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HomeMy WebLinkAbout07-4218GREGORY J. SHEAFFER & SONYA L. SHEAFFER Plaintiffs v. CRYSTAL L. WILLS & CHARLES M. CUSTER, JR. Defendants COMPLAINT FOR CUSTODY 1. The plaintiffs are Gregory J. & Sonya L. Sheaffer, who reside at 35 St. Johns Road, Cumberland County, Camp Hill, Pennsylvania 17011. 2. The defendants are Crystal L. Wills and Charles M. Custer, Jr., who reside at 155 Salem Church Road, Lot #26, Mechanicsburg, Cumberland County, Pennsylvania 17050. . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA . No. 07 - t{~~~ CIVIL TERM . IN CUSTODY 3. Plaintiffs seek custody of the following child: Name Gabriel Ash Custer Present Residence 35 St. Johns Road Camp Hill, PA DOB Awe 9-12-06 10 months The child was born out of wedlock The child is presently in the custody of Gregory J. & Sonya L. Sheaffer, who reside at 35 St. Johns Road, Cumberland County, Camp Hill, Pennsylvania 17011. During the past five years, the child has resided with the following persons and at the following addresses: All Person All Addresses Dates Crystal L. Wills & Charles M. Custer, Jr Nancy Clark (Friend) 155 Salem Church Road Lot #26 Mechanicsburg, Pa 124 Manor Street Enola, Pa Birth to Feb. 27, 2007 Feb. 27, 2007 to Apr. 4, 2007 Gregory J. & Sonya L. 35 St. Johns Road Apri14, 2007 to present Sheaffer Camp Hill, Pa 4 5. 6. 7 8. 9 The mother of the child is Crystal L. Wills, who resides at 155 Salem Church Road, Lot #26, Mechanicsburg, Cumberland County, Pennsylvania 17050. The father of the child is Charles M. Custer, Jr., who resides at 155 Salem Church Road, Lot #26, Mechanicsburg, Cumberland County, Pennsylvania 17050. She is not married. He is not married. The relationship of plaintiffs to the child is that of Paternal Grandparents. The plaintiffs currently reside with the following persons. Names Gabriel Ash Custer Relationship Grandson The relationship of defendants to the child is that of Mother and Father. The defendants currently reside with the following persons. Name Relationship Betty Bobb Mother's Grandmother Lonnie Bobb Mother's Mother Plaintiffs have 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. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiffs do not know of a person not a party to the proceedings that has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiffs has undertaken and performed the primary parental responsibilities for the child. Plaintiffs are best able to provide the care and nurture which the child needs for healthy development. Plaintiffs desire to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. WHEREFORE, Plaintiffs requests this Honorable Court grant Plaintiffs primary physical custody subject to structured visitation in Defendants as agreed upon by the parties. Respectfully submitted, Rominger & Associates Date: ~ I ~G ~~ ~ ~ ~~C~ -J `~ ~G ~ ~ Michael O. Palermo, Jr., Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Gregory Sh r, laint' nya L. heaffer, P ai tiff GREGORY J. SHEAFFER & IN THE COURT OF COMMON PLEAS OF SONYA L. SHEAFFER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs . v. - No. 07 - u~- CIVIL TERM CRYSTAL L. WILLS & CHARLES M. CUSTER, JR. Defendants IN CUSTODY STIPULATION AGREEMENT AS TO CUSTODY The Plaintiffs, Gregory J. Sheaffer and Sonya L. Sheaffer, hereinafter referenced as "Grandparents," and Defendants, Crystal L. Wills and Charles M. Custer, Jr., hereinafter referenced as "Mother & Father," hereby agree to the entry of the following terms in a Court Order defining legal/sole custody rights and responsibilities in relation to the parties' minor child, Gabriel Ash Custer, born September 12, 2006, hereinafter referenced as "Child": 1. The parties hereto agree that the best interest and continuing welfare of the Child would be best served with the custody arrangement as follows: (a) Grandparents will have sole legal custody of Child as defined in 23 Pa. C.S.A. §5302. All decisions affecting the Child's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Grandparents shall make. (b) Grandparents shall have sole legal and primary physical custody of the Child. (c) Mother and Father shall have periods of visitation as agreed upon by the parties. 2. Each party shall have reasonable telephone and a-mail access to the Child and Grandparents will correspond with parents regarding minor child's health, welfare, educational and other developments of the child. 3. The parties shall keep each other advised immediately relative to any emergencies concerning the Child and shall further take any necessary steps to ensure that the health, welfare and well being of the Child are protected. The parties shall do nothing that may estrange the Child from the other party or hinder the natural development of the Child's love or affection for the other party. 4. Each party shall not make any disparaging remarks or allow others to make any disparaging remarks concerning the Child's parents in front of the Child. 