HomeMy WebLinkAbout08-0487LESTER W. GINANNI, JR., IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION-LAW
STEPHANIE E. GINANNI, NO. 0? g t l Defendant IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, comes Lester W. Ginanni, Jr., by his attorneys, Purcell, Krug & Haller
and files the following Complaint for Custody.
1. The Plaintiff is Lester W. Ginanni, Jr., residing at 823 Fishing Creek Road, New
Cumberland, York County, Pennsylvania 17070.
2. The Defendant is Stephanie E. Ginanni, residing at 1102-9 Market Street, New
Cumberland, Cumberland County, Pennsylvania 17070.
3. The Plaintiff seeks custody of the following children:
Name
Eva Rae Ginanni
Lydia Mae Ginanni
Present Residence Age
1102-9 Market Street 8
New Cumberland, PA
1102-9 Market Street 6
New Cumberland, PA
Eva Rae Ginanni, date of birth December 9, 1999 and Lydia Mae Ginanni, date of birth
April 16, 2001 are presently in the custody of the Defendant who resides at 1102-9 Market
Street, New Cumberland, Cumberland County, Pennsylvania. Since birth, the children
have resided with the following persons and at the following address:
Child
Name
Address Date
Eva Rae Ginanni
Stephanie Ginanni
Lester W. Ginanni, Jr
Stephanie Ginanni
Lydia Mae Ginanni Stephanie Ginanni
Lester W. Ginanni, Jr
Stephanie Ginanni
823 Fishing Creek Road birth to
New Cumberland, PA 12-2005
1102-9 Market Street 12-2005 to
New Cumberland, PA present
823 Fishing Creek Road birth to
New Cumberland, PA 12-2005
1102-9 Market Street 12-2005
New Cumberland, PA present
The mother of the children is the Defendant who presently is residing at 1102-9 Market
Street, New Cumberland, Cumberland County, Pennsylvania.
The father of the children is the Plaintiff who presently is residing at 823 Fishing Creek
Road, New Cumberland, Cumberland County, Pennsylvania.
4. The relationship of Plaintiff to Eva Rae Ginanni and Lydia Mae Ginanni is that of
natural Father. The Plaintiff currently resides with the following persons: none
5. The relationship of Defendant to Eva Rae Ginanni and Lydia Mae Ginanni is that
of natural Mother. The Defendant currently resides with the following persons: "Bob"
6. The 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.
The Plaintiff has no information of a custody action concerning the children pending
in a Court of this Commonwealth.
The Plaintiff does not know of a person not a party to the proceeding who has
physical custody of the children or claims to have custody or visitation rights with respect
to the children.
7. The best interest and permanent welfare of the children will be served by
granting the relief requested. The Plaintiff is more capable of providing for the needs of
the children.
WHEREFORE, the Plaintiff requests the Court to grant him custody of Eva Rae
Ginanni and Lydia Mae Ginanni.
Respectfully submitted,
Jo -V-Pfucell, Jr.
29955
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
VERIFICATION
I verify that the statements made in the foregoing Complaint for Custody are true and correct.
I understand that false statements herein are made subject to the penalties of 18 PA C.S. § 4904
relating to unsworn falsification to authorities
Dated: b - C
C7
_
1
LESTER W. GINANNI, JR. IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
STEPHANIE E. GINANNI
DEFENDANT
2008-0487 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, January 25, 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 27, 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/ Dawn S. Sunda Es a. itr
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
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LESTER W. GINANNI, JR.,
Plaintiff
vs.
STEPHANIE E. GINANNI,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION-LAW
NO. 2008-0487
IN CUSTODY
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
) ss:
COUNTY OF DAUPHIN
I, Carol Masich, legal assistant to JOHN W. PURCELL, JR., Attorney for the Plaintiff/Petitioner
in the above action, hereby swear and affirm that on the 30`h day of January, 2008, I sent, by
certified mail, return receipt requested, deliver to addressee only, a certified copy of the Complaint
for Custody containing Order of Court to Stephanie E. Ginanni, the Defendant in the above action.
The return receipt, duly signed is attached hereto and made a part hereof as Exhibit "A".
CLAA rM
Carol Masich, Legal Assistant to
JOHN W. PURCELL, JR.
Sworn and subscribed to
before,?tne thisV
day
Notary
aEALTH OF PENNSYLVANIA
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EvIree Sept. 26.2008
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MM 17 2008?
