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HomeMy WebLinkAbout08-0048 WILLIAM L. GLADFELTER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. - NUMBER: c7F-YP (rc??,t T< - LINDSAY A. SHEVENOCK, Defendant CUSTODY COMPLAINT FOR CUSTODY NOW COMES the Plaintiff, WILLIAM L. GLADFELTER, by his attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is WILLIAM L. GLADFELTER, who currently resides at 1105 Cartref, Etters, County of York, Pennsylvania. 2. Defendant is LINDSAY A. SHEVENOCK, who currently resides at an address unknown to Plaintiff, but whose last known address is 1100 Cedar Run Drive, Camp Hill, County of Cumberland, Pennsylvania. 3. Plaintiff seeks to have rights of primary physical and shared legal custody with respect to ZOE RAE GLADFELTER, born August 20, 2004. The child was born out of wedlock. The child is presently in the custody of Defendant, LINDSAY A. SHEVENOCK. Since birth the child has resided with the following persons and at the following addresses: from birth until August, 2005, with both parents at 222 South Front Street, Wormleysburg, Pennsylvania; from August, 2005, until October, 2005, with Defendant at Tenth Street, New Cumberland, Pennsylvania; from October, 2005, until August, 2006, with Defendant at Hummel Avenue, Camp Hill, Pennsylvania; from August, 2006, until October, 2006, with Plaintiff and Defendant at 1105 Cartref, Etters, Pennsylvania; from October, 2006, until the present with the Defendant at 1100 Cedar Run Drive, Camp Hill, Pennsylvania. The mother of the child is LINDSAY A. SHEVENOCK, who currently resides at an address unknown to Plaintiff, but whose last known address is 1100 Cedar Run Drive, Camp Hill, Pennsylvania. She is single. The father of the child is WILLIAM L. GLADFELTER, who currently resides at 1105 Cartref, Etters, Pennsylvania. He is single. 4. The relationship of the Plaintiff to the child is that of father. The Plaintiff currently resides alone. 5. The relationship of the Defendant to the child is that of mother. She currently resides with the child. 6. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or in another court. The Plaintiff has no information of a custody proceeding concerning the custody of the child in this or in another court. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. -1 7. The best interest and permanent welfare of the child will be served by confirming rights of primary physical and shared legal custody in Plaintiff because Plaintiff can better care for the physical, emotional, and psychological welfare of the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests that Your Honorable Court enter an Order confirming rights of primary physical and shared legal custody in Plaintiff. Respectfully submitted, CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Complaint 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. Jan 2, 2008 DATE WILL AM L. GLADFELTER n ? `? ; ``\L s ? ? ?a ?y , t °+u r? - ? r r ; fFx ?? °-` n .,ice ? rt ?. ??? ? . ? WILLIAM L. GLADFELTER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LINDSAY A. SHEVENOCK DEFENDANT 2008-0048 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, January 10, 2008 , 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 Wednesday, February 06, 2008 at 9:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Es q, 41 jj%Z 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 X48 iiNF I.A ?H3. WILLIAM L. GLADFELTER Plaintiff vs. LINDSAY A. SHEVENOCK Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-0048 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this i day of ?2?r-j A , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered d directed as follows: 1. On a trial basis pending the conciliation conference scheduled in this Order, the parties shall have physical custody of Zoe Rae Gladfelter, born August 20, 2004, in accordance with the following schedule: The Father shall have custody on February 6, 2008 until 2:00 p.m. when the Father shall meet the Mother at her doctor's appointment to exchange custody and again following the Mother's appointment through Friday when the Father shall transport the Child to daycare. The Mother shall have custody from Friday, February 8 at daycare through Saturday, February 9 at 6:00 p.m., when the Father shall have the Child for dinner only. The Mother shall have custody of the Child from after dinner on February 9 through Sunday, February 10 at 9:00 a.m., when the Father shall have custody through Wednesday, February 13. The Mother shall have custody from Wednesday, February 13 at daycare through Saturday, February 16 at 6:00 p.m. The Father shall have custody of the Child from Saturday, February 16 at 6:00 p.m. through Tuesday, February 19. The Mother shall have custody from Tuesday, February 19 at daycare through Saturday, February 23 at 6:00 p.m. The Father shall have custody from Saturday, February 23 at 6:00 p.m. through Wednesday, February 27. E ` The Mother shall have custody from Wednesday, February 27 at daycare through Saturday, March 1 at 6:00 p.m. The Father shall have custody from Saturday, March 1 at 6:00 p.m. through Tuesday, March 4. The Mother shall have custody from Tuesday, March 4 at daycare through Saturday, March 8 at 6:00 p.m. The Father shall have custody from Saturday, March 8 at 6:00 p.m. through Wednesday, March 12. The Mother shall have custody from Wednesday, March 12 at daycare through Saturday, March 15 at 6:00 p.m. The Father shall have custody from Saturday, March 15 at 6:00 p.m. through Tuesday, March 18. The Mother shall have custody from Tuesday, March 18 through Saturday, March 22 at 6:00 p.m. 2. All exchanges of custody on Saturdays shall take place at the Giant store in New Cumberland and all exchanges on Tuesdays or Wednesdays shall take place at the Child's daycare. 