5. Grandparents will have full responsibility for all final decisions for the minor child in all matters to include, but not limited to: medical care, educational needs, social gatherings for the minor and visitations with any parties outside of the primary residence, currently at 35 Saint Johns Road, Camp Hill, Pennsylvania, with that the primary residence can and may change with the needs and desires of the custodial Grandparents without notification to any parties outside of this agreement. 6. Visitation for parents with minor child at the primary residence will not be hindered, provided sufficient verbal and direct notification has been given to grandparents and will be at the conveniences of the Grandparents. Any visitations outside the primary residence, to include, but not limited to, trips, visitations to other residences or locations and family or friends, must be approved by grandparents. A minimum notification for any outside the primary residence visits must be 5 (five) days prior to the planned visitation. (At time of notification, Grandparents shall be given the following: to include, but not limited to: destination(s) and location(s), length of stay/visit and names of any other parties involved with or interacting with minor child during said visitation.) 7. Grandparents reserve the right to inspect residences or locations that occur outside the primary residence visitations. Grandparents may make inquiries to those interacting with minor child. 8. Grandparents have full legal right to make major decisions affecting the minor child, including but not limited to: authorization for major medical or psychiatric care; educational placement; and religious training. Grandparents have the right to receive and inspect all school and medical records. Grandparents will be responsible for taking the minor child to any regularly scheduled medical or dental appointments and for handling any medical and dental emergencies. In an emergency situation, the permissions of both grandparents and parents are unnecessary. 9. Grandparents agree to keep in effect the family health insurance policy provided by his/her employer and agrees to maintain health care benefits at least equivalent to those that existed on the date of this agreement. Grandparents agree to pay all medical and dental costs not covered by insurance or public assistance that the child is entitled to at current. If minor child needs orthodontic work grandparents agree to pay 50% of costs .with the remaining 50% incumbent upon parents. 10. Grandparents do reserve the right as custodial grandparents to fully adopt and assume minor child, Gabriel Ash Custer through further legal remedies if deemed necessary on any future date and time. This matter would be discussed with parents before any litigation or court actions begin. Discretion reverts solely to Grandparents as to the necessity and demand for such procedures. However, the Court of Common Pleas of Cumberland County may ultimately decide these issues. 11. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. 12. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 13. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. 14. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. Consented to: ~Z ~ Date _~ Date 7-~~-~ ~7 Date 7-~~_G~ Date t~. ~i ~~ G,f'~ Michael O. Palermo, Jr. Esquire for Plaintiffs ~•~ Crys L. Wills, Defendant Date Charles M. Custer, Jr., Defendant ~~ •)~~ C `^` V \r `V ~i r"' ; t'": ea c~ f C=i C.V t„' ~~~ w~ ! i3 tTi ~~ ~.. ~ -i ~.fl~ ~1 ./~'~ GREGORY J. SHEAFFER & IN THE COURT OF COMMON PLEAS OF SONYA L. SHEAFFER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs . v. No. 07 -~~ CIVIL TERM CRYSTAL L. WILLS & CHARLES M. CUSTER, JR. Defendants IN CUSTODY ORDER OF COURT ~~ AND NOW, this ~.~ day of ~ ~` 2007 consideration of the within Complaint and the Stipulation and Agreement incorporated therein, and upon agreement of the parties, it is hereby ordered and decreed as follows: 1. The parties hereto agree that the best interest and continuing welfare of the Child would be best served with the custody arrangement as follows: (a) Grandparents, Gregory J. Sheaffer and Sonya L. Sheaffer, will have sole legal custody of Child as defined in 23 Pa. C.S.A. X5302. All decisions affecting the Child's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Grandparents shall make. (b) Grandparents shall have sole legal and primary physical custody of the Child. (c) Mother and Father, Crystal L. Wills and Charles M. Custer, Jr., shall have periods of visitation as agreed upon by the parties. 2. Each party shall have reasonable telephone and a-mail access to the Child. 3. The parties shall keep each other advised immediately relative to any emergencies concerning the Child and shall further take any necessary steps to ensure that the health, welfare and well being of the Child are protected. The parties shall do nothing that may estrange the Child from the other party or hinder the natural development of the Child's love or affection for the other party. 