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HomeMy WebLinkAbout03-6500 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ELIZABETH Z. GRASSMYER Plaintiff vs. No. ' -03- ,"S'OC C.IOI.LTf'h.., CUSTODY - - l RANDALL S. GRASSMYER Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is ELIZABETH Z. GRASSMYER, natural mother, residing at 98 st. John's Road, Camp Hill, PA 17011. 2. The Defendant is RANDALL S. GRASSMYER, natural father, residing at 1459 Hillcrest Drive, Apt. 509, Camp Hill, PA 17011. 3. The Plaintiff seeks primary physical custody of the following child, ALEXANDER GRASSMYER, date of birth: November 15, 1993. The child is under the primary custody of mother and father exercises partial physical custody as governed by the parties' Property & Separation Agreement dated August 4, 2003. 4. During the past five years, the child has resided with the following persons and at the following addresses: A. From August, 2000 to present: with mother at 98 st. John's Road, Camp Hill, PA 17011. B. From birth to August, 2000: with mother father at 98 St. John's Road, Camp Hill, 17011. and PA 5. The mother of the child is ELIZABETH Z. GRASSMYER currently residing at 98 st. John's Road, Camp Hill, PA 17011. She is unmarried. 6. The father of the child is RANDALL S. GRASSMYER currently residing at 1459 Hillcrest Drive, Apt. 509, camp Hill, PA 17011. He is married. 7. The relationship of Plaintiff to the child is that of natural mother. 8. The Plaintiff currently resides with the following persons: a. with her mother and the child. 9. The relationship of Defendant to the child is that of natural father. 10. The Defendant currently resides with the following persons: a. new wife and their child. 11. 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 another court. 12. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Mother and child have been planning a trip to England at the end of December, 2003 and father has agreed to the trip. However, recently, father has decided that he no longer wishes to have his child travel abroad at this time. Mother and child have the plans already made and cannot cancel the plans. The child is looking forward to the trip. 15. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests Your Honorable Court to grant primary physical custody of the child, ALEXANDER GRASSMYER to natural mother, ELIZABETH Z. GRASSMYER. . .. . VERIFICATION I verify that the statements in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. e.s. ~4904, relating to unsworn falsification to authorities. DATE: IJ,-/:2 -O~ "rJ.~A. ) 1,A~ ELIZfjBETH L. ~SMYER {J ~~ i9.. - - C> . )..J r- D (); """ (). -c.J r J?: o '" c:::> = ....., L' r-'1 C' ~-.J ,._-,.", 1") \.[.) o ... ..... I rn :IJ .. ."1") lT1 ~~r8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ELIZABETH Z. GRASSMYER Plaintiff v. NO. 2003- '-.)60 CUSTODY CiofT~ RANDALL S. GRASSMYER Defendant PETITION FOR SPECIAL RELIEF AND CONFIRMATION OF CUSTODY 1. Petitioner is ELIZABETH Z. GRASSMYER, residing at 98 st. Johns Road, Camp Hill, PA 17011. 2. Respondent is RANDALL S. GRASSMYER, residing at 1459 Hillcrest Dr., Apt. 509, Camp Hill, PA 17011. 3. Custody of the parties' child, ALEXANDER GRASSMYER, is governed by the terms of a PROPERTY AND SEPARATION AGREEMENT dated August 4, 2003. Copies of the relevant portions of the Agreement are attached hereto and made a part hereof as Exhibit "An. 4. Pursuant to the terms of the Agreement, Mother has primary custody and Father has partial physical custody alternate weekends and Wednesday evenings. Both parties have two weeks vacation with thirty days notice to the other party. 5. Mother planned a trip to England and obtained a passport for her son. Father was aware of the plans and signed the documents necessary to obtain the passport. 6. Mother gave notice to Father of the planned vacation thirty days in advance. The notice was sent by Airborne Express Overnight delivery on November 25, 2003. See attached Exhibit "B". 7. On or about November correspondence from Father's attorney 28th, Mother objecting to the received vacation - 1 - plans. 8. Mother and son are traveling to England from December 26th to January 3rd. The tickets are paid for, hotel rooms and events purchased and booked. The child is looking forward to the trip. 9. Mother believes that Father will attempt to interfere with the vacation plans. 