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HomeMy WebLinkAbout07-6118 Saundra J Bloser, In the Court of Common Pleas Plaintiff Cumberland County, Pennsylvania V No e7- (-J19 efl;a -Til. Wesley L Bloser, Civil Action - Law Defendant In Custody COMPLAINT FOR CUSTODY 1. The Plaintiff Saundra J Bloser residing at 329 North Mountain Road, Newville, Cumberland County, Pennsylvania 17241 2. The Defendant is Wesley L Bloser residing at 20 Blain McCrea Road, Newville, Cumberland County, Pennsylvania 17241. 3. Plaintiff seeks custody of the following children: Children Date of Birth Cody Lynn Bloser April 1 1990 Colton Lynn Bloser February 22 1993 The children were not born out of wedlock. The children have been in the primary custody of Defendant. During the past five years, the children have resided with the following persons and at the following addresses: NAME RESIDENCE DATES Mother and Father 20 Blain McCrea Road birth to present Newville PA 17241 The mother of the child is Saundra J Blower, Plaintiff, and she is married to Defendant, Wesley L Bloser. 4. The relationship of Plaintiff to the child is that of Mother. Plaintiff currently resides alone. 5. The relationship of Defendant to the child is that of Father currently residing with the subject minor children. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 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 interests and permanent welfare of the children will be served by granting the relief requested because if there ever was a case in the history of mankind wherein the defacto custodial parent created the most outrageous and offensive situation involving the minor children and their mother, this is the one, and further: a. Defendant has embarked upon a deliberate course of alienation; b. Defendant has used the children as pawns in the domestic matters between the parties; 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene. None. WHEREFORE, Plaintiff requests the court to grant the relief herein requested. Respectfully submitted, MILLER LIPSITT LLC ms's i er, Esquire i rth 21St Street D Hill, PA 17011 7) 737-6400 VERIFICATION I verify that the statements made in the foregoing To !i, V 61m,-A /- SAP 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. r? Date: Co r -z) 07 Saundra J Bloser 1V_ - na a T.1 + al yc e ` SAUNDRA J. BLOSER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2007-6118 CIVIL ACTION LAW WESLEY L. BLOSER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, October 24, 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, November 14, 2007 at 10:00 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. 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/ ohn . 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 jO" *4w SC :Z Wd ?Z 100 LOOZ A'dViON6HI ' d -3141 J0 M .. .6 NOV 2 2007 if SAUNDRA J. BLOSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-6118 Civil Term WESLEY L. BLOSER Defendant : ACTION IN CUSTODY COURT ORDER AND NOW, this 1i day of November, 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: This Order is entered pursuant to a Custody Conciliation Conferenc A Custody Hearing is hereby scheduled on the .lD? day of at ,16 aiOpm in Courtroom number __ in the Cumberlan County Court of Common Pleas, Carlisle, PA 17013 at which time testimony will be taken related to the sole issue of whether Cody Bloser should be court ordered to attend counseling. For purposes of this hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the hearing date. 2. The Father, Wesley Bloser, and the Mother, Saundra Bloser, shall enjoy shared legal custody of Cody L. Bloser, born 4/01/90 and Colton Bloser, born 2/22/93. The parties agree that major non-emergency decisions concerning the Children's health, welfare, education and religion shall be made by them jointly, after discussion and consultation with the other, with a view toward obtaining and following a harmonious policy in the Children's best interest. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children 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. The Father shall have primary physical custody of Cody and Colton Bloser subject to Mother's partial physical custody as follows. Mother shall have custody/visitation with and Colton Bloser one evening per week from 6:00 pm until 8:00 pm at a neutral public location. Said visitation shall commence 11 / 19/07, then again on 11/29/07 and thereafter commencing 12/5/07 every p 1 ? 4Q :,q tg l ? +4 P ?. .. Wednesday. Father shall provide transportation for said exchanges at the agreed upon location. The parties may modify this paragraph by mutual consent. 4. The Parties are directed to initiate family counseling pertaining to Colton Bloser with a mutually agreeable counselor. The Parties are directed to comply with the counselor's recommendations. The cost of the counseling, after any appropriate payment through insurance for the parties, shall be split equally between the parties. 