4 5 6. 7 Each party shall not make any disparaging remarks or allow others to make any disparaging remarks concerning the Child's pazents in front of the Child. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. -~ Distribution: ~hael O. Palermo, Jr., Esquire ~stal L. Wills & Chazles M. Custer, Jr. J . !' ~ o7-~-a i' '~~ r.''1 i 4 ~~._ ~~ PJ.. n 7 ~j1147 ~v~~,.J _. ~ ~1~. ,' ~~M~ 2010 JAN -7 AM i i ~ 04 GREGORY J. SHEAFFER & SONYA L. SHEAFFER, Plaintiffs/Respondents CUP~_ ' ~~,=~.~~t'~? tom'°vIV~'Y Pr.^JivSYL~Ir'~I~1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA, vs. CRYSTAL L. WILLS (HERSHBERGER) CHARLES M. CUSTER, JR., Defendant/Petitioner NO.: 07-4218 CIVIL TERM IN CUSTODY PETITION FOR MOD{FICATION OF CUSTODY 1. The Petitioner is Crystal L. Wills (Hershberger), now married and residing at 6606 Carlisle Pike, Silver Spring Township, Cumberland County, Mechanicsburg, Pennsylvania 17050. 2. The Respondents are Gregory and Sonya Sheaffer, who reside at 35 St. John's Road, Cumberland County, Camp Hill, Pennsylvania 17011. 3. On or about July 14, 2007, Petitioner was provided a legal document by the Respondent's Attorney requesting that an Agreement as to custody be executed. At that time, Petitioner had no legal counsel nor was told to seek legal counsel prior to executing that document. (See Attached and Marked as Petitioner Exhibit "A") 4. At the time Petitioner executed the above referenced document, she was without the benefit of Counsel; 18 years of age; new un-wed mother; and was suffering from some emotional health problems. 70. oa ~- G~-~ssr~ 5. Petitioner was un-aware that she entered into an Agreement handing over Sole Legal Custody of her child to the Co-Respondent's. On January 5, 2010, Co-Respondent's informed Petitioner that they were moving out of state, to California, in February 2010 and that the child will be moving with them to California. Furthermore, they stated that Mother will "never see her child again" and that they are in the process of terminating her Parental Rights. 6. Petitioner was married on or about November 13, 2007, and lives in the local area. However, Respondent's have consistently refused to allow her periods of visitation per the prior Order of Court dated July 23, 2007. (See Attached and Marked as Petitioner's Exhibit "B") WHEREFORE, the Petitioner requests a Modification of the existing unilateral Custody Order whereby she would be awarded Joint Legal Custody and specified periods of Partial Physical Custody of her minor child. Finally, Petitioner is respectfully requesting that this Honorable Court Order the Respondents to remain in the Jurisdiction. of Cumberland County until such time when a Conciliation Hearing can be scheduled before this Court. Date: ~ to ~ D Respectfully Submitted, By: Paul Bradford Orr, Esquire Attorney for Defendant/Petitioner 50 East High Street Carlisle, PA 17013 (717) 258-8558 PA Court ID # 71786 VERIFICATION l verify that the statements made in the foregoing Petition are true and correct. 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: ~ "! ~~ C L. Her berger, Petitioner GREGORY J. SHEAFFER & IN THE COURT OF COMMON PLEAS OF SONYA L. SHEAFFER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs . v. - No. 07 - u~- CIVIL TERM CRYSTAL L. WILLS & CHARLES M. CUSTER, JR. . Defendants IN CUSTODY STIPULATION AGREEMENT AS TO CUSTODY The Plaintiffs, Gregory J. Sheaffer and Sonya L. Sheaffer, hereinafter referenced as "Grandparents," and Defendants, Crystal L. Wills and Charles M. Custer, Jr., hereinafter referenced as "Mother & Father," hereby agree to the entry of the following terms in a Court Order defining legal/sole custody rights and responsibilities in relation to the parties' minor child, Gabriel Ash Custer, born September 12, 2006, hereinafter referenced as "Child": The parties hereto agree that the best interest and continuing welfare of the Child would be best served with the custody arrangement as follows: (a) Grandparents will have sole legal custody of Child as defined in 23 Pa. C.S.A. §5302. All decisions affecting the Child's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Grandparents shall make. (b) Grandparents shall have sole legal and primary physical custody of the Child. (c) Mother and Father shall have periods of visitation as agreed upon by the parties. 2. Each party shall have reasonable telephone and a-mail access to the Child and Grandparents will correspond with parents regarding minor child's health, welfare, educational and other developments of the child. 3. The parties shall keep each other advised immediately relative to any emergencies Petitioner's Exhibit „A,~ concerning the Child and shall further take any necessary steps to ensure that the health, welfare and well being of the Child are protected. The parties shall do nothing that may estrange the Child from the other party or hinder the natural development of the Child's love or affection for the other party. 