10. Plaintiff seeks to confirm custody of ALEXANDER GRASSMYER, age 10, residing with Mother at 98 st. John's Rd. camp Hill, PA. The child was not born out of wedlock. The child is presently in the custody of Mother. The child has resided with Mother at the above address since the parties separated in August, 2000. Prior to that date the parties resided together at the above address. The parties are divorced. 11. Mother resides at the above address and is divorced. Father resides at 1459 Hillcrest Dr., Camp Hill, PA 17011. He is remarried. 12. The relationship of the Plaintiff to the child is that of Mother. She resides with her mother and the child. 13. The relationship of the Defendant to the child is that of Father. He resides with his new wife and their child. 14. Plaintiff has not participated as a party or witness, or in another capacity, in other 1 i tigation concerning the custody of the child in this or another court. 15. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 16. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 17. The best interest and permanent welfare of the child will be served by granting the relief requested because Mother and son have been planning this trip for quite a long time. 18. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the - 2 - child has been named as parties to this action. WHEREFORE, Petitioner requests this Honorable Court enter an Order confirming primary physical custody of Alexander Grassmyer with Mother and confirming that Mother shall have custody of the child from December 26th, 2003 at 2 P.M. until January 3rd, 2004 at which time she returns from vacation and confirming partial custody with Father at the times set forth in the Property and Separation Agreement. RESPECTFULLY SUBMITTED, - 3 - PROPERTY AND SEPARATION AGREEMENT THIS AGREEMENT made "I-~ day of III1GtI$T by and between ELIZABETH L. GRASSMYER of 98 st. John's Hill PA, (hereinafter referred to as "WIFE"); AND RANDALL S. GRASSMYER of 98 st. John's Rd., Camp Hill, PA, (hereinafter referred to as "HUSBAND"); WHEREAS, the parties were married on October 27, 1990, and there has been one child born of this marriage, ALEXANDER, born , 200q Rd., Camp November 15, 1993. WHEREAS, the parties hereto are contemplating separation; and WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification, the settling of all matters between them related to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future, support, alimony or maintenance of WIFE by HUSBAND or of HUSBAND by WIFE; and WHEREAS, both parties agree to relinquish any and all claims which either may have against any property now owned or belonging to the other or which may hereafter be acquired by either of them by purchase, gift, devise, bequest, inheritance otherwise, except as to the obligations, covenants and agreements contained herein; NOW, THEREFORE, the parties intending to be legally bound hereby do covenant and agree that: SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The - 1 - HUSBAND agrees to file "No Fault" divorce proceeds and finalize said Divorce within three years of the date of the signing of this agreement. HUSBAND further agrees not to dissipate or borrow funds from the Sysco corporation Savings and Incentive Plan so as to reduce benefits owed to WIFE pursuant to this agreement. HEALTH INSURANCE: HUSBAND agrees to maintain major medical and hospitalization insurance on WIFE for a period of three years from the date of the execution of this Agreement. CUSTODY: The parties shall have shared legal custody of ALEXANDER so that each shall participate in major decisions affecting the best interests of said child including, but not limited to, medical, religious and educational decisions and each parent shall have access to medical, dental and school records. Mother will have primary physical custody of ALEXANDER; Father will have partial physical custody on alternate weekends from Friday at 6:00 pm until Sunday at 5:00 pm; every Wednesday from 6:00 pm until 8:00 pm; The parties shall alternate the five major holidays, i.e., Labor Day, Thanksgiving, Easter, Memorial Day and 4th of July; Christmas from December 24th at noon to December 25th at 2:00 pm with Mother every year. From December 25th at 2:00 pm to December 26th at 2:00 pm with Father. Two weeks vacation with each parent with thirty (30) days notice to other parent. CHILD SUPPORT: HUSBAND agrees to pay $100.00 per week for the support of ALEXANDER until he reaches the age of 18 or is