3. In the event either party is unavailable to provide care for the Child during his or her period of custody for two (2) hours or more, that parent shall contact the other parent to offer the opportunity to provide care for the Child during the custodial parent's unavailability before contacting third parry caregivers. 4. The Father shall enroll in parenting classes at ParentWorks, Inc. (or other agency offering parenting classes) as soon as practicable following the initial conciliation conference. The Mother shall also contact ParentWorks, Inc. (or other agency offering parenting classes) at such time as all medical restrictions on her ability to drive are removed. 5. The parties and their counsel shall attend an additional custody conciliation conference in the office of the conciliator, Dawn S. Sunday, on Wednesday, March 19, 2008 at 10:30 a.m. for the purpose of reviewing the physical custody schedule and establishing legal custody and holiday arrangements. 6. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 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, cc: ? Charles E. Petrie, Esquire - Counsel for Father ?Michelle L Sommer, Esquire - Counsel for Mother ?dt? ? E S ?n?.l,? 6 a/r ? ?va ^I?Y{ ry J .?r? 30,12- Fa 7Mr 5 WIIk,JAM L. GLADFELTER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2008-0048 CIVIL ACTION LAW LINDSAY A. SHEVENOCK Defendant 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 Zoe Rae Gladfelter August 20, 2004 Mother/Father 2. A custody conciliation conference was held on February 6, 2008, with the following individuals in attendance: the Father, William Gladfelter, with his counsel, Charles E. Petrie, Esquire, and the Mother, Lindsay A. Shevenock, with her counsel, Michelle L. Sommer, Esquire.. 3. The parties agreed to entry of an Order in the form as attached. Cx)? i'6 Date Dawn S. Sunday, Esquire Custody Conciliator 11AAIt $ 4 Zll00,/ M?" WILLIAM L. GLADFELTER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2008-0048 CIVIL ACTION LAW LINDSAY A. SHEVENOCK Defendant IN CUSTODY ORDER AND NOW, this 18th day of March, 2008, the conciliator, being advised by counsel that all custody issues have been resolved by agreement between the parties, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for March 19, 2008 is cancelled. BY THE COURT, Dawn S. Sunday Film r cr*t 3 ?' . WILLIAM L. GLADFELTER, Plaintiff V. LINDSAY A. SHEVENOCK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA 2008-0048 CIVIL ACTION - LAW . IN CUSTODY TO THE HONORABLE M. L. EBERT, JUDGE OF SAID COURT: THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between WILLIAM L. GLADFELTER, (hereinafter referred to as "Father' and LINDSAYA. SHEVENOCK, (hereinafter referred to as "Mother'). WHEREAS, the parties are the natural parents of one child, namely ZOE RAE GLADFELTER, born August 20, 2004, (hereinafter referred to as "Child'; and WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive stipulation and agreement relative to physical and legal custody of their Child. NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: 1. Legal Custody: 2 a. The parties will share joint legal custody of ZOE RAE GLADFELTE9 (age 3 - born August 20, 2004). The parties agree that major decisions concerning their Child, including, but not necessarily limited to, the Child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the Child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the Child. Each parry agrees not to attempt to alienate the affections of the Child from the other parry. Each party shall notify the other of any activity or circumstance concerning their Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions, which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either parry as a parent as authorized by statute. Mutual agreement should be made, in advance, regarding the following matters: enrollment or termination in a particular school or school program, advancing or holding the Child back in school, authorizing enrollment in college, authorizing their Child's driver's license or purchase of an automobile, authorizing employment, authorizing either Child's marriage or enlistment in the 3 armed forces, approving a petition for emancipation, authorizing foreign travel, passport application or exchange student status. 2. Primary Physical Custody: a. Shall be shared as follows will allow each parent seven (7) overnights in a two (2) week period. This schedule will continue on this rotating schedule every two (2) weeks: i. Week One 1. Father shall have custody of the child from Monday after daycare through Wednesday morning. 2. Mother shall have custody from Wednesday after daycare through Friday morning. 3. Father shall have custody of the child from Friday after daycare through Monday morning. ii. Week Two 1. Mother shall have custody of the child from Monday after daycare through Wednesday morning. 2. Father shall have custody from Wednesday after daycare through Friday morning. 3. Mother shall have custody of the child from Friday after daycare through Monday morning b. All exchanges of custody in the evening shall take place at the Giant store in New Cumberland and all exchanges in the morning shall take place at the Child's daycare facility. c. The parent with physical custody during any given period of time shall communicate in a prompt fashion with the other parent concerning the well-being of their Child, and shall appropriately notify the other parent of any changes in health or educational progress. Each parent shall 4 execute any and all legal authorizations so that the other parent may obtain information from the Child's schools, physicians, psychologists, or other individuals concerning their progress and welfare. d. Right of First Refusal: i. In the event either parry is unavailable to provide care for the Child during his or her period of custody for two (2) hours or more, that parent shall contact the other parent to offer the opportunity to provide care for the Child during the custodial parent's unavailability before contacting third parry caregivers. 