5. Telephone contact between the Children and the non-custodial parent shall be liberal as agreed upon between the parties. It is directed that both parents shall communicate with one another regarding the custody matter and to not involve the Children in said communications. 6. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. 8. The parties may modify this Order by mutual agreement in writing. In the absence of mutual consent, the terms of this Order shall control. 9. An update conciliation conference is scheduled for February 19, 2008 at 9:00 am before the assigned Conciliator at the Court of Common Pleas of Cumberland County, Carlisle, PA 17013. 10. Counsel for the parties are directed and allowed to request this matter to be removed from the scheduled hearing date if appropriate. BY THE COURT, J. Cc: nstopher Smull, Esq., 210 Grandview Avenue, Ste 102, Camp Hill, PA 'es Miller, Esq., 765 Poplar Church Rd., Camp Hill, PA 17011 Jeer m J. Mangan, Esq. 17011 1 SAUNDRA J. BLOSER, Plaintiff V. WESLEY L. BLOSER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 07-6118 Civil Term : ACTION IN CUSTODY CONCII.IATION 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 children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Cody L. Bloser 04/01/90 Primarily Father Colton L. Bloser 02/22/93 Primarily Father 2. A Conciliation Conference was held on November 14, 2007 with the following individuals participating: The Father, Wesley L. Bloser, with his counsel, Kristopher Smull, Esquire The Mother, Saundra J. Bloser, with her counsel, James Miller, Esquire. 3. Father's position on custody is as follows: The parties agreed to the legal and physical custody as outlined in the attached proposed Order. The point of contention is whether or not it is appropriate for Cody Bloser should attend counseling. Father acknowledges that Cody has some anger issues related to Cody's relationship with Mother but does not feel counseling is necessary and does not feel that he can force Cody to attend. Cody will be 18 on April 1, 2008 and refuses to attend counseling, neither individual counseling or family counseling with Mother. 4. Mother's position is as follows: The parties agreed to the legal and physical custody as outlined in the attached proposed Order. The point of contention is whether or not it is appropriate for Cody Bloser should attend counseling. Mother indicates that Cody has severe anger issues toward her and life in general and requests that Cody be ordered to attend counseling. 5. The Conciliator recommends an Order in the form as attached scheduling a Hearing pertaining to the sole issue of whether Cody Bloser should be court ordered to attend counseling and entering an Order of Court It is the Conciliator's belief that this would be in the Children's best interest. It is 4 , k expected that the Hearing will require half a day. 6. The proposed recommended Order may contain a requirement that the parties file a pre-trial memorandum with the Judge to whom the matter has been assigned. Date: November 18, 2007 Jo angan, Esq ' e Cu o Conciliator -r Saundra J Bloser, In the Court of Common Pleas Plaintiff Cumberland County, Pennsylvania V No 07-6118 Wesley L Bloser, Civil Action - Law Defendant In Custody PRAECIPE TO WITHDRAW REQUEST FOR HEARING TO THE PROTHONOTARY: Kindly strike Plaintiff's request for a hearing and the hearing scheduled thereon for February 20, 2008, at 1:30 pm and mark it as withdrawn leaving in place all other terms and conditions set forth in the Order of Court dated November 23 2007. Respectfully submitted, MILLER LIPSITT LLC Jame A. Miller, Esquire 76 oplar Church Road amp Hill, PA 17011 (717) 737-6400 x,. Saundra J Bloser, In the Court of Common Pleas Plaintiff Cumberland County, Pennsylvania V No 07-6118 Wesley L Bloser, Civil Action - Law Defendant In Custody CERTIFICATE OF SERVICE I hereby certify that I have forwarded a copy of the foregoing Praecipe to the persons at the addresses listed below on the date herein. Date: Tuesday, February 05, 2008 Honorable Wesley Oler, Jr Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Kristopher T Smull, Esquire Maria P Cognetti & Associates 210 Grandview Ave Ste 102 Camp Hill, PA. 17011-1706 J es A. Miller, Esquire 65 Poplar Church Road Camp Hill, PA 17011 (717) 737-6400 t-,3 CCU czk 5 } rrt €~r it . P;. -D 9P --1 11 1 J. BLOSER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-6118 Civil Term WESLEY L. BLOSER Defendant : ACTION IN CUSTODY Prior Judge: J. Wesley Oler, Jr. COURT ORDER AND NOW, this P.?day of February, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. The prior Order of Court dated November 23, 2007 shall remain in full force and effect with the exception that the custody hearing scheduled for February 20, 2008 is CANCELLED. 