emancipated. HUSBAND further agrees to maintain major medical and hospitalization insurance on said child. HUSBAND further agrees to be responsible for all unreimbursed dental and medical expenses incurred on behalf of said minor. HIGHER EDUCATION: HUSBAND acknowledges that the parties have planned that higher education shall be made available for their child should he qualify for formal education beyond high school. HUSBAND agrees that should their child qualify for formal education - 7 - EXECUTION OF DOCUMENTS: Each party, shall at the request of the other, execute, acknowledge and deliver any documents which may be reasonably necessary to give full effect to this Agreement. VOID CLAUSES: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue at full force, effect and operation. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. IN WITNESS WHEREOF, and intending to be legally bound, the parties have hereunto set their hands.and seals the day and year first abo e written. WITNESS ~0"4"'A'P~4d~4i4'~A.. ~. .--4..~ y ELi~ BETH....K~ER U /~/f~~, ..?I~.. ~. ~R - 11 - COMMONWEALTH OF PENNSYLVANIA ) c.u.m be.rlo..t\c:l ) SS: COUNTY OF U.Uei\.'H~R ) On this ~ day of AU/ir1o:<., , 2000, before me, a Notary Public, the undersigned officer, personally appeared ELIZABETH L. GRASSMYER, known to me or subsequently proven to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF I have hereunto set my hand and notarial seal. ~L~ Notary Public My commission ~-- ... ..-..--..... --_." . NOTAfilAL SEI\l expl.res: R08ERTA E. BIESECKER, Notary Public I C;jlnp Hjl~ 8mo. Cumberland County rl/Y t_-:ommission Expires July 23, ~Ol COMMONWEALTH OF PENNSYLVANIA ) Cu.rnberlQ.nd. ) SS: COUNTY OF ~NCAST~~ ) On this ,.. day of AII&luT , 2000, before me, a Notary public, the undersigned officer, personally appeared RANDALL S. GRASSMYER known to me or subsequently proven to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF I have hereunto set my hand and notarial seal. ~[~ Notary Public My commission expires: NOTARIAL SEAL ROBERTA E. BIESECKER. Notary Public Camp Hill Bore. Cumberlancl Cc?unly My comm~ Expitw,JuIy 23,'8llO1 . \, - 12 - Elizabeth Z. Grassmyer 98 St. John's Road Camp Hill, PA 17011 November 25, 2003 Randall S. Grassmyer 1459 Hillcrest Court Apt. 509 Camp Hill, PA 17011 Dear Randy: Although you have previously been made aware of our pending vacation as a result of signing for Alex's passport, as required per our Property and Separation Agreement dated August 4, 2000, I am giving you 30 days notice regarding taking Alex on vacation beginning December 26,2004. If you have any questions, please feel free to contact me in writing. Thank you for your cooperation. Sincerely, rP~~) &. El~b~gZ~Gr~;myer CC: File Lucile Longo SHIPMENT NO. SHIPMENT DATE WEIGHT -w= 3289 512 4813//' ~~-- 03 FRoi}lmNAM~ ~ AO~~'S" N- ~d $. i "TY !-Itu-r b P/.I I i "l',/i/)UIREO) ~ SENT BY' INAM~~'~.f.) ~ PHONE ,f z::7:;7f:.~~:^J <<IX) I "'J"1/-"5q J-I,Uere.sf- f;ft. ~ 509 ~ c'ram 1-/.;/1 !'A; [ZI?>toii'REO) ~ AnN: (NAME/~PT.) PHONE .. 111 -TfA-94tp2 ......---...-...._~-_.~~._.._.~.. --- MARIA P. COGNETTI & ASSOCIATES Attorneys & Counselors at Law 210 Gl'andview Avenue, Suire J02. Camp Hill, PA 17011 Telephone (717) 909-4060 . Fax (717) 909-4068 Email CognettiLaw@aol.com Maria P. Cognetti* A.ttomey at Law Practice Limited to Matrimonial Law Karen A. Sheriff Paralegal "Fellow, Amcricarl Academy of Matrimonial Lawyers "Fellow, International Academy of Matrimonial LawyCTS November 26, 2003 VIA UPS OVERNIGHT Tracking No. 1Z 04A 75F 22 1000 626 4 And Regular Mail Elizabeth Z. Grassmyer 98 St. Johns Road Camp Hill, PA 17011 RE: GRASSMYER V. GRASSMYER Our File No. 312 Dear Ms. Grassmyer: As you know, pursuant to the terms of your August 4,2000 Property and Separation Agreement, you and Mr. Grassmyer share legal custody of your son, Alexander. Hopefully at the time that you entered into this Agreement your attorney had explained to you the ramifications of shared legal custody. In any event, Mr. Grassmyer has shared with me your intention to take Alex out of the country on December 26,2003. Please be advised that you do not have Mr. Grassmyer's consent to do this. This matter was not discussed with him ahead of time, nor did you even bother to seek his input or his consent. Had you done so, he could have advised you that he did not approve and would not agree. Therefore, I will expect that you will either change your own personal