3. Holidays: a. Easter: i. Mother will have custody of the Child in even-numbered years from Saturday at 8:00 p.m. to Sunday at 8:00 p.m., alternating with Father on odd-numbered years. b. Thanksgiving: i. Father will have custody of the Child in even-numbered years from Wednesday at 8:00 p.m. to Thursday at 8:00 p.m., alternating with Mother on odd-numbered years. c. Christmas: i. Mother will have custody of the Child in even-numbered years from Noon Christmas Eve until Noon Christmas Day, alternating with Father on odd-numbered years. d. Mother's Day: i. Mother will have physical custody of the Child on Mother's Day from 9:00 a.m. until 8:00 p.m. e. Father's Day: 5 i. Father will have physical custody of the Child on Father's Day from 9:00 a.m. until 8:00 p.m. f. Picnic Holidays: i. Mother and Father will alternate custody for the following holidays from 9:00 a.m. until 8:00 p.m.; Memorial Day, 4" of July and Labor Day. 1. Mother will have custody of the Child on Memorial Day in 2008 and Labor Day in 2008. Father will have custody of the child on the 4' of July in 2008. 2. Father will have custody of the Child on Memorial Day in 2009 and Labor Day in 2009. Mother will have custody of the child on the 4d' of July in 2009. g. The holiday schedule shall take precedence over the regular custody schedule. 4. Summer a. During the summer months, each parent will be afforded at least a week (seven consecutive days), as long as he or she provides at least thirty (30) days written notice to the other party of his or her selected weeks; as well as, the destination of the vacation and a number where the Child can be reached. 5. Should either parry have the Child spend overnight at a place other than their primary residence, the other parent will be given the address and phone number. 6. Telephone Contact: a. Each parent shall be entitled to reasonable telephone contact with the Child which shall not be excessive as well as daily contact via e-mail with the Child when in the custody of the other parent. 6 7. The parents shall organize ways for their Child to maintain their friendships, extracurricular activities, and other special interests, regardless of which household they may be in. It is also suggested that toys, clothes, etc. not become matters of contention. Major gifts should be discussed and coordinated between the parents. 8. Each parent will exercise care in screening babysitting/Child care providers. The telephone numbers of these providers will be provided to both parents. Parents should provide one another with a phone number and address where the Child may be contacted at all times whenever reasonably possible. This principle applies to situations such as vacations and overnights with friends. Each parent should be promptly and politely responsive to the other parent's telephone calls. 9. The parents shall permit and support the Child's access to all family relationships. Special family events such as weddings, family reunions, family gatherings, funerals, graduations, etc. shall be accommodated by both parties with routine visitations resuming immediately thereafter. Each parent shall have the option of proposing time or date variations to the other parent when special recreational options or other unexpected opportunities arise. Each parent must confer with the other parent before arranging regularly occurring extracurricular activities for the Child which might interfere with regular visitation. 10. During any period of custody or visitation the parties to this Order. shall not possess or use any controlled substance, nor shall they consume alcoholic beverages to the point of intoxication, nor smoke cigarettes inside the residence or vehicle. The parties shall likewise assure, to the extent possible, that other household members and/or houseguests comply with this prohibition. 7 11. Neither parent shall permanently relocate if the relocations would necessitate a change in the visitation schedule or if the relocation would result in a change of school for the Child or exceed a fifty (50) mile radius without a minimum notice of ninety (90) days to the other parent. The ninety (90) day notice is designed to afford the parents an opportunity to renegotiate the custodial arrangements or to have the matter listed for a Court hearing. For the Child's welfare, neither parent should consider moving very far from the other until the Child has reached adulthood. 12. No Conflict zone: a. Each parent agrees not to attempt to alienate the affections of the Child from the other and will make a special conscious effort not to do so. Both parents shall establish a no-conflict zone for their Children and refrain from making derogatory comments about the other parent in the presence of the Child and, to the extent possible, shall not permit third parties from making such comments in the presence of the Child whether the Child is sleeping or awake. Each parent shall speak respectfully of the other whether it is believed the other reciprocates or not. Each parental figure shall refer to the other by the appropriate role name such as Mom, Dad, your grandmother, etc. Each parent should agree to refrain from encouraging the Child to provide reports about the other parent. Communication should always take place directly between parents, without using the Child as an intermediary. Each parent should encourage their Child to send the appropriate holiday cards to the other parent. 13. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County 8 does, in fact, have jurisdiction over the issue of custody of the parties' minor Child, who has resided for at least the past six (6) months in Cumberland County, Pennsylvania. 14. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other parry. 15. The parties acknowledge that they have read and understand the provisions of this Agreement Each parry acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. WITNESSETH: A E WILLIAM L. GLAD 7ftER DATE LINDSAY SHEVENOCK Distribution: Charles Petrie, Esquire Attorney for the Plaintiff 3528 Brisban Street Harrisburg, PA 17111 Michelle L. Sommer, Esquire Attorney for the Defendant Abom & Kutulakis, L.L.P. 36 South Hanover Street Carlisle, PA, 17013 9 COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On this ? day of 51 2008, before me, the undersigned officer, personally appeared WI L. GLADFELTER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. NWEALTH OF PLNNSYLVANK K PaxWV elly R Robert; . t ry ?ubliC Bono, i;auph MY COr1V vicar 641 ft in County Jan. 27, 2009 MAAfber, Pennsylvania Association of Notaft COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On this 15 day of 2008, before me, the undersigned officer, personally appeared LINDSAY A. SHEVENOCK, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the purposes therein contained. NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial seal Shannon L. Freeman. Notary Public Carlisle Boro, Cumbenand Courtly My Commission E)Ores April 7, 2009 10 Member, Psnnsylvanls Association of Notaries I A c _. r M v tj MAY 1 62008 WILLIAM L. GLADFELTER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. 2008-0048 CIVIL ACTION - LAW LINDSAY A. SHEVENOCK, Defendant IN CUSTODY AND NOW this 11 S? day of 2008, the attached Custody Stipulation and Agreement is hereby made an Order of Court. BY THE COURT: M. L. Ebert, Judge cc: Charles Petrie, Esquire, Attorney for the Plaintiff ZMichelle L. Sommer, Esquire, Attorney for the Defendant 00-1.) t'es rn9 1 LCCL s?a c1 08 1 Alom & KITLILAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 WILLIAM L. GLADFELTER, Plaintiff V. LINDSAY A. SHEVENOCK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA 2008-0048 CIVIL ACTION - LAW IN CUSTODY TO THE HONORABLE M. L. EBERT, JUDGE OF SAID COURT: AND NOW, this 18''' day of June, 2008, comes undersigned counsel, ABOM & KUTULAKIS, L.L.P., by Michelle L. Sommer, Esquire, who respectfully requests This Honorable Court grant this Motion to Withdraw as Counsel for the above-named Defendant and, in support thereof, respectfully avers the following: 1. The Plaintiff, William L. Gladfelter, is represented by and through his counsel, Charles Petrie, Esquire. 2. The Defendant, Lindsay A. Shevenock, is represented by and through her counsel, Michelle L. Sommer, Esquire of Abom & Kutulakis, L.L.P. 3. A Complaint for Custody was filed by the Plaintiff, William L. Gladfelter, by and through his counsel on January 4, 2008. (A copy of the Complaint for Custody is attached hereto as Exhibit "A„) 4. A Custody Conciliation Conference was scheduled before Dawn S. Sunday, Esquire for January 10, 2008. 5. The Conciliation Conference was rescheduled to February 6, 2008 at which time the parties agreed to share physical custody of the minor child. (An Order dated February 11, 2008 signed by the Honorable M.L. Ebert, Jr. is attached hereto as Exhibit "B") 6. At that time a follow-up Conciliation was scheduled for March 19, 2008 for the purposes of reviewing the physical custody schedule and to establish legal custody and a holiday schedule. 7. However, the Conciliation Conference for March 19, 2008 was cancelled due to the fact that the parties entered into a Custody Stipulation and Agreement which was made an Order of Court on May 21, 2008. (A copy of said Custody Stipulation and Order is attached hereto as Exhibit "C") 8. As a result of the final Custody Stipulation and Agreement which addressed legal custody, physical custody and the holiday schedule, undersigned counsel's services are no longer required in this custody matter. 9. Charles Petrie, Esquire, attorney for Plaintiff, has been contacted and does not oppose this Motion. WHEREFORE, undersigned counsel respectfully requests this Honorable Court to grant her request to withdraw as counsel in this matter. Date (i l b log Respectfully submitted, ABOM & KUTULAKIS, L.L.P. Michelle L. Sommer, quire 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 93034 WILLIAM L. GLADFELTER, Plaintiff VS. LINDSAY A. SHEVENOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : NUMBER: CUSTODY COMPLAINT FOR CUSTODY NOW COMES the Plaintiff, WILLIAM L. GLADFELTER, by his attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is WILLIAM L. GLADFELTER, who currently resides at 1105 Cartref, Etters, County of York, Pennsylvania. 2. Defendant is LINDSAY A. SHEVENOCK, who currently resides at an address unknown to Plaintiff, but whose last known address is 1100 Cedar Run Drive, Camp Hill, County of Cumberland, Pennsylvania. 