advised the conciliator that Judge Hess has previously been involved in a related matter concerning the Mother's children from a prior marriage. Therefore counsel requested that this matter also be forwarded to Judge Hess due to his familiarity with the background of this family. Date Daw9S( undaY, Esquire U Custody Conciliator VERIFICATION I, William P. Conrad, hereby verify that the statements made in the foregoing document 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 18 Pa. C. S. Section 4904, relating to unworn falsification to authorities. ? OL- DAT ED: k ? 31? C William P. Conrad CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the foregoing document was this day served upon the person and in the manner indicated below. SERVICE BY FIRST CLASS MAIL: John J. Connelly, Esquire James, Smith, Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 DATED: izab .h S. Bec e , s ire 1'^J -7 C-o v P1_ v I FEB 1 6 2005 KAREN L. CONRAD IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 03-3900 CIVIL ACTION LAW WILLIAM P. CONRAD Defendant IN CUSTODY ORDER OF COURT AND NOW, this 17- day of 60r" , 2005, upon consideration of the attached Custody Conciliation Report, lered and directed as follows: 1. The Mother, Karen L. Conrad, and the Father, William P. Conrad, shall have shared legal custody of Katelyn M. Conrad, born April 28, 1991, Nathan P. Conrad, born February 14, 1993, Spencer N. Conrad, born May 20, 1994, and Natalie I. Conrad, born September 28, 2003. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The parties shall make arrangements for Katelyn to be evaluated by a psychiatrist and receive focused psychiatric care to address her history of behavior and emotional problems. The parties shall select a professional by agreement who participates in the applicable insurance plan. Any costs of evaluation/therapy which are not covered by insurance shall be shared equally between the parties. The parties shall follow the recommendations of the psychiatrist with regard to the frequency and duration of sessions as well as the individuals who will be participating in each session. The parties shall also follow any recommendations by the psychiatrist pertaining to custodial schedule adjustments and ongoing counseling with a psychologist. Neither party shall cancel any scheduled appointments for the Child under this provision without the advance written consent of the other party. 3. On a temporary basis during the course of psychiatric treatment for Katelyn as provided in the preceding paragraph, the physical custody schedule set forth in Paragraph 2 of the prior Order of this Court dated September 22, 2003 shall be suspended as it applies to Katelyn and replaced with the following: Katelyn shall primarily reside with the Father and the Mother shall have partial custody of Katelyn on alternating weekends from Friday after school through Monday before school (following the existing alternating sequence). In addition, during weeks following the Mother's weekend periods of custody, the Mother shall have custody of Katelyn from Thursday after school through Friday morning before school and, during weeks following the Father's weekend periods of custody, the Mother shall have custody of Katelyn from Monday after school through Tuesday before school. The temporary arrangements provided in this paragraph shall be adjusted depending upon the results of the psychiatric treatment. 4. The custody schedule set forth in Paragraph 2 of the prior Order of this Court dated September 22, 2003 shall continue in effect for Nathan, Spencer and Natalie. 5. Within 90 days of completion of Katelyn's treatment under this Order, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary to address custodial issues concerning Katelyn. 6. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, vin A. Hess J. cc: iz eth S. Beckley, Esquire - Counsel for Father n J. Connelly, Jr., Esquire - Counsel for Mother v 00 a3, DD? KAREN L. CONRAD Plaintiff vs. WILLIAM P. CONRAD Defendant Prior Judge: Kevin A. Hess CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3900 CIVIL ACTION LAW IN CUSTODY 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Katelyn M. Conrad Nathan P. Conrad Spencer N. Conrad Natalie L Conrad April 28, 1991 February 14, 1993 May 20, 1994 September 28, 2003 Mother/Father Mother/Father Mother/Father Mother/Father 2. A conciliation conference was held on February 10, 2005, with the following individuals in attendance: The Mother, Karen L. Conrad, with her counsel, John J. Connelly, Jr., Esquire, and the Father, William P. Conrad, with his counsel, Elizabeth S. Beckley, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date r Dawn S. Sunday, Esquire Custody Conciliator 1 NOV 2 3 2005 o KAREN L. CONRAD IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-3900 CIVIL ACTION LAW WILLIAM P. CONRAD Defendant IN CUSTODY ORDER OF COURT AND NOW, this 2 8 ' day of rJ 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated February 17, 2005 is vacated and replaced by the provisions of this Order and the prior Order of this Court dated September 22, 2003 which shall continue in effect. 