plans or leave the child with Mr. Grassmyer during your absence. In addition to all of the obvious ramifications about travel overseas, you should likewise be aware of the fact that you cannot simply plan a vacation and knowingly take Mr. Grassmyer's custodial time away from him without his prior consent. With the above in mind, please understand that if you choose to ignore this letter, we will have no alternative but to file with the Court immediately upon your return. I am certainly hopeful that this will not be necessary. However, you should know that we look upon your 2-d ~SS:ll EO 20 oaa Elizabeth Z. Grassmyer ~ber 26, 2003 Page 2 , conduct in this matter quite seriously. This would be in total derogation of the custodial agreement. Please let Mr. Grassmyer know immediately upon your receipt ofthis letter what your intentions are in this regard. If you have any question as to the contents of this letter, please run this by your prior counsel, Ms. Longo, or any other attorney whom you would wish to consult. I will be happy to discuss this matter with him or her. Very truly yours, i~u@/;j;~ Maria P. ~ogne~~ MPC/tjb cc: Randall Grassmyer E-d ~SS:11 EO 20 oacr VERIFICATION I verify that the statements in the foregoing Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. !l4904, relating to unsworn falsification to authorities. ~!;il.~~ DATE: /;J.,- 1.2- O..i 1~~ )..; 0 II C> t~ $ o " ....., ~'.;'J cO> '-'-' r::..."'"J fi"1 o -n ...... -r- fii~ ::;~-n :,y ~:4(~} .:~~~ ;} .~ ~Yl ", -~ '....: -< , - -j -'q '.' r._.' ELIZABETH Z. GRASSMYER, PETITIONER : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. RANDALL S. GRASSMYER, RESPONDENT : 03-6500 CIVIL TERM ORDER OF COURT AND NOW, this 2'2-- day of December, 2003, a hearing on the within petition shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania at 4:00 p.m., Tuesday, December 23, 2003. /" M. Lucile Longo, Esquire ) For Petitioner C P . / / 6, I D ~{l.Lct..... Maria P. Cognetti, Esquire I.;';' '----,- /V1 For Respondent ~ ~ OJ ----- 'I :sal . , FIlED-DfF\CE OF lHE PH01\-\CNCiiNW 2UG3 DE.e 23 [Iii 8: h 0 CUl'./'::,;','~~,,->~," ',.,.' ,~~~\..>..E\l ry Pt\'~\~S\'L'>//'~';:'\.r\ ELIZABETH Z. GRASSMYER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 03-6500 CIVIL ACTION LAW RANDALL S. GRASSMYER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, December 23, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Suuday, Esq. at 39 West Main Street, Mecbanicsburg, PA 17055 on Wednesday, January 21, 2004 , the conciliator, 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 nan'ow 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 hearin/!. FOR THE COURT. By: Isl Dawn S. Sunday, Esq. Custody Conciliator L- 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 TIUS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE 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 ~!r/ ~ ~ ~l WDe'CI .~lv~~ ~rl1/ ~K [o.E~.CI ,?~ Ip '7 ~ 4; 'p:? (O'['('>-e/ ,l\;.r'!(<'," " :~:,"'::;J ,~ "1 'I' ('.J Cr:"O~O"7 t':t ~{: ~'l ~;'" ""..". I:. J... ELIZABETH Z. GRASSMYER, PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. RANDALL S. GRASSMYER, . RESPONDENT : 03-6500 CIVIL TERM AND NOW, this ORDER OF COURT -z..14 day of December, 2003, upon agreement of the parties, mother shall have custody of the child, Alexander Grassmyer, for her scheduled vacation from December 26, 2003 at 2 p.m. until January 3, 2004 at which time she returns from her trip to England. If mother does not return with the child from her scheduled vacation, she shall pay father's attorneys' fees and costs associated with any court proceedings necessitated by mother's failure to return to the United States. M. Lucile Longo, Esquire For Petitioner c c ~ ~ 11-~r()~ ':nk Maria P. Cognetti, Esquire For Respondent :sal >" cr; ""- c_ ('") LU-;;.' ~2(j I...!-::r=. 'Q'Q 60- w 0_ ~t.Ll u.- ':c .- U- o ':::0 N ~.::: 0- ("') N CO l.rJ P r'" c:;-:':? = c.... ".- . - '-:;7 ;-! ::::0) D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ELIZABETH Z. GRASSMYER VS. No. 03-6500 RANDALL S. GRASSMYER IN CUSTODY ACCEPTANCE OF SERVICE I hereby accept service of the Complaint for Custody on behalf of Randall S. Grassmyer in the above captioned action and certify that I am authorized to do so. Suite 102 17011 DATE: lO-I04: "" <= "'" ..;;:;-' o -n :;:l m:TI ,- -om -')D nT ~~ (-'.