3. Plaintiff seeks to have rights. of primary physical and shared legal custody with respect to ZOE RAE GLADFELTER, born August 20, 2004. The child was born out of wedlock. The child is presently in the custody of Defendant, LINDSAY A. SHEVENOCK. Since birth the child has resided with the following persons and at the following addresses: from birth until August, 2005, with both parents at 222 South Front Street, Wormleysburg, Pennsylvania; from August, 2005, until October, 2005, with Defendant at Tenth Street, New Cumberland, Pennsylvania; from October, 2005, until August, 2006, with Defendant 4 ¦ EXHIBIT A Hummel Avenue, Camp Hill, Pennsylvania; from August, 2006, until October, 2006, with Plaintiff and Defendant at 1105 Cartref, Etters, Pennsylvania; from October, 2006, until the present with the Defendant at 1100 Cedar Run Drive, Camp Hill, Pennsylvania. The mother of the child is LINDSAY A. SHEVENOCK, who currently resides at an address unknown to Plaintiff, but whose last known address is 1100 Cedar Run Drive, Camp Hill, Pennsylvania. She is single. The father of the child is WILLIAM L. GLADFELTER, who currently resides at 1105 Cartref, Etters, Pennsylvania. He is single. 4. The relationship of the Plaintiff to the child is that of father. The Plaintiff currently resides alone. 5. The relationship of the Defendant to the child is that of mother. She currently resides with the child. 6. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or in another court. The Plaintiff has no information of a custody proceeding concerning the custody of the child in this or in another court. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by confirming rights of primary physical and shared legal custody in Plaintiff because Plaintiff can better care for the physical, emotional, and psychological welfare of the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests that Your Honorable Court enter an Order- confirming rights of primary physical and shared legal custody in Plaintiff. Respectfully submitted, CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff TRUE COPY in Testimony whereof, ! and the sea{ of said Court at .. ?:?:........., j This ..... .....; ? day of ,l Prothonotary, COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Complaint 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. Jan 2, 2008 DATE WILL AM L. GLADFELTER FED 7 2008 0411111 WILLIAM L. GLADFELTER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2008-0048 CIVIL ACTION LAW LINDSAY A. SHEVENOCK Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of F Lg _ 2008, upon consideration of the attached Custody Conciliation Report, it is ordere and directed as follows: 1. On a trial basis pending the conciliation conference scheduled in this Order, the parties shall have physical custody of Zoe Rae Gladfelter, born August 20, 2004, in accordance with the following schedule: The Father shall have custody on February 6, 2008 until 2:00 p.m. when the Father shall meet the Mother at her doctor's appointment to exchange custody and again following the Mother's appointment through Friday when the Father shall transport the Child to daycare. The Mother shall have custody from Friday, February 8 at daycare through Saturday, February 9 at 6:00 p.m., when the Father shall have the Child for dinner only. The Mother shall have custody of the Child from after dinner on February 9 through Sunday, February 10 at 9:00 a.m., when the Father shall have custody through Wednesday, February 13. The Mother shall have custody from Wednesday, February 13 at dav_ care through Saturday. February 16 at 6:00 p.m. The Father shall have custody of the Child from Saturday. February 16 at 6:00 p.m. through Tuesday, February 19. The Mother shall have custody from Tuesday, February 19 at daycare through Saturday, February 23 at 6:00 p.m. The Father shall have custody from Saturday. February 23 at 6:00 p.m. through Wednesday. February 27. E?BIT The Mother shall have custody from Wednesday, February 27 at daycare through Saturday, March 1 at 6:00 p.m. The Father shall have custody from Saturday, March 1 at 6:00 p.m. through Tuesday, March 4. The Mother shall have custody from Tuesday, March 4 at daycare through Saturday, March 8 at 6:00 p.m. The Father shall have custody from Saturday, March 8 at 6:00 p.m. through Wednesday, March 12. The Mother shall have custody from Wednesday, March 12 at daycare through Saturday, March 15 at 6:00 p.m. The Father shall have custody from Saturday, March 15 at 6:00 p.m. through Tuesday, March 18. The Mother shall have custody from Tuesday, March 18 through Saturday, March 22 at 6:00 p.m. 2. All exchanges of custody on Saturdays shall take place at the Giant store in New Cumberland and all exchanges on Tuesdays or Wednesdays shall take place at the Child's daycare. 3. In the event either party is unavailable to provide care for the Child during his or her period of custody for two (2) hours or more, that parent shall contact the other parent to offer the opportunity to provide care for the Child during the custodial parent's unavailability before contacting third party caregivers. 4. The Father shall enroll in parenting classes at ParentWorks, Inc. (or other agency offering parenting classes) as soon as practicable following the initial conciliation conference. The Mother shall also contact ParentWorks, Inc. (or other agency offering parenting classes) at such time as all medical restrictions on her ability to drive are removed. 5. The parties and their counsel shall attend an additional custody conciliation conference in the office of the conciliator, Dawn S. Sunday, on Wednesday. March 19, 2008 at 10:30 a.m. for the purpose of reviewing the physical custody schedule and establishing legal custody and holiday arrangements. 6. Neither party shall do or say anything which may estrange the Child from the other parent. injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 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, cc: Charles E. Petrie, Esquire - Counsel for Father Michelle L Sommer, Esquire - Counsel for Mother r to ?.'