2. A telephone conference is hereby scheduled for March 25, 2008 at 1:00 pm to be coordinated by the assigned conciliator. The purpose of this conference is to ascertain how Mother's trip to Florida went with Colton Bloser and to determine whether increased time for Mother's custodial periods with Colton would be in his best interest. 3. 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, .1-? J. Cc: sto her Smull, Esq., 210 Grandview Avenue, Ste 102, Camp Hill, PA 17011 es Miller, Esq., 765 Poplar Church Rd., Camp Hill, PA 17011 ,46Fm J. Mangan, Esq. % 3)- (Y J 9 o/ 0 ¢ C D C%j C\ j {.? LLJ _t...s. „-. ' LA- , { r Ll- CY7 J ® c:a Jy C14 } ,R SAUNDRA J. BLOSER, Plaintiff V. WESLEY L. BLOSER Defendant Prior Judge: J. Wesley Oler, Jr. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 07-6118 Civil Term : ACTION IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Cody L. Bloser 04/01/90 Primarily Father Colton L. Bloser 02/22/93 Primarily Father 2. A Conciliation Conference was held on November 14, 2007 and an Order of Court dated November 23, 2007 was entered. An update conciliation conference was held February 19, 2008 with the following individuals participating: The Father, Wesley L. Bloser, with his counsel, Kristopher Smull, Esquire The Mother, Saundra J. Bloser, with her counsel, James Miller, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date: -Z Jo gan, Esquire C tod Conciliator s a SAUNDRA J. BLOSER, Plaintiff V. WESLEY L. BLOSER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-6118 Civil Term CIVIL ACTION - LAW CUSTODY PRAECIPE TO ENTER AND WITHDRAW APPEARANCE Kindly withdraw the appearance of Kristopher T. Smull, Esquire and Maria P. Cognetti and Associates on behalf of the above-named Defendant, Wesley Bloser, in connection with the above captioned matter. Date: Kindly enter the appearance of Kristopher T. Smull, Esquire and Robinson & Geraldo, on behalf of the above-named Defendant, Wesley Bloser, in connexion with the above captioned matter. Date: ?1? 10? Krisfth&T. Smull; Esquire ROBINSON & GERALDO Attorney I.D. No. 69140 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 Telephone No. (717) 232-8525 a CERTIFICATE OF SERVICE 1, Kristopher T. Smull, Esquire, do hereby certify that on the g? day of May, 2008, I caused a true and correct copy of the Praecipe to Enter and Withdraw Appearance to be served upon the following individual by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. James Miller, Esquire 765 Poplar Church Road Camp Hill, PA 17011 ROBINSON RALDO By: wk,--\ Krist p T. Smull, Esquire c?a .c,_ : _~ ? -.? ??! :, ? c, ?.; ` ? ?.;? ?==' ` . , ?? ??.. ? Saundra J Bloser, Plaintiff V Wesley L Bloser, Defendant In the Court of Common Pleas Cumberland County, Pennsylvania No 07-6118 Civil Action - Law In Custody PETITION TO MODIFY CUSTODY 1. The Plaintiff Saundra J Bloser residing at 329 North Mountain Road, Newville, Cumberland County, Pennsylvania 17241 2. The Defendant is Wesley L Bloser residing at 20 Blain McCrea Road, Newville, Cumberland County, Pennsylvania 17241. 3. Plaintiff seeks to modify the existing November 23, 2007, custody order ("order") attached hereto as Exhibit A as it relates to her minor son, Colton Lynn Bloser, date of birth February 22 1993. 4. Custody matters addressed in the order relating to the parties' other son, Cody L Bloser, date of birth April 1 1990 never were resolved by the parties or court; he has since graduated from high school and turned 18 years old. 5. Custody matters relating to Colton have essentially been a rollercoaster between the parties and Colton. 6. Since the entry of the order, circumstances have risen which positively confirm Plaintiff's belief and conviction that her relationship with her son, Colton, is a good relationship. However, given Defendant's primary custody status and the backdrop of his negative influence, Plaintiff's reparation of her relationship with Colton has been extraordinarily and unnecessarily difficult and at times, seems irreparable. 7. The best interests and permanent welfare of Colton will be best served by granting Plaintiff physical custody in the following preference: a. primary physical custody subject to Defendant's periods of partial custody; b. shared physical custody on an alternating week basis; or, c. partial physical custody every other weekend, one night per week and shared summers; d. along with holidays and birthdays shared in each of the foregoing 8. The existing November 23 2007 must be modified to reflect custody that more appropriately addresses the needs of Plaintiff and Colton in order to: a. better prepare Colton socially; b. offer appropriate guidance with rules governing conduct; and c. instill in Colton a sense of responsibility and respect. WHEREFORE, Plaintiff requests the court to grant the relief herein requested. Respectfully submitted, MILLER LIPSITT LLC James A. Miller, Esquire 765 Poplar Church Road Camp Hill, PA 17011 (717) 737-6400 NOV E1.2007H4 SAUNDRA J. BLOSER, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-6118 Civil Term WESLEY L. BLOSER Defendant : ACTION IN CUSTODY COURT ORDER eday AND NOW, thiof November, 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. This Order is entered pursuant to a Custody Conciliation Conference. A Custody Hearing is hereby scheduled on the day o 200-a at 13? s?