2. The Mother, Karen L. Conrad, and the Father, William P. Conrad, shall have shared legal custody of Katelyn M. Conrad, born April 28, 1991, Nathan P. Conrad, born February 14, 1993, Spencer N. Conrad, born May 20, 1994, and Natalie I. Conrad, born September 28, 2003. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terns of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 3. The parties shall select a new psychiatrist for Katelyn to be further evaluated and receive focused psychiatric care to address her history of behavior and emotional problems. The parties shall select a professional by agreement who participates in the applicable insurance plan. Any costs of the evaluation/psychiatric care which are not covered by insurance shall be shared equally between the parties. The parties shall follow the recommendations of the psychiatrist with regard to the frequency and duration of sessions as well as the individuals who will be participating in each session. 4. The parties shall make arrangements for Katelyn to participate in counseling with Jamie Orris, LSW or other professional selected by agreement between the parties. The purpose of the counseling shall be to provide therapy in conjunction with the Child's psychiatric treatment. All costs of counseling which are not covered by insurance shall be shared equally between the parties. 5. Neither party shall cancel any scheduled appointments for Katelyn under this Order without the advance written consent of the other party. 0!: TI r A(,Y 2CO5 is! O' -49 c, 10 6. The parties shall participate in a weekly telephone call to share information concerning the Children. Unless otherwise agreed between the parties, the Mother shall initiate the weekly telephone calls to the Father every Sunday at 9:00 p.m. Unless otherwise agreed between the parties, all decision making exchanges of communication shall be conducted by e-mail. 7. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, A. Hess J. cc:vJbhn J. Connelly, Jr., Esquire - Counsel for Mother ,.'Nilliam P. Conrad, Father ?? IP- KAREN L. CONRAD Plaintiff vs. WILLIAM P. CONRAD Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3900 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Katelyn M. Conrad Nathan P. Conrad Spencer N. Conrad Natalie L Conrad April 28, 1991 February 14, 1993 May 20, 1994 September 28, 2003 Father Mother/Father Mother/Father Mother/Father 2. A custody conciliation conference was held on November 17, 2005, with the following individuals in attendance: The Mother, Karen L. Conrad, with her counsel, John J. Connelly, Jr., Esquire, and the Father, William P. Conrad, who is not represented by counsel in this matter. 3. Based upon discussions at the conference and the agreement of the parties that suspension of the September 22, 2003 Order would be temporary, the conciliator recommends an Order in the form as attached. aljzs Date Dawn S. Sunday, Esquire Custody Conciliator KAREN L. CONRAD Plaintiff/Petitioner V. WILLIAM P. CONRAD Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3900 CIVIL ACTION - LAW IN CUSTODY PETITION TO MODIFY EXISTING CUSTODY ORDER AND COMES NOW, Petitioner, Karen Lee Conrad, by and through her attorneys, James, Smith, Dietterick & Connelly, LLP by John J. Connelly, Jr., Esquire, and files the following Petition to Modify Existing Custody Order and in support thereof, respectfully represents as follows: The Petitioner is Karen Lee Conrad, Plaintiff in the above-captioned action, who currently resides at 108 Sgrignoli Lane, Enola, Pennsylvania 17025. The Respondent is William P. Conrad, Defendant in the above-captioned action, who currently resides at 138 Wyoming Avenue, Enola, Pennsylvania 17025. The parties are the parents of four minor children, Katelyn M. Conrad, born April 28, 1991, Nathan P. Conrad, born February 14, 1993, Spencer N. Conrad, born May 20, 1994 and Natalie I. Conrad, born September 28, 2000, who are subject of the existing Order and are currently equally sharing custody of the children based on a schedule more particularly set forth in the Order attached hereto and marked as Exhibit "A". 