LESTER W. GINANNI, JR. IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2008-0487 CIVIL ACTION LAW
STEPHANIE E. GINANNI
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this / 5' day of lvu-,. *A , 2008, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The Father, Lester W. Ginanni, Jr., and the Mother, Stephanie E. Ginanni, shall have shared
legal custody of Eva Rae Ginanni, born December 9, 1999, and Lydia Mae Ginanni, born April 16,
2001. Major decisions concerning the Children including, but not necessarily limited to, their health,
welfare, education, religious training and upbringing shall be made jointly by the parties after
discussion and consultation with a view toward obtaining and following a harmonious policy in each
Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the
Children. Neither party shall attempt to alienate the affections of the Children from the other party.
Each party shall notify the other of any activity or circumstance concerning the Children 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.
2. On a trial basis pending the follow-up custody conciliation conference scheduled in this
Order, the parties shall have physical custody of the Children in accordance with the following
schedule:
A. Beginning Thursday, March 13, 2008, the Father shall have custody of the Children
on alternating weekends from Thursday at 4:00 p.m., when the Father shall pick up the Children
through Monday at 8:30 a.m., when the Father shall transport the Children to school or to the Mother's
residence, if there is no school. During the interim weeks, the Father shall have custody of the
Children from Thursday at 4:00 p.m. when the Father shall pick up the Children, through Friday at
8:30 a.m., when the Father shall transport the Children to school or to the Mother's residence, if there
is no school.
B. The Mother shall have custody of the Children at all times not otherwise specified
for the Father.
3. The parties shall participate in a course of co-parenting counseling with Deborah Salem or
other professional selected by agreement between the parties. The purpose of the counseling shall be
to assist the parties in establishing sufficient communication and cooperation to enable them to
effectively co-parent their Children. Each parent shall be responsible to pay the costs of his or her
individual sessions and the costs of joint sessions shall be shared equally between the parties. The
parties shall contact the counselor's office within ten (10) days of this Order to schedule the initial
sessions. The parties shall schedule and complete co-parenting sessions on a timely basis.
4. The Father shall obtain written confirmation from his physician concerning the Father's
ability to drive extended distances with small children. In the event the Father's physician is unable to
confirm that there are no restrictions on the Father's driving, the parties shall cooperate in establishing
reasonable restrictions for the Father's travel with the Children by agreement.
5. Neither party shall smoke in the presence or vicinity of the Children, including their
residence, during periods of custody. Neither party shall take the Children to bars although the parties
agree that the Children may be in the non-smoking dining areas of restaurants which include bars in a
portion of the restaurant. Both parties shall provide breakfast for the Children before school.
6. The parties and counsel shall attend a follow-up custody conciliation conference, in the
office of the conciliator, Dawn S. Sunday, on Tuesday, June 17, 2008 at 2:00 p.m. The purpose of the
conference shall be to assess the'Children's adjustment to the trial custody arrangements and establish
an ongoing custody schedule which meets their needs.
7. Neither party shall do or say anything which may estrange the Children from the other
parent, injure the opinion of the Children as to the other parent, or hamper the free and natural
development of the Children's love and respect for the other parent. Both parties shall ensure that third
parties having contact with the Children comply with this provision.
8. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the terms of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
J.
cc: ?JofW. Purcell, Jr., Esquire - Counsel for Father
-Robert B. Lieberman, Esquire - Counsel for Mother
Copt Es mat ticL
LESTER W. GINANNI, JR. IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. 2008-0487 CIVIL ACTION LAW
STEPHANIE E. GINANNI
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 Children who are the subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Eva Rae Ginanni December 9, 1999 Mother
Lydia Mae Ginanni April 16, 2001 Mother
2. A custody conciliation conference was held on March 12, 2008, with the following
individuals in attendance: the Father, Lester W. Ginanni, Jr., with his counsel, John W. Purcell, Jr.,
Esquire, and the Mother, Stephanie E. Ginanni, with her counsel, Robert B. Lieberman, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date Dawn S. Sunday, Esquire
Custody Conciliator
AUG 16 2008
LESTER W. GINANNI, JR. IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2008-0487 CIVIL ACTION LAW
STEPHANIE E. GINANNI
Defendant IN CUSTODY
ORDER
AND NOW, this 21sT day of August, 2008 , the conciliator, having been advised that
all custody issues have been resolved by agreement between the parties, hereby relinquishes
jurisdiction.
FOR THE COURT,
r
Dawn S. Sunday, Esquire
Custody Conciliator
C3
CZD
cy ??
