Loading...
HomeMy WebLinkAbout08-1656KENNETH KREIDLER and SUSAN KREIDLER, Plaintiffs -vs- ANDREW MACSKIMMING and JENNIFER KREIDLER, IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA NO. Q S-"- ) ( 5- (? c rn l fi-c i . CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiffs, Kenneth and Susan Kreidler, by and through their attorney, Carrie M. Bowmaster, Esquire and avers as follows in support of this Complaint for custody. 1. Plaintiffs are Kenneth and Susan Kreidler, adult individuals currently residing at 455 Sioux Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant Andrew MacSkimming is an adult individual currently residing at 309 Third Street, Summerdale, Cumberland County, Pennsylvania. Defendant Jennifer Kreidler is an adult individual currently residing at 124 East Main Street, Shiremanstown, Pennsylvania. 3. Plaintiffs seek partial physical custody of the following minor child: Teagan Rae MacSkimming, born June 3, 2005, who resides at 309 Third Street, Summerdale, Cumberland County, Pennsylvania. 4. The minor child was born out of wedlock. 5. Plaintiffs are the maternal grandparents of Teagan. Defendant Andrew MacSkimming is the natural father of Teagan. Jennifer Kreidler is the natural mother of Teagan. 6. The child is presently in the physical custody of Defendant, Andrew MacSkimming, who resides at 309 Third Street, Summerdale, Cumberland County, Pennsylvania. 7. Since birth, the child has resided with the following persons at the following addresses: NAME Mother, Susan and Kenneth Kreidler and Aunt Jennifer Kreidler ADDRESS 455 Sioux Drive Mechanicsburg, PA 17050 DATES Birth - approx. Oct 05 Mother, Father and Paternal grandmother Needra MacSkimming Mother, Susan and Kenneth Kreidler and Aunt Jennifer Kreidler Father and Needra MacSkimming 309 Third Street Summerdale, PA 455 Sioux Drive Mechanicsburg, PA 17050 309 Third Street Summerdale, PA Oct. 05 - Jan. 06 Jan. 06 - Feb. 06 Feb. 06 - present 8. The mother of the child is Jennifer Kreidler, currently residing at 124 East main Street, Shiremanstown, Cumberland County, Pennsylvania. She is single. 9. The father of the child is Andrew MacSkimming, currently residing at 309 Third Street, Summerdale, Cumberland County, Pennsylvania. He is single. 10. The relationship of Plaintiff to the child is that of maternal grandparents. The Plaintiffs currently reside with the following persons: Name Relationship No one 11. The relationship of Defendant Andrew MacSkimming to the child is that of natural father. The Defendant currently resides with the following persons: Name Relationship Needra MacSkimming Mother Teagan Rae MacSkimming Daughter 12. The relationship of Defendant Jennifer Kreidler to the child is that of natural mother. The Defendant currently resides with the following persons: Name Relationship unknown 13. Plaintiffs have not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the child in this or any other Court. Plaintiffs have no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. Plaintiffs do not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. Plaintiffs seek partial custody of their granddaughter, Teagan, under 23 Pa.C.S.A. Section 5312. Mother and Father have been separated since February 2006, which is more than the required six months under this section. 15. Plaintiffs seek partial physical custody of the child on alternating weekends, one week each summer and holiday times. 16. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Teagan resided with grandparents for the first four months of her life and became attached to her grandparents during this time. b. Grandparents allowed Father to stay with them during Teagan's first two weeks of life so that he could establish a bond with her. c. Even after Mother moved in with Father, Teagan spent some weekends at Grandparents' home. d. When Mother and Father broke up and Grandparents did not approve of Mother's life choices, they encouraged Mother to allow Teagan to reside with Father instead of creating an unstable life for Teagan. e. From February 2007 until April 2007, Father continued to allow Grandparents frequent and overnight visits with Teagan. f. Beginning in April 2007 until June 2007, Father began to reduce the amount of time Teagan was allowed to spend with Grandparents. g. In June 2007, Father stopped all contact with Grandparents and has not allowed them to see her since then. h. Father has based his actions in part on the fact that Grandparents had adopted Teagan's mother and therefore Teagan was not their blood relative. Grandparents only see Teagan as their granddaughter and make no distinction between their children and their adopted children or their grandchildren. i. Teagan enjoyed a close relationship with Grandparents and enjoyed spending time with them. Grandparents' extended family also enjoyed a relationship with her that has not been able to continue. j. Grandparents had treated Father as one of their sons. They transported him to pre-natal appointments for Teagan, took him on family vacations and allowed him to spend overnights in their home. k. Grandparents are still willing to include Father in their family events as they believe that Teagan would benefit from such contact. 