4. In November of 2005, the Petitioner advised the Respondent that the Petitioner and her husband had acquired a lot in the Cumberland Valley School District and would be building a home in that District. Petitioner informed Respondent that she wanted the parties youngest child Natalie to begin school in the Cumberland Valley School District. 5. The parties' minor child, Natalie I. Conrad, because of their relocation would be eligible to attend the Cumberland Valley School District beginning in kindergarten. Her older brothers and sisters referenced above who attend the East Pennsboro School District will be in middle school and high school when she begins kindergarten and would not be attending the school she attended. Her younger siblings to her current marriage, however, would be attending the Cumberland Valley School District at the same school when they became school age. Those children, Victoria Lewis, born May 17, 2003 and Lily Lewis, born August 11, 2004, are now ages 2 /z years and 16 months. Therefore, although she would never attend school with her older siblings at East Pennsboro School District if she attended the Cumberland Valley School District, she would attend school with her younger siblings. 6. Petitioner and Respondent have attended parenting therapy with Eugene Stecher at Guidance Associates with the hope of resolving the issue of where Natalie attends school. To date, the parenting therapy has proven fruitless and the Respondent adamantly has refused to cooperate with permitting Natalie to enroll in the Cumberland Valley School District for the upcoming 2006- 2007 school year. 7. All of the other parties' children would remain in the East Pennsboro School District until their graduation regardless of the relocation of the Petitioner's household. 8. The Petitioner is a stay at home mother and is available to transport her child, if necessary, to and from the Cumberland Valley School District as well as continuing to maintaining the older children at the East Pennsboro School District. 9. It is believed and therefore averred that because of the superior education available to her in the Cumberland Valley School District and because her younger siblings will attend school with her at some point in the future, it is in the child's best interest to begin the school year 2006- 2007 in the Cumberland Valley School District. 10. Because the parties share legal custody, the Court must make the determination as to where the child will attend school. WHEREFORE, your Petitioner, Karen Lee Conrad, requests that the Court grant that Natalie I. Conrad be enrolled in the Cumberland Valley School District. Respectfully submitted, JAMES, SMITH, DIE7TERICK & CONNELLY Date: (- S - (D(, By: squire o Aofonr nPelyti, tiJorn., eEr ise$ox 650 Hershey, PA 17033 (717) 533-3280 PA I.D. No. 15615 VERIFICATION I, Karen L. Conrad, verify that the statements made in the foregoing pleading are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. I -a y- o Date: Karen L. Conrad KAREN L. CONRAD : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 03-3900 WILLIAM P. CONRAD : CIVIL ACTION - LAW Defendant/Respondent : IN CUSTODY CERTIFICATE OF SERVICE 1, John J. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly LLP, attorney for the Petitioner, Karen Lee Conrad, hereby certify that I have served a copy of the foregoing Petition to Modify Existing Custody Order on the following on the date and in the manner indicated below: U.S MAIL FIRST CLASS. PRE-PAID William P. Conrad 138 Wyoming Avenue Enola, PA 17025 Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY Date: U G By: Post Office Box 650 Hershey, PA 17033 (717) 533-3280 PA I.D. No. 15615 J hnY foronne y, Jr., Esquire d me , EXHIBIT "A" CS E 1 20PS 03 KAREN L. CONRAD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-3900 CIVIL ACTION LAW WILLIAM P. CONRAD Defendant IN CUSTODY ORDER OF COURT AND NOW, this 2 a .,,,.e1 day of ? ? ?? 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall submit themselves, their minor Children, and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by Arnold Shienvold, PhD. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best serve the needs and interests of the Children. The parties shall sign all authorizations requested by the evaluator to obtain additional information pertaining to the parties and the Children. The Mother shall pay all costs of the evaluation initially but reserves the right to request that the Court allocate the costs between the parties in future proceedings. 