John W. Purcell, Jr., Esquire
ID #29955
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
jpurcell@pkh.com
LESTER W. GINANNI, JR.,
Plaintiff
V.
STEPHANIE E. GINANNI,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
NO. 2008-0487
IN CUSTODY
MOTION TO
REAPPOINT CUSTODY CONCILIATOR
AND NOW, comes the Plaintiff, Lester W. Ginanni, Jr., by his attorney, Purcell,
Krug & Haller, who requests this Honorable Court to reappoint Dawn S. Sunday,
Esquire, as Conciliator, and to schedule an expedited Custody Conference, and in
support thereof, avers the following:
1. The parties had attended a Custody Conciliation Conference before
Dawn S. Sunday on March 12, 2008, after which the parties agreed to attend co-
parenting counseling to try to formulate an agreed upon Custody Order.
2. The parties did attend counseling with Anthea Stebbins, after which the
parties came to an Agreement, which counsel for the Plaintiff formulated in writing and
forwarded to counsel for the Defendant.
3. Despite the parties' agreement to the general terms, the parties have not
been able to agree on the specific language of the Order, so it is requested by the
Plaintiff that the Custody Conciliator, who previously relinquished jurisdiction, be
reappointed to schedule another Custody Conciliation Conference.
Ow
4. One of the main sticking points in the parties' agreement is Christmas
visitation, so the Plaintiff requests that the Conciliator schedule an expedited conference
prior to Christmas in an attempt to resolve that issue.
Respectfully submitted,
PURCELL, KRUG & HALLER
2
gy:
hn . Purcell, Jr., Esquire
ID #29955
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: Attorney for Plaintiff
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4 ? J
VERIFICATION
I verify that the statements made in the foregoing MOTION To APPOINT
CUSTODY CONCILIATOR are true and correct.
I understand that false statements herein are made subject to the penalties of
18 Pa. C. S. §4904 relating to unworn falsification to authorities.
r,
1
Date.
r ?.
J
CERTIFICATE OF SERVICE
I, Kimberly S. DeFalco, Legal Assistant to John W. Purcell, Jr., hereby certify that
a true and correct copy of the foregoing document was served upon the Defendant, by
sending a copy of the same via first class U.S. Mail to:
Robert B. Lieberman, Esquire
PO Box 1004
Harrisburg, PA 17108-1004
?J
Kimberly S. D Fa co, Legal Assistant to
John W. Purcell, r., Esquire
PURCELL, KRUG & HALLER
I.D. No. 29955
DATE: I??0%
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LESTER W. GINANNI, JR. IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
STEPHANIE E. GINANNI
DEFENDANT
2008-0487 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, December 09, 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, January 14, 2009 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: Is/ Daum S. Sunday, Esq. )IA
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
Akv
iNno
8 C : ! I WV 01 030 00OZ dbKUNll"j ..O d 3Hi J0
JAN ? F 20096
LESTER W. GINANNI, JR. IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2008-0487 CIVIL ACTION LAW
STEPHANIE E. GINANNI
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this z 7` day of yAn- , , 2009, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated March 18, 2008 is vacated and replaced with this Order.
2. The Father, Lester W. Ginanni, Jr., and the Mother, Stephanie E. Ginanni, shall have shared
legal custody of Eva Rae Ginanni, born December 9, 1999, and Lydia Mae Ginanni, born April 16,
2001. Major decisions concerning the Children including, but not necessarily limited to, their health,
welfare, education, religious training and upbringing shall be made jointly by the parties after
discussion and consultation with a view toward obtaining and following a harmonious policy in each
Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the
Children. Neither party shall attempt to alienate the affections of the Children from the other party.
Each party shall notify the other of any activity or circumstance concerning the Children 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.
3. The parties shall have physical custody of the Children in accordance with the following
schedule:
A. The Father shall have custody of the Children on alternating weekends from
Thursday after school at 3:30p.m (or at 10:00 a.m. if there is no school) through Sunday at 6:00 p.m.
During weeks following the Mother's weekend period of custody, the Father shall have custody from
Monday after school at 3:30 p.m. (or 10:00 a.m. if there is no school) through Tuesday when school
starts (or if there is no school at 6:00 p.m.). During weeks following the Father's weekend period of
custody, the Father shall have custody of the Children from Thursday after school at 3:30 p.m. (or at
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10:00 a.m. if there is no school) through Friday when school begins (or if there is no school at 6:00
P.M.).