4. Each party shall not make any disparaging remarks or allow others to make any dispazaging remarks concerning the Child's pazents in front of the Child. 5. Grandparents will have full responsibility for all final decisions for the minor child in all matters to include, but not limited to: medical care, educational needs, social gatherings for the minor and visitations with any garties outside of the primary residence, currently at 35 Saint Johns Road, Camp Hill, Pennsylvania, with that the primary residence can and may change with the needs and desires of the custodial Grandparents without notification. to any parties outside of this agreement. 6. Visitation for pazents with minor child at the primary residence will not be hindered, provided sufficient verbal and direct notification has been given to grandparents and will be at the conveniences of the Grandparents. Any visitations outside the primary residence, to include, but not limited to, trips, visitations to other residences or locations and family or friends, must be approved by grandparents. A minimum notification for any outside the primary residence visits must be 5 (five) days prior to the planned visitation. (At time of notification, Grandpazents shall be given the following: to include, but not limited to: destination(s) and location(s), length of staylvisit and names of any other parties involved with or interacting with minor child during said visitation.) 7. Grandparents reserve the right to inspect residences or locations that occur outside the primary residence visitations. Grandparents may make inquiries to those interacting with minor child. 8. Grandparents have full legal right to make major decisions affecting the minor child, including but not limited to: authorization for major medical or psychiatric care; educational placement; and religious training. Grandparents have the right to receive and inspect all school and medical records. Grandparents will be responsible for taking the minor child to any regulazly scheduled medical or dental appointments and for handling any medical and dental emergencies. In an emergency situation, the permissions of both grandparents and parents are unnecessary. 9. Grandparents agree to keep in effect the family health insurance policy provided by his/her employer and agrees to maintain health care benefits at least equivalent to those that existed on the date of this agreement. Grandparents agree to pay all medical and dental costs not covered by insurance or public assistance that the child is entitled to at current. If minor child needs orthodontic work grandparents agree to pay 50% of costs .with the remaining 50% incumbent upon parents. 10. Grandparents do reserve the right as custodial grandparents to fully adopt and assume minor child, Gabriel Ash Custer through further legal remedies if deemed necessary on any future date and time. This matter would be discussed with parents before any litigation or court actions begin. Discretion reverts solely to Grandpazents as to the necessity and demand for such procedures. However, the Court of Common Pleas of Cumberland County may ultimately decide these issues. 11. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. 12. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 13. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. 14. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. Consented to: ~i ~ Date ~. Date Date Michael O. Palermo, Jr. Esquire for Plaintiffs ~-~y-~2 ~.~, Date Crys L. Wills, Defendant Date Charles M. Custer, Jr., Defendant ca ~~~ `~... +++. ~ ~ ~~ hQ V -J r;~ i `. 4-.`. ', ._., c ~' ~.: _. ~..~ ~, -r~ r~i~ ?,`~''.i _~~ :~s~ ~, i +" 1 .~~ GREGORY J. SHEAFFER & IN THE COURT OF COMMON PLEAS OF SONYA L. SHEAFFER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. No. 07 -~Z~CIVIL TERM CRYSTAL L. WILL5 & . CHARLES M. CUSTER, JR. . Defendants IN CUSTODY ORDER OF COURT t~ AND NOW, this '1.3 day of ~v1 2007 consideration of the within Complaint and the Stipulation and Agreement incorporated therein, and upon agreement of the parties, it is hereby ordered and decreed as follows: 1. The parties hereto agree that the best interest and continuing'welfare of the Child would be best served with the custody arrangement as follows: (a) Grandparents, Gregory J. Sheaffer and Sonya L. Sheaffer, will have sole legal custody of Child as defined in 23 Pa. C.S.A. X5302. AlI decisions affiecting the Child's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Grandparents shall make. (b) Grandparents shall have sole legal and primary physical custody of the Child. (c) Mother and Father, Crystal L. Wills and Charles M. Custer, Jr., shall have periods of visitation as agreed upon by the parties. 2. Each party shall have reasonable telephone and a-mail access to the Child. 