2. Pending completion of the custody evaluation and agreement of the parties or further Order of Court, the parties shall share having legal and physical custody of Katelyn M. Conrad, born April 28, 1991, Nathan P. Conrad , born February 14, 1993, Spencer N. Conrad, born May 20, 1994, and Natalie I. Conrad, born September 28, 2003. The parties shall continue to follow the existing shared custody schedule under which the parties alternate having custody of the Children on weekends from Friday through Sunday, from Sunday through Tuesday and from Tuesday through Friday each week. 3. Within sixty days of receipt of the evaluator's custody recommendations, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary to assist the parties in establish ongoing custody arrangements. 4. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, s? d vin A. Hess J. cc: John J. Connelly, Jr., Esquire - Counsel for Mother Elizabeth S. Beckley, Esquire - Counsel for Father TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand rd the steal of said C at Ga.Lge, Pt. 'hire ?rday of? Prothonatard KAREN L. CONRAD, Plaintiff vs. WILLIAM P. CONRAD Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3900 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: I. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME Katelyn M. Conrad Nathan P. Conrad Spencer N. Conrad Natalie I. Conrad DATE OF BIRTH April 28, 1991 February 14, 1993 May 20, 1994 September 28, 2000 CURRENTLY IN CUSTODY OF Mother / Father Mother / Father Mother / Father Mother / Father 2. A Conciliation Conference was held on September 11, 2003 with the following individuals in attendance: The Mother, Karen L. Conrad, with her counsel, John J. Connelly, Jr., Esquire, and the Father, William P. Conrad, and his counsel, Elizabeth S. Beckley, Esquire. 3. The parties agreed to entry of an Order in the form as attached. 4. Although this is a newly filed custody matter, counsel advised the conciliator that Judge Hess has previously been involved in a related matter concerning the Mother's children from a prior marriage. Therefore counsel requested that this matter also be forwarded to Judge Hess due to his familiarity with the background of this family. Date- T Dawn S. Sunday, Esquire Custody Conciliator N ? O ?' ? O G ..° s- ?-- ..... ? --L ,. _-? KAREN L. CONRAD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIAM P. CONRAD DEFENDANT 03-3900 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, February 01, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, February 28, 2006 at 11:30 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. The court hereby directs the parties to furnish any and all existing; Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunday, Esq. j (] 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 30 I RE- CEIVE0 MAR 0 7 2C`KAREN L. CONRAD IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-3900 CIVIL ACTION LAW WILLIAM P. CONRAD Defendant IN CUSTODY ORDER OF COURT AND NOW, this r day of Ma cf , 2006, upon consideration of the attached Custody Conciliation Report, it is rdered and directed as follows: 1. The prior Orders of this Court shall continue in effect as modified by this Order. 2. The Mother may enroll Natalie Conrad, born September 28, 2000, in the Cumberland Valley School District, where the Mother resides, beginning in the 2006-2007 school year. 3. The parties shall exchange school related information pertaining to the Child or Children residing in his or her respective school districts with the other parent on a timely basis. The information to be exchanged under this provision shall include, but shall not be limited to, report cards, bus schedules, school related sports/activities schedules, parent-teacher conferences and major school events. BY THE COURT, cc: John J. Connelly, Jr., Esquire - Counsel for Mother William P. Conrad, Father ir•w? ?'?' 3 o S'. o 1 I I KAREN L. CONRAD Plaintiff vs. WILLIAM P. CONRAD Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3900 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 Natalie Conrad September 28, 2000 Mother/Father 2. A custody conciliation conference was held on February 28, 2006, with the following individuals in attendance: The Mother, Karen L. Conrad, with her counsel, John J. Connelly, Jr., Esquire. The Father, William P. Conrad contacted the conciliator on the morning of the conference to advise of his agreement to the Mother's request for modification in lieu of the Father's appearance at the conference. 3. The parties agree to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator i Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Defendant/Petitioner KAREN L. CONRAD, Plaintiff/Respondent V. WILLIAM P. CONRAD, Defendant/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-3900 CIVIL ACTION - LAW IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW, comes William P. Conrad, who, by and through his attorneys, Johnson, Duffle, Stewart & Weidner, files this Petition for Modification of Custody, in which he avers that: 1. Petitioner, William P. Conrad, is an adult individual residing at 138 Wyoming Avenue, Enola, Cumberland County, Pennsylvania 17025. 