/pm in Courtroom number _-L in the Cumberl County Court of Common Pleas, Carlisle, PA 17013 at which time testimony 'll be taken related to the sole issue of whether Cody Bloser should be court ordered to attend counseling. For purposes of this hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the hearing date. 2. The Father, Wesley Bloser, and the Mother, Saundra Bloser, shall enjoy shared legal custody of Cody L. Bloser, born 4/01/90 and Colton Bloser, born 2/22/93. The parties agree that major non-emergency decisions concerning the Children's health, welfare, education and religion shall be made by them jointly, after discussion and consultation with the other, with a view toward obtaining and following a harmonious policy in the Children's best interest. Pursuant to the terms of 23 .Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children 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. The Father shall have primary physical custody of Cody and Colton Bloser subject to Mother's partial physical custody as follows. Mother shall have custody/visitation with and Colton Bloser one evening per week from 6:00 pm until 8:00 pm at a neutral public location. Said visitation shall commence 11/19/07, then again on 11/29/07 and thereafter commencing 12/5/07 every '?,uhwn4- Wednesday. Father shall provide transportation for said exchanges at the agreed upon location. The parties may modify this paragraph by mutual consent. 4. The Parties are directed to initiate family counseling pertaining to Colton Bloser with a mutually agreeable counselor. The Parties are directed to comply with the counselor's recommendations. The cost of the counseling, after any appropriate payment through insurance for the parties, shall be split equally between the parties. 5. Telephone contact between the Children and the non-custodial parent shall be liberal as agreed upon between the parties. It is directed that both parents shall communicate with one another regarding the custody matter and to not involve the Children in said communications. 6. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. 8. The parties may modify this Order by mutual agreement in writing. In the absence of mutual consent, the terms of this Order shall control. 9. An update conciliation conference is scheduled for February 19, 2008 at 9:00 am before the assigned Conciliator at the Court of Common Pleas of Cumberland County, Carlisle, PA 17013. 10. Counsel for the parties are directed and allowed to request this matter to be removed from the scheduled hearing date if appropriate. BY TIE O , s J. Cc: Kristopher Smull, Esq., 210 Grandview Avenue, Ste 102, Camp Hill, PA 17011 James Miller, Esq., 765 Poplar Church Rd., Camp Hill, PA 17011 John J. Mangan, Esq. TRUE Copy .. ltOM RfGORD- fr?.le iMony whereof "! here unto t my hand and h seas of said Lou 1 at r1ile, Pa. 27.. a y ht., Prot onotarv SAUNDRA J. BLOSER, Plaintiff V. WESLEY L. BLOSER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 07-6118 Civil Term : ACTION IN CUSTODY CONCH,IATION 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 children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Cody L. Bloser 04/01/90 Primarily Father Colton L. Bloser 02/22/93 Primarily Father 2. A Conciliation Conference was held on November 14, 2007 with the following individuals participating: The Father, Wesley L. Bloser, with his counsel, Kristopher Smull, Esquire The Mother, Saundra J. Bloser, with her counsel, James Miller, Esquire. 3. Father's position on custody is as follows: The parties agreed to the legal and physical custody as outlined in the attached proposed Order. The point of contention is whether or not it is appropriate for Cody Bloser should attend counseling. Father acknowledges that Cody has some anger issues related to Cody's relationship with Mother but does not feel counseling is necessary and does not feel that he can force Cody to attend. Cody will be 18 on April 1, 2008 and refuses to attend counseling, neither individual counseling or family counseling with Mother. 4. Mother's position is as follows: The parties agreed to the legal and physical custody as outlined in the attached proposed Order. The point of contention is whether or not it is appropriate for Cody Bloser should attend counseling. Mother indicates that Cody has severe anger issues toward her and life in general and requests that Cody be ordered to attend counseling. 