. f a WILLIAM L. GLADFELTER Plaintiff vs. LINDSAY A. SHEVENOCK Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-0048 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 Zoe Rae Gladfelter August 20, 2004 Mother/Father 2. A custody conciliation conference was held on February 6, 2008, with the following individuals in attendance: the Father, William Gladfelter, with his counsel, Charles E. Petrie, Esquire, and the Mother, Lindsay A. Shevenock, with her counsel, Michelle L. Sommer, Esquire.. 3. The parties agreed to entry of an Order in the form as attached. .1 Date Dawn S. Sunday, Esquire Custody Conciliator MAY 162008 WILLIAM L. GLADFELTER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. 2008-0048 CIVIL ACTION - LAW LINDSAY A. SHEVENOCK, Defendant IN CUSTODY AND NOW this day of . 2008, the attached Custody Stipulation and Agreement is hereby made an Order of Court. BY THE COURT: M. L. ESert, judge cc: Charles Petrie, Esquire, Attorney for the Plaintiff Michelle L. Sommer, Esquire, Attorney for the Defendant ? u ?r?rirao my l)a(14 .,day 01__ EXI-HBIT 4 WILLIAM L. GLADFELTER, IN THE COURT OF COMMON QEA? Plaintiff CUMBERLAND COUNTY PA, ' `= T , `- _ -` nib v. L 2008-0048 CIVIL ACTION t? c? LINDSAY A. SHEVENOCK °;-? a ? , Defendant IN CUSTODY ' _ ' TO THE HONORABLE M. L. EB ERT, JUDGE OF SAID COURT: THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between WILLIAM L. GLADFELTER, (hereinafter referred to as "Father'D and LINDSAYA. SHEVEIVOCK (hereinafter referred to as "Mother'. WHEREAS, the parties are the natural parents of one child, namely ZOE RAE GLADFELTER, born August 20, 2004, (hereinafter. referred to as "Child'; and WHEREAS) the parties live separate and apart, and wish to enter into a comprehensive stipulation and agreement relative to physical and legal custody of their Child. NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: 1. Legal Custody: 2 a. The parties will share joint legal custody of ZOE RAE GLADFELTEA (age 3 - born August 20, 2004). The parties agree that major decisions concerning their Child, including, but not necessarily limited to, the Child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the Child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the Child. Each party agrees not to attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning their Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions, which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. Mutual agreement should be made, in advance, regarding the following matters: enrollment or termination in a particular school or school program, advancing or holding the Child back in school, authorizing enrollment in college, authorizing their Child's driver's license or purchase of an automobile, authorizing employment, authorizing either Child's marriage or enlistment in the 3 armed forces, approving a petition for emancipation, authorizing foreign travel, passport application or exchange student status. 2. Primary Physical Custody: a. Shall be shared as follows will allow each parent seven (7) overnights in a two (2) week period. This schedule will continue on this rotating schedule every two (2) weeks: i. Week One 1. Father shall have custody of the child from Monday after daycare through Wednesday morning. 2. Mother shall have custody from Wednesday after daycare through Friday morning. 3. Father shall have custody of the child from Friday after daycare through Monday morning. ii. Week Two 1. Mother shall have custody of the child from Monday after daycare through Wednesday morning. 2. Father shall have custody from Wednesday after daycare through Friday morning. 3. Mother shall have custody of the child from Friday after daycare through Monday morning b. All exchanges of custody in the evening shall take place at the Giant store in New Cumberland and all exchanges in the morning shall take place at the Child's daycare facility. c. The parent with physical custody during any given period of time shall communicate in a prompt fashion with the other parent concerning the well-being of their Child, and shall appropriately notify the other parent of any changes in health or educational progress. Each parent shall 4 execute any and all legal authorizations so that the other parent may obtain information from the Child's schools, physicians, psychologists, or other individuals concerning their progress and welfare. d. Right of First Refusal: i. In the event either party is unavailable to provide care for the Child during his or her period of custody for two (2) hours or more, that parent shall contact the other parent to offer the opportunity to provide care for the Child during the custodial parent's unavailability before contacting third party caregivers. 3. Holidays: a. Easter: i. Mother will have custody of the Child in even-numbered years from Saturday at 8:00 p.m. to Sunday at 8:00 p.m., alternating with Father on odd-numbered years. b. Thanksgiving: i. Father will have custody of the Child in even-numbered years from Wednesday at 8:00 p.m. to Thursday at 8:00 p.m., alternating with Mother on odd-numbered years. c. Christmas: i. Mother will have custody of the Child in even-numbered years from Noon Christmas Eve until Noon Christmas Day, alternating with Father on odd-numbered years. d. Mother's Day: i. Mother will have physical custody of the Child on Mother's Day from 9:00 a.m. until 8:00 p.m. e. Father's Day: 5 i. Father will have physical custody of the Child on Father's Day from 9:00 a.m. until 8:00 p.m. f. Picnic Holidays: i. Mother and Father will alternate custody for the following holidays from 9:00 a.m. until 8:00 p.m.; Memorial Day, 4`h of July and Labor Day. 1. Mother will have custody of the Child on Memorial Day in 2008 and Labor Day in 2008. Father will have custody of the child on the 4' of July in 2008. 