B. The Mother shall have custody of the Children at all times not otherwise specified
for the Father.
4. The parties shall share having custody of the Children on holidays as follows:
A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run
from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon and Segment B, which shall
run from Christmas Day at 12:00 noon through December 26 at 12:00 noon. In even-numbered years,
the Father shall have custody of the Children during Segment A and the Mother shall have custody
during Segment B. In odd-numbered years, the Mother shall have custody of the Children during
Segment A and the Father shall have custody during Segment B.
B. Thanksgiving: In every year, unless otherwise agreed between the parties, the
Mother shall have custody on Thanksgiving Day from 9:00 a.m. until 4:00 p.m. and the Father shall
have custody from Thanksgiving Day at 4:00 p.m. through the following Friday at 6:00 p.m. or
through the entire weekend if it is the Father's weekend period of custody.
C. Easter: In every year, the Mother shall have custody of the Children on Easter
Sunday from 9:00 a.m. until 4:00 p.m., and the Father shall have custody from Easter Sunday at 4:00
p.m. through the time when school resumes on the following Monday or, if there is no school on the
Monday after Easter, until 6:00 p.m.
D. Halloween Trick or Treat: In every year, the Mother shall have custody for Trick or
Treat Night in New Cumberland. In every year, the Father shall be entitled to have custody of the
Children for Trick or Treat Night in another community on a different night, for which the parties shall
cooperate in making arrangements.
E. Memorial Day/July Fourth/Labor Day: In even-numbered years, the Father shall
have custody of the Children for Memorial Day and Labor Day from 9:00 a.m. until 6:00 p.m. and the
Mother shall have custody of the Children for July Fourth from 9:00 a.m. until after the fireworks. In
odd-numbered years, the Mother shall have custody of the Children during the same time period for
Memorial Day and Labor Day and the Father shall have custody for July Fourth.
F. Mother's Day/Father's Day: In every year, the Mother shall have custody of the
Children for Mother's Day and the Father shall have custody for Father's Day from 9:00 a.m. until
6:00 p.m.
G. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule and the vacation schedule.
5. Each party shall be entitled to have custody of the Children during the summer for two (2)
weeks, which may be scheduled either consecutively or non-consecutively. Each party shall schedule
periods of custody under this provision to include his or her regular weekend period of custody. The
parties shall provide each other with notice of his or her intention to schedule a period of custody under
this provision at least one (1) week in advance. The party providing notice first shall be entitled to
preference on his or her selection of vacation dates. In the event either party intends to remove the
Children from his or her residence for an overnight period or longer, that parent shall provide the other
parent with advance notice of the address and telephone number where the Children can be contacted.
6. Neither party shall smoke in the presence or vicinity of the Children, including their
residence, during periods of custody. Neither party shall take the Children to bars although the parties
agree that the Children may be in the non-smoking dining areas of restaurants which include bars in a
portion of the restaurant. Both parties shall provide breakfast for the Children before school.
7. Neither party shall do or say anything which may estrange the Children from the other
parent, injure the opinion of the Children as to the other parent, or hamper the free and natural
development of the Children's love and respect for the other parent. Both parties shall ensure that third
parties having contact with the Children comply with this provision.
8. Unless otherwise agreed, the parent receiving custody of the Children shall be responsible to
provide transportation for the exchange of custody, unless that parent is returning the Children directly
to school.
9. Both parties shall refrain from involving the Children in legal matters or disputes concerning
the custodial arrangements.
10. The parties agree that the Children shall not be required to clean up dog feces during either
party's period of custody.
11. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the terms of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
Kevin W Hess J.
cc: ? J hn W. Purcell, Jr., Esquire - Counsel for Father
.,Robert B. Lieberman, Esquire - Counsel for Mother
I -es f*r%&L . L
LESTER W. GINANNI, JR.
Plaintiff
vs.
STEPHANIE E. GINANNI
Defendant
Prior Judge: Kevin A. Hess
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-0487 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Eva Rae Ginanni December 9, 1999 Mother/Father
Lydia Mae Ginanni April 16, 2001 Mother/Father
2. A custody conciliation conference was held on January 16, 2009, with the following
individuals in attendance: the Father, Lester W. Ginanni, Jr., with his counsel, John W. Purcell, Jr.,
Esquire, and the Mother, Stephanie E. Ginanni, with her counsel, Robert B. Lieberman, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date Dawn S. Sunday, Esquire
Custody Conciliator