2. Respondent, Karen L. Conrad (now Lewis), is an adult individual residing at 5835 Heatherwood Court, Enola, Cumberland County, Pennsylvania 3. On September 22, 2003, the Honorable Kevin A. Hess entered a Custody Order giving the parties shared legal and physical custody of their 4 children: Katelyn M. Conrad, born April 28, 1991; Nathan P. Conrad, born February 14, 1993; Spencer N. Conrad, born May 30, 1994 and Natalie I. Conrad, born September 28, 2000. A true and correct copy of the Court's September 22, 2003 Order is attached hereto marked as Exhibit "A" and incorporated herein. 2. This Order should be modified because: A. Nathan P. Conrad has resided with Father since November, 2008. B. Spencer N. Conrad has resided with Father since April 5, 2009. C. Both boys are estranged from their Mother who has made no attempt to see them, call them, or appear at their sports activities. D. The Order should be modified to reflect the status quo as to Nathan P. Conrad and Spencer N. Conrad. E. Neither boy wants to resume the prior schedule. WHEREFORE, Petitioner believes it is in the best interests of the children for the Court to modify the existing Order to reflect that the Father has primary custody of Nathan P. Conrad and Spencer N. Conrad. Date: & WEIDNER :364153 ?? mernssa feel ureevy VERIFICATION I, William P. Conrad, do verify that the statements made in the foregoing Petition for Modification of Custody Order are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. 4g / 6'n? William P. Conrad Dated: CERTIFICATE OF SERVICE AND NOW, this 11 day of April, 2009, the undersigned does hereby certify that she did this date serve a copy of the Petition for Modification of Custody Order upon the other party of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: John J. Connelly, Jr., Esquire James, Smith, Dietterick & Connelly P. O. Box 650 Hershey, PA 17033 JOHNS FFIE, STEWART & WEIDNER By: W(-i -..u e?ffelidsa Peel Greevy ff-x4ikf A ?- ??p 2003 KAREN L. CONRAD, IN THE COURT OF COMMON PLEAS OF Plaintiff' CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-3900 CIVIL ACTION LAW WILLIAM P. CONRAD Defendant IN CUSTODY ORDER OF COURT AND NOW, this d-7,-A day of pp?,?,?,/.?. , 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall submit themselves, their minor Children, and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by Arnold Shienvold, PhD. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best serve the needs and interests of the Children. The parties shall sign all authorizations requested by the evaluator to obtain additional information pertaining to the parties and the Children. The Mother shall pay all costs of the evaluation initially but reserves the right to request that the Court allocate the costs between the parties in future proceedings. 2. Pending completion of the custody evaluation and agreement of the parties or fiuther Order of Court, the parties shall share having legal and physical custody of Katelyn M. Conrad, born April 28, 1991, Nathan P. Conrad , born February 14, 1993, Spencer N. Conrad, born May 20, 1994, and Natalie I. Conrad, born September 28, 2003. The parties shall continue to follow the existing shared custody schedule under which the parties alternate having custody of the Children on weekends from Friday through Sunday, from Sunday through Tuesday and from Tuesday through Friday each week. 3. Within sixty days of receipt of the evaluator's custody recommendations, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary to assist the parties in establish ongoing custody arrangements. 4. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, 1?e4in A. Hess J. cc: John J. Connelly, Jr., Esquire - Counsel for Mother Elizabeth S. Beckley, Esquire - Counsel for Father TRUE COPY FROM RECORD in Tummy who". f hen unto sd my hand and the seal of said Coupt at C&IL*S, pL My 47 jvc-o T071V 1?jif , IZ. 1ALyu- -A Prothonotsr l • KAREN L. CONR.AD, Plaintiff VS. WILLIAM P. CONRAD Defendant Prior Judge: Kevin A. Hess CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3900 CIVIL ACTION LAW IN CUSTODY 0 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Katelyn M. Conrad Nathan P. Conrad Spencer N. Conrad Natalie I. Conrad April 28, 1991 February 14, 1993 May 20, 1994 September 28, 2000 Mother / Father Mother / Father Mother / Father Mother / Father 2. A Conciliation Conference was held on September 11, 2003 with the following individuals in attendance: The Mother, Karen L. Conrad, with her counsel, John J. Connelly, Jr., Esquire, and the Father, William P. Conrad, and his counsel, Elizabeth S. Beckley, Esquire. 