3. The parties shall keep each other advised immediately relative to any emergencies concerning the Child and shall further take any necessary steps to ensure that the health, welfare and well being of the Child are protected. The parties shall do nothing that may estrange the Child from the other party or hinder the natural development of the Child's love or affection for the other party. Petitioner's Exhibit ~~ B., .~r 4. Each party shall not make any disparaging remarks or allow others to make any disparaging remarks concerning the Child's parents in front of the Child. 5. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 7. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. ~',~'~_ Distribution: ~hael O. Palermo, Jr., Esquire ~stal L. Wills & Charles M. Custer, Jr. J . ~~~ O ~~~~ L ~! ~~; r..` :fly ~~~ ~~ ~~C ~~~~~ J•,j ia. GREGORY J. SHEAFFER & SONYA L. W THE COURT OF COMMON PLEAS OF SHEAFFER PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA ~'. CRYSTAL L. HERSHBF.RGER (WILLS) DEFENDANT • 2007-4218 C:1VIL ACTION LAW TN CUSTODY ORDER OF COURT AND NOW, Monday, January 11, 2010 _, 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 Monday, February. 08, 2010 _ at 2:00 PM for aPre-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. >3y: /s/ Dawn S. Sunda Es . Custody Conciliator "fhe 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 7? hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD "T'AKE THIS PAPER TO YOUR A'C"T'ORNEY A"f ONCE. IF YOU DO NOT HAVE AN ATTORNEY OK CANNOT AFFOKD ONE, GO T'O OR TELEPHONE THE OFFICE SE"1' FORTH BELOW TO F[ND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 "Telephone (717} 249-3166 ~l~.f ~~ 1 ~ ~u {.;r. ~" f f ,1' Z~~~ J~~ ~ ~ ~~ ~~ ~~ ~t:~~~ ~ ~. ±`~iT~f ~~ v.~'~'~3it, !'+'i ~~~~?~ . y.... ~e o i 200 ~ Z GREGORY J. SHEAFFER and IN THE COURT OF COMMON PLEAS OF SONYA L. SHEAFFER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. 2007-4218 CIVIL ACTION LAW CRYSTAL L. HERSHBERGER (WILLS) Defendant IN CUSTODY ORDER OF COURT AND NOW, this 1 S~ day of ~ ~ c y w~y 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: Order. 1. The prior Order of this Court dated July 23, 2007 shall continue in effect as modified by this 2. The Mother shall schedule supervised periods of visitation with the Child through the YWCA, or other agency agreed upon between the parties, to occur one time per week for as much time at each visit as permitted by the YWCA. The Paternal Grandparents shall provide transportation for the Child to and from periods of supervised visitation. The Mother shall notify the conciliator through her counsel as to the date of the first period of visitation and the conciliator shall schedule afollow-up custody conciliation conference to take place promptly following the sixth consecutive weekly period of visitation. All costs of the visitation shall be paid by the Mother. The Paternal Grandparents shall cooperate in making the Child available for periods of visitation. 3. In the event the Mother misses a scheduled period of supervised visitation, without providing notice of justifiable extenuating circumstances, the Paternal Grandparents may terminate the visitation schedule and a custody conciliation conference may be scheduled at the request of either parry at that time. 4. No party shall do or say anything which may estrange the Child from any other party, injure the opinion of the Child as to the other parties, or hamper the free and natural development of the Child's love and respect for any other party. All parties shall ensure that third parties having contact with the Child comply with this provision. c:~ ~ ; (' ~ _ _.l _ C~ ~" f .. ~.,,.~ ~~ P "(` ~ 1'7 C ~ '' ~_ti[ ~:--' ~* _-i L . ~. 5. 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, M. L. Ebert, Jr. J. cc: ul B. Orr, Esquire -Counsel for Mother ~egory and Sonya Sheaffer -Paternal Grandparents ~ Charles Custer -Father x~~.~~v .~ GREGORY J. SHEAFFER and SONYA L. SHEAFFER Plaintiff vs. CRYSTAL L. HER5HBERGER (WILLS) Defendant Prior Judge: M.L. Ebert, Jr. 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007-4218 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 Gabriel Ash Custer September 12, 2006 Paternal Grandparents 2. A custody conciliation conference was held on January 28, 2010, with the following individuals in attendance: the Mother, Crystal L. Wills, formerly Hershberger, with her counsel, Paul Orr, Esquire, and the Paternal Grandparents, Gregory and Sonya Sheaffer, who were not represented by counsel at the conference. According to the Paternal Grandparents, the Father, Charles Custer, is currently serving in the Marines and is not willing to provide his address to the Mother at this time. They requested that the Father's copy of the agreed upon Order be provided to the Father through their home address. 3. The parties agreed to entry of an Order in the form as attached. _ ,) ~~ ~ 9 oloi d Date Dawn S. Sunday, Esqui Custody Conciliator