1. Mother has her own problems, including mental health issues and addiction issues. Mother is unable to exercise custody of Teagan at this time and thus is unable to continue to foster a relationship between her daughter and her parents. m. Mother does support Grandparents request for partial custody of her daughter. n. Grandparents believe that they can promote a relationship between Teagan, her Mother and their extended family without the child feeling that she must choose between parents or grandparents. o. Grandparents believe that Teagan has benefited from having a relationship with them in the past and will continue to benefit from having a relationship with them in the future. 17. 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, Plaintiffs request that this Honorable Court grant them partial physical custody of the minor child. Respectfully submitted, Date: -2 7 - Carrie M. Bowmaster, Esquire Attorney I.D. No. 70226 Attorney for Plaintiffs 505 North Walnut Street Mt. Holly Springs, PA 17065 (717) 372-3157 VERIFICATION I verify that the statements made in this document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: -r? -000 / ennet Kreidler, Plaintiff VERIFICATION I verify that the statements made in this document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: o2-o?y 40P usan Krei ler, Plaintiff W c ? 1 7.? G' c3 C> c=? _ C }} rv ' ? Q O u? n KENNETH KREIDLER AND SUSAN IN THE COURT OF COMMON PLEAS OF KREIDLER PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-1656 CIVIL ACTION LAW ANDREW MACSKIMMING AND JENNIFER KREIDLER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, March 17, 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 Tuesday, April 15, 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. 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 vilr?.' yr+ 0 S Z VY L 1 OW HOZ KENNETH KREIDLER and SUSAN KREIDLER Plaintiff vs. ANDREW MacSKIMMING and JENNIFER KREIDLER Defendants 'APR -18 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-1656 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this day of 2008, upon -kr consideration of the attached Custody Conciliation Repo , it is ordered and directed as follows: 1. The parents shall consult with each other in making all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. In the event the parties are unable to reach an agreement after consultation, the Father shall be responsible to make the ultimate decision. Each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The Father shall have primary physical custody of the Child. 3. Beginning Saturday, April 19, 2008, the maternal Grandmother shall have custody of the Child on alternating Saturdays from 9:30 a.m. until 1:30 p.m. The maternal Grandmother shall exercise her periods of custody under this provision in a public place, unless otherwise agreed between the parties. The Mother may also be present during the maternal Grandmother's periods of custody. 4. The parties shall make arrangements for a counselor or other health professional to conduct an assessment, provide counseling and issue recommendations and guidance to address the issues raised by the Father with regard to the paternal Grandfather as it relates to the well-being of the Child. The professional shall be selected by agreement between the parties. The parties shall select the professional and contact the professional's office to initiate the assessment within twenty (20) days of the date of the custody conciliation conference. 3 5. Within ninety (90) days of the date of this Order, counsel for any party or a party pro se may contact the conciliator to schedule an additional custody conciliation conference, if necessary. 6. 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. B J. cc: ? arrie M. Bowmaster, Esquire - Counsel for Maternal Grandparents elissa L. Van Eck, Esquire - Counsel for Father Jennifer Kreidler, Mother (16P t ES eylL 2 l `4 I Y/;. -1/08 t C :1 I't"I ZZ ??` J 1 E00Z 'Y KENNETH KREIDLER and SUSAN KREIDLER Plaintiff vs. ANDREW MacSKIMMING and JENNIFER KREIDLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-1656 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 Teagan Rae MacSkimming June 3, 2005 CURRENTLY IN CUSTODY OF Father 2. A custody conciliation conference was held on April 15, 2008, with the following individuals in attendance: the maternal Grandparents, Kenneth and Susan Kreidler, with their counsel, Carrie M. Bowmaster, Esquire, the Father, Andrew MacSkimming, with his counsel, Melissa L. Van Eck, Esquire, and the Mother, Jennifer Kreidler, who is not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. dwij Date Dawn S. Sunday, Esquire Custody Conciliator .11 1 a FS + 4 spp KENNETH KREIDLER and SUSAN IN THE COURT OF COMMON PLEAS OF KREIDLER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. 2008-1656 CIVIL ACTION LAW ANDREW MacSKIMMING and JENNIFER KREIDLER IN CUSTODY Defendants ORDER OF COURT AND NOW, this A day of 2008, upon consideration of the attached Custody Conciliation Re ort, it is ordered and directed as follows: The prior Order of this Court dated April 21, 2008 shall continue in effect as modified by this Order. 2. The parties and their respective counsel shall appear for a custody conciliation conference on Wednesday, September 17, 2008 at 3:00 p.m. in the office of the conciliator, Dawn S. Sunday. 