3. The parties agreed to entry of an Order in the form as attached. 4. Although this is a newly filed custody matter, counsel advised the conciliator that Judge Hess has previously been involved in a related matter concerting the Mother's children from a prior marriage. Therefore counsel requested that this matter also be forwarded to Judge Hess due to his familiarity with the background of this family. Date Dawn S. SundaY, Esquire U Custody Conciliator I RE- CEIVE0 MAR 0 7 K"I 1? KAREN L. CONRAD IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-3900 CIVIL ACTION LAW WILLIAM P. CONRAD Defendant IN CUSTODY ORDER OF COURT AND NOW, this r day of '2? a• c! , 2006, upon consideration of the attached Custody Conciliation Report, it is rdered and directed as follows: 1. The prior Orders of this Court shall continue in effect as modified by this Order. 2. The Mother may enroll Natalie Conrad, born September 28, 2000, in the Cumberland Valley School District, where the Mother resides, beginning in the 2006-2007 school year. 3. The parties shall exchange school related information pertaining to the Child or Children residing in his or her respective school districts with the other parent on a timely basis. The information to be exchanged under this provision shall include, but shall not be limited to, report cards, bus schedules, school related sports/activities schedules, parent-teacher conferences and major school events. BY THE COURT, cc: John J. Connelly, Jr., Esquire - Counsel for Mother William P. Conrad, Father -'Q 5', 0 L. 4- I F KAREN L. CONRAD Plaintiff vs. WILLIAM P. CONRAD Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3900 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 Natalie Conrad September 28, 2000 Mother/Father 2. A custody conciliation conference was held on February 28, 2005, with the following individuals in attendance: The Mother, Karen L. Conrad, with her counsel, John J. Connelly, Jr., Esquire. The Father, William P. Conrad contacted the conciliator on the morning of the conference to advise of his agreement to the Mother's request for modification in lieu of the Father's appearance at the conference. 3. The parties agree to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator ,{'')fit 7 THE: ,r 1"AR7 2i 09 PR 28 AM r r : 51 IU I 4'10.00 P Or/ CK- a.99 so ??1338 KAREN L. CONRAD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIAM P. CONRAD 2003-3900 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, May 04, 2009 __, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, June 04, 2009 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: /si Dawn S. Sunda Es . 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 OF THE i=l?-€? ?-t?E 2009 MAY --5 PM 3: 00 cuw v,AI)? 7 _} JUN 15 7009 G KAREN L. CONRAD IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2003-3900 CIVIL ACTION LAW WILLIAM P. CONRAD Defendant IN CUSTODY ORDER OF COURT AND NOW, this / 7' day of 2009, upon consideration of the attached Custody Conciliation Re ort, it is ordered and directed as follows: 1. The parties shall continue to share having legal custody of the Children and physical custody of Natalie pursuant to paragraph 2 of the prior Order of this Court dated September 22, 2003. 2. The Father shall have primary physical custody of Nathan and Spencer. 3. The Mother shall have partial physical custody of Nathan and Spencer, beginning Friday, June 19, 2009 from Friday at 3:00 p.m. through Sunday at 7:00 p.m. and every Wednesday, beginning June 10, 2009 from 4:30 p.m. when the Father shall transport the Children to the Mother's residence, until 8:30 p.m., when the Mother shall return the Children to the Father's residence. Unless otherwise agreed, the Father shall provide all transportation for exchanges of custody on weekends. The parties shall cooperate in making adjustments to the midweek period of custody by agreement to accommodate the Children's activities, if necessary. The parties agree that the Children may stay overnight at the Mother's residence during the midweek custodial period if they desire to do so. 4. The parties shall continue to share having custody of the Children on holidays in accordance with the established family custom. The parties shall communicate with each other directly concerning any changes or other issues related to the custody schedule. The parties shall not exchange messages or communicate through the Children. 5. The Mother shall ensure that the Children attend all of their regularly scheduled activities during her periods of custody. 