5. The Conciliator recommends an Order in the form as attached scheduling a Hearing pertaining to the sole issue of whether Cody Bloser should be court ordered to attend counseling and entering an Order of Court It is the Conciliator's belief that this would be in the Children's best interest. It is expected that the Hearing will require half a day. 6. The proposed recommended Order may contain a requirement that the parties file a pre-trial memorandum with the Judge to whom the matter has been assigned. Date: November 18, 2007 Jo gan, Esq ' e C o Conciliator Saundra J Bloser, Plaintiff V Wesley L Bloser, Defendant In the Court of Common Pleas Cumberland County, Pennsylvania No 07-6118 Civil Action - Law In Custody VERIFICATION I verify that the statements made in the foregoing Petition to Modify Custody 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. Date: Wednesday, June 18, 2008 Gou _Q AYV Saundra J Bloser C? ? s r°' ? =' .:? :? -n ?, ?? ? ?- -r ? ?? °' `- ? ? '?- ? ? d , r Y , ? ? ?? ?` ?^ k- SAUNDRA J. BLOSER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2007-6118 CIVIL ACTION LAW WESLEY L. BLOSER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, June 30, 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 Monday, July 28, 2008 at 10:30 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. 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/ ohn . 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 Oro) s 6? •? Y 0C Nn OUR t JUL 2 8 2008 SAUNDRA J. BLOSER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-6118 Civil Term WESLEY L. BLOSER Defendant : ACTION IN CUSTODY Prior Judge: J. Wesley Oler, Jr. COURT ORDER AND NOW, this a_ day of July 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. The prior Orders of Court entered in this matter are hereby VACATED. 2. The Father, Wesley Bloser, and the Mother, Saundra Bloser, shall enjoy shared legal custody of Colton Bloser, born 2/22/93. The parties agree that major non- emergency decisions concerning the Child's health, welfare, education and religion shall be made by them jointly, after discussion and consultation with the other, with a view toward obtaining and following a harmonious policy in the Child's best interest. 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. The Father shall have primary physical custody of Colton Bloser subject to Mother's partial physical custody as follows: a. Mother shall have custody/visitation with and Colton Bloser every Wednesday evening per week from 6:00 pm until 8:00 pm at a neutral public location. The parties may alter/expand the time and location by mutual agreement. b. Father shall provide transportation for said exchanges at the agreed upon location. c. Mother shall have additional periods of physical custody of Colton as necessary or proper and the parties may modify this paragraph by mutual consent. 4. The Parties are directed to continue the family counseling pertaining to Colton Bloser with Franco Psychological Associates or some other mutually agreeable counselor. The Parties are directed to comply with the counselor's n = ii P ,,,v ! £ inr Run ! f 1 j7 recommendations and comply with the counselor's request for Mother and/or Father's participation. The cost of the counseling, after any appropriate payment through insurance for the parties, shall be split equally between the parties. 5. Telephone contact between the Child and the non-custodial parent shall be liberal as agreed upon between the parties. It is directed that both parents shall communicate with one another regarding the custody matter and to not involve the Child in said communications. 6. In the event of a medical emergency, the custodial party shall notify the other party as soon as practicable after the emergency is handled. 7. Neither party may say or do anything nor permit a third party to do or say 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 or affection for the other party. It is specifically directed that neither Mother nor Father may discuss with Colton, or influence Colton, the other parent's perceived shortcomings or alleged flaws. 8. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify this Order by mutual agreement in writing. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT Cc: , nstopher Smull, Esq., 210 Grandview Avenue, Ste 102, Camp Hill, PA 17011 ,dines Miller, Esq., 765 Poplar Church Rd., Camp Hill, PA 17011 ,,6hn J. Mangan, Esq. /,0 3V SAUNDRA J. BLOSER, Plaintiff V. WESLEY L. BLOSER Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 07-6118 Civil Term : ACTION IN CUSTODY CONCILIATION CONFERENCE SUNEW"Y REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Colton L. Bloser 02/22/93 Primary Father 2. A Conciliation Conference was held on November 14, 2007, an Order of Court dated November 23, 2007 was issued, an update conciliation conference was held February 19, 2008, an Order issued February 22, 2008 and a conference was held on July 28, 2008 with the following individuals participating: The Father, Wesley L. Bloser, with his counsel, Kristopher Smull, Esquire The Mother, Saundra J. Bloser, with her counsel, James Miller, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. ?- Date: 2Z Conciliator