3. Pending the conference scheduled in this Order, the maternal Grandmother shall have partial physical custody of the Child from Saturday, September 6, 2008 at 9:30 a.m. through Sunday, September 7, 2008 at 6:00 p.m. The Mother may also be present during the maternal Grandmother's period of custody. The maternal Grandmother shall ensure that the Child is not left alone in the care of the maternal Grandfather. BY T-ME COURT, Edward E. Guido Z cc: ame M. Bowmaster, Esquire - Counsel for Maternal Grandparents elissa L. Van Eck, Esquire - Counsel for Father ? Jennifer Kreidler, Mother (20 t e S Mla L LL Q to?OS 77 J. 3 -"J", I ;t °,y3 ,4; 1 -j 6 :01 1401 1]s (0 uz A6. VILL Sf KENNETH KREIDLER and SUSAN KREIDLER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. ANDREW MacSKIMMING and JENNIFER KREIDLER Defendants Prior Judge: Edward E. Guido 2008-1656 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 Teagan Rae MacSkimming June 3, 2005 did not attend the conference for an undetermined reason. Father 2. A custody conciliation conference was held on September 3, 2008, with the following individuals in attendance: the maternal Grandparents, Kenneth Kreidler and Susan Kreidler, with their counsel, Carrie M. Bowmaster, Esquire, the Mother, Jennifer Kreidler, who is not represented by counsel, and the Father's counsel, Melissa L. Van Eck, Esquire. The Father, Andrew MacSkimming, 3. This Court previously entered an Order in this matter on April 21, 2008, under which the Father had primary physical custody of the Child, the maternal Grandmother had partial physical custody on alternating Saturdays, at which time the Mother could be present, and arrangements were made for an assessment of issues regarding the maternal Grandfather. The present conference was scheduled at the request of the maternal Grandparents, pursuant to the April 21, 2008 Order, to review the arrangements. 4. In the absence of the Father's participation, it was agreed by the parties in attendance and the Father's counsel on his behalf that in order to establish more comprehensive arrangements for an ongoing period of time it would be beneficial for the Mother to obtain legal counsel and to reconvene the conference with both the Father and the Mother's counsel participating as well. It was also agreed that the maternal Grandmother would have a weekend period of custody in the interim as provided in the proposed Order. 5. The parties agreed to entry of an Order in the form as attached. v Date Dawn S. Sunday, Esquire Custody Conciliator KENNETH KREIDLER AND SUSAN KREIDLER Plaintiffs VS. ANDREW MACSKIMMING AND JENNIFER KREIDLER Defendants . : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-1656 CIVIL ACTION -- LAW IN CUSTODY PRAECIPE To the Prothonotary of Cumberland County, Pennsylvania: Madam/Sir: Kindly enter my appearance as the attorney of record for the Defendant, Jennifer Kreidler. Respectfully, Dated: D COYNE & COYNE, P.C. By: _Ah'? Kv- ? ? Vo ar ket Street Camp Hill, PA 1 70 1 1-4227 (717)737-0464 Pa. S. Ct. No. 53788 Attorney for Defendant Jennifer Kreidler Marie Coyne, Esqui 1M CERTIFICATE OF SERVICE I, LISA MARIE COYNE, hereby certify that I have, on the below date, caused a true and correct copies of the attached Praecipe to Enter Appearance to be served upon the person named below by way of first class mail, postage prepaid: Dawn S. Sunday, Esquire 39 West Main Street Mechanicsburg, PA 17055 Carrie M. Bowmaster, Esquire 505 North Walnut Street Mt. Holly Springs, PA 17065 Melissa L. Van Eck, Esquire 7800A Allentown Blvd. Harrisburg, PA 17112 Dated: 0 By: is arie Coyne, E quire Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Defendant Jennifer Kreidler N 4 ft AIR Cols y ; ._.. ?:® { r .• OIL C1 C r 3t t t m } C? ?p SFP 2 2 2008 KENNETH KREIDLER and SUSAN IN THE COURT OF COMMON PLEAS OF KREIDLER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff ; vs. 2008-1656 CIVIL ACTION LAW ANDREW MacSKIMMING and JENNIFER KREIDLER IN CUSTODY Defendants ORDER OF COURT AND NOW, this o* day of ' 2008, upon consideration of the attached Custody Conciliation Repoi , it is ordered and directed as follows: 1. All prior Orders in this matter are vacated. 2. The Father, Andrew MacSkimming, and the Mother, Jennifer Kreidler, shall have shared legal custody of Teagan Rae MacSkimming, born June 3, 2005. Major decisions concerning the Child including, but not necessarily limited to, her 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 the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the affections of the Child from the other party. Each parry shall notify the other of any activity or circumstance concerning the 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. 3. The Father shall have primary physical custody of the Child. 4. The Mother shall have partial physical custody of the Child on alternating weekends, beginning September 19, 2008, from Friday at 6:00 p.m. through Sunday at 5:00 p.m., for which the parent receiving custody of the Child shall be responsible to provide transportation. In addition, the Mother shall have custody of the Child every Wednesday from 1:00 p.m. until 6:00 p.m., for which the Mother shall provide all transportation. 