-)r'O ~:::~ ~,.,.. :-.:n -:.: "- ~ ~ m ;~ r:? .c:- .r. - v ELIZABETH Z. GRASSMYER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-6500 CNIL ACTION LAW RANDALL S. GRASSMYER Defendant IN CUSTODY ORDER OF COURT AND NOW, this 3P- day of J,~ ,2004, upon consideration of the attached Custody Conciliation Report, it IS or ed and directed as follows: 1. The parties shall engage in a course of coparenting counseling and mediation with a professional (or professionals) selected by agreement. The purpose of the coparenting counseling shall be to assist the parties in establishing sufficient communication and cooperation to enable them to effectively coparent their Child. The purpose of the mediation shall be to assist the parties on an ongoing basis to resolve conflicts which arise with regard to the custodial arrangements, including the Father's request for additional time with the Child. The parties shall equally share all costs ofthe counseling and mediation which are not reimbursed by insurance. 2. The parties shall continue to follow the custody provisions of the Marital Settlement Agreement dated August 4,2003 as clarified or modified by the provisions of this Order. 3. In even numbered years, -the Mother shall have custody of the Child on Easter, July 4th and Labor Day and the Father shall have custody on Memorial Day and Thanksgiving. In odd numbered years, the Father shall have custody of the Child on Easter, July 4th and Labor Day and the Mother shall have custody on Memorial Day and Thanksgiving. 4. In the event a party schedules a period of vacation custody during the other party's alternating weekend period of custody or weekday period of partial custody, the parties shall cooperate in scheduling a make-up period of custody either within thirty days before the vacation or within thirty days following the end of the vacation, at the election of the parent who is entitled to the make-up period. The make-up periods of custody for the Father resulting from the Mother's February 2004 period of vacation custody shall take place as follows: The Father shall have a weekend period of custody from February 6 through 8, the Mother shall have her period of weekend custody from February 13 through 15 and thereafter the parties shall resume the regular weekend schedule. The Father shall also have a make-up period of custody on Monday, March 1, 2004 for the Wednesday evening period of custody which he will miss during the Mother's vacation. 5. The party receiving custody of the Child shall be responsible to provide transportation for the exchange, with the exception of weekday evening periods of partial custody for which the Father shall provide all transportation. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions ofthis Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY~~~~ J. cc: ~UCi11e Longo, Esquire - Counsel for Mother ~~a P. Cognetti, Esquire - Counsel for Father 'b-o~ O'J.:'D ~ I-" ~~ @~ u::LU FE ~ o ~ G "J< 0... {~:i? .'-" .$: '...,:;J ;~S~ 'Lfr t' ~q[:L -~ ::5 (,) x: 0- M I en L.,l I.l... ..".. "'" ~ ELIZABETH Z. GRASSMYER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-6500 CIVIL ACTION LAW RANDALL S. GRASSMYER 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 Alexander Grassmyer November 15, 1993 Mother 2. A Conciliation Conference was held on January 27,2004, with the following individuals in attendance: The Mother, Elizabeth Z. Grassmyer, with her counsel, M. Lucile Longo, Esquire, and the Father, Randall S. Grassmyer, with his counsel, Maria P. Cognetti, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ----.J ~ ,}. Ii ,).oo~ Date ~~ Dawn S. Sunday, Esquire Custody Conciliator I:\Closed Files\Grassmyer\Pleadings\Praecipe to Withdraw Custody.wpd July 14,2005 ELIZABETH Z. GRASSMYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : 03-6500 CIVIL TERM RANDALL S. GRASSMYER, n"fendant : CIVIL ACTION - LAW : IN CT1STODY PRAECIPE FOR WITHDRAW AL/ENTRY OJr APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf ofthe Defendant, Randall S. Grassmyer, in the above-captioned matter. By: ~AP.C G MARIA P COG I, ESQUIRE Attorney LD. No. 4 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Date: 8. I . a.5 TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the Defendant, Randall S. Grassmyer, in the above- captioned matter. Date: Tl1'1le, zwS- By: ~k- RANDALL S. GRASS~f1YER, PRO SE 120 Oak Ridge Drive Halifax, P A 17032 (717) 362-1191 ~; JI \ .l.::- lJ -<1 ..... -T.:-Il \'1/"'T-~" -1~, ~gl'lJ "),.-, .' . '~." _("1 '~~> -;.:",:, ;?tlj, <5 >~ r:-? (.J') 1':-