6. The parties shall make arrangements for Nathan and Spencer to engage in counseling with Jamie Orris to address conflicts which have arisen within the family. The parties shall follow the recommendations of the counselor with regard to the parties' participation in the counseling sessions. All costs of the counseling which are not covered by insurance shall be shared equally between the parties. 7. After the family counseling has been initiated, counsel for either party may contact the conciliator within six months of the date of this Order to schedule a follow-up custody conciliation conference if necessary. 8. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, Kevin A. ess J. cc: ssaP. Greevy, Esquire - Counsel for Father J. Connelly, Jr., Esquire - Counsel for Mother jo?fi 1 ?? KAREN L. CONRAD Plaintiff vs. WILLIAM P. CONRAD Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2003-3900 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Nathan Conrad February 14, 1993 Father Spencer Conrad May 30, 1994 Father Natalie Conrad September 28, 2000 Mother/Father 2. A custody conciliation conference was held on June 4, 2009, with the following individuals in attendance: the Mother, Karen L. Lewis, formerly Conrad, with her counsel, John J. Connelly, Jr., Esquire, and the Father, William P. Conrad, with his counsel, Melissa Peel Greevy, Esquire 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator RLEC Ir -'..? OF 7HE IF'- 2009 AN Z 7 AH I0* 23 VVivIL" ?'?-)t?? f JAN 1 120%j KAREN L. CONRAD IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2003-3900 CIVIL ACTION LAW • r, Q WILLIAM P. CONRAD rn Defendant IN CUSTODY I-1 ORDER OF COURT ?_{ ru cil -? AND NOW, this /Z ' day of 11 ,1 e.., , 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated June 17, 2009 shall continue in effect as modified by this Order. 2. Pending further Order of Court or agreement of the parties, the Mother shall have partial physical custody of Nathan and Spencer on alternating weekends from Friday at 3:00 p.m. through the following Monday, when the Mother shall transport the Children to school. In addition, during the weeks following the Mother's weekend periods of custody, the Mother shall have custody of Nathan and Spencer on Thursday from 3:00 p.m. until 8:30 p.m. and during weeks following the Father's weekend periods of custody, the Mother shall have custody on Tuesday from 3:00 p.m. until 8:30 p.m. This amended schedule shall begin on Tuesday, January 12, 2010. The Mother's periods of custody with Natalie shall continue pursuant to the prior Orders. 3. The Mother shall provide transportation for all exchanges of custody for Spencer and Nathan as set forth in the prior paragraph with the exception of the return exchanges on weekday evenings at 8:30 p.m., for which the Father shall be responsible to provide transportation. 4. The parties shall ensure that the Children attend all of their regularly scheduled activities during each party's period of custody. 5. The parties shall share having physical custody of all three Children on the following holidays: New Year's Day, Easter, Memorial Day, July Fourth, Labor Day, Thanksgiving, and Christmas. The parent who has custody of Natalie during the overnight before the holiday shall have custody of all three Children from 9:00 a.m. until 2:00 p.m. on the day of the holiday and the other parent shall have custody from 2:00 p.m. until 7:00 p.m. on the holiday. 6. Each parent shall be entitled to have two vacation periods with the Children each year upon providing reasonable notice to the other parent. 7. Within four months of the date of this Order, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference if necessary. 8. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, Kevin A. Hiss J. cc: elissa P. Greevy, Esquire - Counsel for Father ?rohn J. Connelly, Jr., Esquire - Counsel for Mother 06? es en :a t LL // 4to -- 1 KAREN L. CONRAD Plaintiff vs. WILLIAM P. CONRAD Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2003-3900 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Nathan Conrad February 14, 1993 Father Spencer Conrad May 30, 1994 Father Natalie Conrad September 28, 2000 Mother/Father 2. A custody conciliation conference was held on January 7, 2010, with the following individuals in attendance: the Mother, Karen L. Lewis, formerly Conrad, with her counsel, John J. Connelly, Jr., Esquire, and the Father, William P. Conrad, with his counsel, Melissa Peel Greevy, Esquire. 3. The parties agreed to entry of an Order in the form as attached. J G?'lc?cyn-L? t ob 6-0a.'? Date Dawn S. Sunday, Esquire Custody Conciliator