5. The parties shall share or alternate having custody of the Child on holidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 2:00 p.m. through Christmas Day at 2:00 p.m., and Segment B, which shall run from Christmas Day at 2:00 p.m. through December 26 at 2:00 p.m. In even-numbered years, the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. In odd-numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. B. Thanksgiving: The parties shall alternate having custody of the Child for Thanksgiving, with the Mother having custody in even-numbered years and the Father having custody in odd-numbered years. The Mother's Thanksgiving period of custody shall run consecutively with her regular Wednesday period of custody so that the entire period runs from Wednesday at 1:00 p.m. through Thanksgiving Day at 6:00 p.m. C. Easter: The Easter holiday period of custody shall be the same as the regular weekend periods of custody with the Mother having custody over the Easter weekend in odd-numbered years and the Father having custody in even-numbered years. In the event the Easter weekend falls on the other party's regular weekend, the parties shall exchange weekends over Easter and the immediately following weekend so that both parties have two (2) consecutive weekends in a row and thereafter resume the regular alternating schedule. D. Memorial DU/Labor Day: In every year, the Father shall have custody of the Child for the entire Memorial Day weekend and the Mother shall have custody for the entire Labor Day weekend. In the event the holiday weekend falls on the other party's regular weekend period of custody, the parties shall also switch the weekend period of custody immediately following the holiday and thereafter resume the regular alternating schedule. E. Mother's DU/Father's Day: The Mother shall have custody of the Child every year for Mother's Day and the Father shall have custody of the Child for Father's Day, with the specific times to be arranged by agreement between the parties. F. Parents' birthdays, each party shall be entitled to have custody of the Child on his or her birthday each year, with the specific times to be arranged by agreement. G. Halloween Trick or Treat: Until the Child begins kindergarten, the parties agree that the Child will not participate in Halloween trick or treating. The parties shall continue to cooperate to resolve their differences concerning Halloween/Trick or Treat in an effort to promote the best interests of the Child. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 6. Each parent shall be entitled to have custody of the Child each summer for seven (7) consecutive days upon providing notice to the other party by the end of March. The parent providing notice first shall be entitled to preference on his or her selection of vacation days under this provision. The party scheduling vacation custody under this provision shall provide advance notice to the other parent of the address and telephone number where the Child can be contacted while on vacation. 7. The maternal Grandparents may have periods of custody with the Child during the Mother's partial custodial time as arranged between the Mother and the maternal Grandparents. 8. The Child shall not be left alone in the care of the maternal Grandfather. 9. If deemed necessary to protect the Child, either parent may request that the other parent undergo drug testing, which request shall be made through counsel. The testing shall be completed within forty-eight (48) hours of any such request. The parent requesting the testing shall pay the costs of the drug test. In the event of a positive test result, the parent testing positive shall reimburse the other parent for the costs of the testing. 10. The Father shall provide to the Mother copies of the front and back of the Child's medical insurance card as soon as possible following the conciliation conference and shall provide a duplicate medical insurance card upon receipt from the insurer. 11. 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. 12. Neither party shall use illegal drugs or consume alcohol to excess during his or her periods of custody with the Child. The parties shall ensure that parties having contact with the Child comply with this provision. 13. 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. B) Edward E. Guido J. cc: /9 ie M. Bowmaster, Esquire - Counsel for Maternal Grandparents Aelissa L. Van Eck, Esquire - Counsel for Father ,Zisa Marie Coyne, Esquire - Counsel for Mother V ?Z:1 14d ?Z d3S EQOZ MVII N? IjriiOdd 3Hl JO u; f7c -Q311A KENNETH KREIDLER and SUSAN KREIDLER Plaintiff VS. ANDREW MacSKIMMING and JENNIFER KREIDLER Defendants Prior Judge: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 2008-1656 CIVIL ACTION LAW IN CUSTODY 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 Teagan Rae MacSkimming June 3, 2005 Father 2. A custody conciliation conference was held on September 17, 2008, with the following individuals in attendance: the maternal Grandparents, Susan and Kenneth Kreidler, with their counsel, Carrie M. Bowmaster, Esquire, the Father, Andrew MacSkimming, with his counsel, Melissa L. Van Eck, Esquire, and the Mother, Jennifer Kreidler, with her counsel, Lisa M. Coyne, Esquire. 3. The parties agreed to entry of an Order in the form as attached. - Date Dawn S. Sunday, Esquire Custody Conciliator