2. Father will have custody of the Child on Memorial Day in 2009 and Labor Day in 2009. Mother will have custody of the child on the 4`s of July in 2009. g. The holiday schedule shall take precedence over the regular custody schedule. 4. Summer: a. During the summer months, each parent will be afforded at least a week (seven consecutive days), as long as he or she provides at least thirty (30) days written notice to the other party of his or her selected weeks; as well as, the destination of the vacation and a number where the Child can be reached. 5. Should either party have the Child spend overnight at a place other than their primary residence, the other parent will be given the address and phone number. 6. Telephone Contact: a. Each parent shall be entitled to reasonable telephone contact with the Child which shall not be excessive as well as daily contact via e-mail with the Child when in the custody of the other parent. 6 7. The parents shall organize ways for their Child to maintain their friendships, extracurricular activities, and other special interests, regardless of which household they may be in. It is also suggested that toys, clothes, etc. not become matters of contention. Major gifts should be discussed and coordinated between the parents. 8. Each parent will exercise care in screening babysitting/Child care providers. The telephone numbers of these providers will be provided to both parents. Parents should provide one another with a phone number and address where the Child may be contacted at all times whenever reasonably possible. This principle applies to situations such as vacations and overnights with friends. Each parent should be promptly and politely responsive to the other parent's telephone calls. 9. The parents shall permit and support the Child's access to all family relationships. Special family events such as weddings, family reunions, family gatherings, funerals, graduations, etc. shall be accommodated by both parties with routine visitations resuming immediately thereafter. Each parent shall have the option of proposing time or date variations to the other parent when special recreational options or other unexpected opportunities arise. Each parent must confer with the other parent before arranging regularly occurring extracurricular activities for the Child which might interfere with regular visitation. 10. During any period of custody or visitation the parties to this Order. shall not possess or use any controlled substance, nor shall they consume alcoholic beverages to the point of intoxication, nor smoke cigarettes inside the residence or vehicle. The parties shall likewise assure, to the extent possible, that other household members and/or houseguests comply with this prohibition. 7 11. Neither parent shall permanently relocate if the relocations would necessitate a change in the visitation schedule or if the relocation would result in a change of school for the Child or exceed a fifty (50) mile radius without a minimum notice of ninety (90) days to the other parent. The ninety (90) day notice is designed to afford the parents an opportunity to renegotiate the custodial arrangements or to have the matter listed for a Court hearing. For the Child's welfare, neither parent should consider moving very far from the other until the Child has reached adulthood. 12. No Conflict Zone: a. Each parent agrees not to attempt to alienate the affections of the Child from the other and will make a special conscious effort not to do so. Both parents shall establish a no-conflict zone for their Children and refrain from making derogatory comments about the other parent in the presence of the Child and, to the extent possible, shall not permit third parties from making such comments in the presence of the Child whether the Child is sleeping or awake. Each parent shall speak respectfully of the other whether it is believed the other reciprocates or not. Each parental figure shall refer to the other by the appropriate role name such as Mom, Dad, your grandmother, etc. Each parent should agree to refrain from encouraging the Child to provide reports about the other parent Communication should always take place directly between parents, without using the Child as an intermediary. Each parent should encourage their Child to send the appropriate holiday cards to the other parent. 13. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County 8 does, in fact, have jurisdiction over the issue of custody of the parties' minor Child, who has resided for at least the past six (6) months in Cumberland County, Pennsylvania. 14. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. 15. The parties acknowledge that they have read and understand the provisions of this Agreement Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. WITNESSETH: SZ5- A WILLIAML GLAD ER Lam) DATE LINDSAY $HEVENOC% Distribution: Charles Petrie, Esquire Attorney for the Pl dxf 3528 Brisban Street Harrisburg, PA 17111 Michelle L. Sommer, Esquire Attorney for the Defendant Abom & Kutulakis, L.L.P. 36 South Hanover Street Carlisle, PA, 17013 9 COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On this day of 2008, before me, the undersigned officer, personally appeared WI L. GLADFELTER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. l`IWEALTH OF PENNSYLVANIA :Notaoat Kelly P. ReM-. Nov2ry Public * C?'?? Mdarq io , i?auptun County Exp'res Jan. 27, 2009 Nfllllber, Pennsylvania Association of Noterlgq COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On this 15 - day of 2008, before me, the undersigned officer, personally appeared LINDSAY A. SFIEVENOCB, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the purposes therein contained. Jh an f?a d L NOTARY PUBLIC COMMONWEALT I OF PENNSYLVANIA Notarial Seal Shannon L. Freornan, Notary Public Carlisle Boro, Clumbmand County My Commission Fires April 7, 2009 10 Member, Pennsyivenlrl Msociation of Notaries AND NOW, this 18'' day of June 2008, I, Michelle L. Sommer, Esquire, of Abom & Kutulakis, LLP., hereby certify that I did serve a true and correct copy of the foregoing Motion to Withdraw as Counsel by First Class U.S. Mail addressed to the following: Lindsay Shevenock 2211 Cedar Run Drive Extended Apartment C Camp Hill, PA 17011 Charles E. Petrie, Esquire 3528 Brisban Street Harrisburg, PA 17111 Attorney for Plaintiff Respectfully submitted, ABOM & KUTUL 4m, L.L.P. . ",4. L'I IMD-) Michelle L. Sommer, Bgqwire Supreme Court ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 C) rut 77 7 n JUN 2 4 2008, WILLIAM L. GLADFELTER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. 2008-0048 CIVIL ACTION - LAW LINDSAY A. SHEVENOCK, Defendant IN CUSTODY AND NOW, this L day of June, 2008, upon Motion of Michelle L. Sommer, Esquire, a Rule is hereby issued upon the parties to show cause why the Petitioner should not be permitted to withdraw as counsel for Lindsay A. Shevenock. Rule returnable It days after the date of service of this Order. Service to be by certified mail upon Lindsay A. Shevenock and upon Charles E. Petrie, Esquire, Counsel for Defendant, William L. Gladfelter. BY THE COURT: )*A i.. M. L. Ebert, J. istribution: chelle L. Sommer, Esquire ?arles E. Petrie, Esquire 12cF&'F-.T M'ato" /0'pigp I yy, I h t'1, tiMI !?r? 6?t :I '?,4 SZ -1nC S, +j'G Z 3jHi K) v? H OM CSC' U ULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 WILLIAM L. GLADFELTER, Plaintiff V. LINDSAY A. SHEVENOCK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA 2008-0048 CIVIL ACTION - LAW IN CUSTODY TO THE HONORABLE M. L. EBERT, JUDGE OF SAID COURT: MOTION TO MAKE RULE ABSOLUTE AND NOW, this 0- day of July, 2008, comes Petitioner, Michelle L. Sommer, Esquire, of Abom & Kutulakis, L.L.P., who respectfully avers the following: 1. On June 20, 2008 Petitioner filed a Motion to Withdraw as Counsel in the above-captioned matter. 2. A Rule to Show Cause was issued on June 25, 2008 upon the parties to show cause why the Petitioner should not be permitted to withdraw as counsel for Defendant, Lindsay A. Shevenock. 3. More than twenty days have elapsed and neither the Defendant nor counsel for the Plaintiff, Charles E. Petrie, Esquire, have filed a response to the Rule to Show Cause. WHEREFORE, undersigned counsel respectfully requests this Honorable Court grant her request to withdraw as counsel in this matter. Respectfully submitted, ABOM & KUTULAKIS, L.L.P. 1a51MOS i- Date Michelle L. So r, Esquire 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney I.D. No. 93034 CERTIFICATE OF SERVICE AND NOW, this l0 day of July 2008, I, Michelle L. Sommer, Esquire, of A6om & Kutulakis, LL.P., hereby certify that I did serve a true and correct copy of the foregoing Motion to Make Rule Absolute by First Class U.S. Mail addressed to the following: Lindsay Shevenock 2211 Cedar Run Drive Extended Apartment C Camp Hill, PA 17011 Charles E. Petrie, Esquire 3528 Brisban Street Harrisburg, PA 17111 Attorney for Plaintiff Respectfully submitted, ABOM&KUTULAKvs L.L.P. Michelle L. Somme /,Esquire Supreme Court ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 C'm t`S'Y 4.Y cr? WILLIAM L. GLADFELTER, Plaintiff V. LINDSAY A. SHEVENOCK, Defendant JUL ? 5 ?U08 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA 2008-0048 CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this l S day of July, 2008, upon consideration of the within Motion to Make Rule Absolute, said Motion is hereby GRANTED, Michelle L. Sommer, Esquire and Abom & Kutulakis, L.L.P. are hereby granted leave to Withdraw as Counsel for the above- named Defendant, Lindsay A. Shevenock. Di tribution• belle L. Sommer, Esquire harles E. Petrie, Esquire J BY THE COURT: lk"I M. L. Ebert, J. 5 11 1-1- 1 Q? 11 -- I 4 L4.9 WY oz inf 8ooz AARON COHEN PLAINTIFF V. LISA MATUKAITIS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-46 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, _ Frida , arch 19, 2010 _, upon consideration of the attached Complaint, it is hereby directed that parties and th it respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at 39 West Main Street, Mechani sburg, PA 17055 on Monday, April 19, 2010 at 2:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defin and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conferen e may provide grounds for entry of a temporarv or permanent order. The court hereby directs the Special Relief orders, and Custody rties to furnish any and all existing Protection from Abuse orders, ers to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Es q. Custody Conciliator The Court of Common Pl as of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For i formation about accessible facilities and reasonable accommodations available to disabled individuals ha ing business before the court, please contact our office. All arrangements must be made at least 72 hours prio to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE T IS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CAN OT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT HERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 '0100,04w: FIE-OFFICE OF THE PROTHONOTARY 2010 `I ?3 P 1? 35 3• a3• I o mak, i 9- -- Swlc)a-tA