HomeMy WebLinkAbout08-18296rk*
NICHOLAS MARTIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
:No. o t- F- I F a 9
GLENNDA MYERS,
Defendant
IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, comes the Plaintiff, Nicholas Martin, by and through his counsel,
Michael J. Whare, Esquire and avers as follows:
1. Plaintiff is Nicholas Martin, who currently resides at 7 Pine Road, Apartment
304, Mt. Holly Springs Cumberland County, Pennsylvania 17065.
2. Defendant is Glennda Myers, who currently resides at 398 Petersburg Road,
Carlisle, Cumberland County, Pennsylvania 17013.
3. Plaintiff seeks shared physical custody of
Name
Amber Ann Martin
The child was born out of wedlock.
Primary Residence DOB
398 Petersburg Road 5/10/07
Carlisle, PA 17013
The child is presently in the custody of Glennda Myers, mother, who resides at 398
Petersburg Road, Carlisle, Cumberland County, Pennsylvania 17013.
Since birth, the child has resided with the following persons at the following
addresses:
Name Addresses Dates
Nicholas Martin and
Glennda Myers
52'/2E. Penn St.
Carlisle, PA 17013
Birth- December 2007
Glennda Myers,Glenn Myers,
Lorie Myers, Nicole Myers,
398 Petersburg Road Dec. 2007 - present
Carlisle, PA 17013
The father of the child is Nicholas Martin, who resides at 7 Pine Road, Apartment
304, Mt. Holly Springs, Cumberland County, Pennsylvania 17065.
He is single.
The mother of the child is Glennda Myers, who resides at 398 Petersburg Road,
Carlisle, Cumberland County, Pennsylvania 17013.
She is single.
4. The relationship of the Plaintiff to the child is that of natural father.
The Plaintiff currently resides with the following persons:
Name
Relationship
n/a
5. The relationship of the Defendant to the child is that of natural mother.
The Defendant currently resides with the following persons:
Name Relationshin
Amber Ann Martin daughter
Lorie Myers mother
Glenn Myers father
Nicole Myers sister
Glenn Myers grandfather
6. 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.
7. Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth.
8. 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.
9. 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. All other persons, named below, who are known to have or
claim a right to custody or visitation of the child will be given notice of the
pendency of this action and the right to intervene:
Name(s) Address Basis of Claim
None
10. The best interest and permanent welfare of the child will be served by
granting the relief requested because:
a) Mother has repeatedly refused to allow father visits with his daughter despite
father's numerous requests to see his daughter.
b) Mother is impeding father's ability to foster a relationship with his daughter.
c) A Court Order of custody and structured visitation is desired so that Plaintiff
and child may plan their schedules accordingly, and so that misunderstandings and unmet
expectations regarding custody and visitation can be avoided, and also so that the child is
not used in a manipulative fashion.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant his
Complaint for shared physical custody of the child.
Respectfully submitted,
Date: ?14
Michael J. Whare, squire
3 7 East Pomfret Street
Carlisle, PA 17013
Supreme Ct. Id No. 89028
Attorney for Plaintiff
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NICHOLAS MARTIN IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
GLENNDA MYERS
DEFENDANT
2008-1829 CIVIL ACTION LAW
. IN CUSTODY
ORDER OF COURT
AND NOW, Friday, March 28, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, April 11, 2008 at 1:00 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 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By; /s/ ohn J. Manganjr., Esq. IVmJ
Custody Conciliator y
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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NICHOLAS MARTIN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 08-1829 CIVIL ACTION LAW
GLENNDA MYERS, IN CUSTODY
Defendant
ORDER OF COURT
IRK
AND NOW this ? day of April 2008, upon consideration of the attached Custody
Conciliation Report, it is Ordered and Directed as follows:
1. Legal Custody: The Father, Nicholas Martin, and the Mother, Glennda Myers, shall have
shared legal custody of Amber Ann Martin, born 5/10/2007. The parties shall have an equal
right to make 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.
Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and
information pertaining to the Child including, but not limited to, medical, dental, religious or
school records, the residence address of the Child and of the other parent. To the extent one
parent has possession of any such records or information, that parent shall be required to share
the same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
2. Physical Custody: Mother shall have primary physical custody of the Child subject to Father's
partial physical custody as follows:
a. Commencing April 11, 2008, Father shall have partial physical custody of the
Child every other weekend from Friday 7:00 pm until Monday morning 7:30
am. Father shall pick the Child up at Mother's residence, or some other
mutually agreed upon location, and shall drop off the Child at day care Monday
morning no later than 7:30 am. (On April 11, 2008, Father shall pickup the
Child at day care at 4:30 pm in order for Father and Mother to notify day care of
Father's authority to pick the Child up).
b. Every Wednesday, Father shall have physical custody of the Child from 4:30 pm
until 9:00 pm. Father shall pick the Child up at day care and return the Child to
Mother's residence no later than 9:00 pm.
C. Father shall have addition periods of physical custody of the Child as mutually
agreed to and the parties may alter/expand said times and days as mutually
necessary or proper.
3. The custodial parent shall ensure that the Child goes to bed at an appropriate time and that
appropriate child restraints are used when transporting the Child.
4. Holidays: In even years, Mother shall have custody of the Child on her birthday and Father
shall have the following day from 9:00 am until 6:00 pm or one day the next weekend from
9:00 am until 6:00 pm. In odd years, Father shall have custody of the Child on her birthday and
Mother shall have the following day from 9:00 am until 6:00 pm or one day the next weekend
from 9:00 am until 6:00 pm. Specific to 2008, Mother shall have custody of Amber on 5110
and from 8:00 am until 12:00 pm on 5111. Specific to 2008, Father shall have physical custody
of Amber from 12:00 pm on 5111 until 7:30 am Monday morning. Father shall drop the Child
off at day care Monday morning. On Father's day, Father shall have physical custody of the
Child from 8:00 am until 6:00 pm. Father shall have physical custody of Amber on Memorial
Day from 9:00 am until 3:00 pm. All other holidays shall be addressed at the updated
conciliation conference.
5. The non-custodial parent shall have telephone contact with the Child four times per week or as
mutually agreed upon.
6. Neither parry may say or do anything nor permit a third party to do or say anything that may
estrange the Child from the other party, or injure the opinion of the Child as to the other party,
or may hamper the free and natural development of the Child's love or affection for the other
party. To the extent possible, both parties shall not allow third parties disparage the other
parent in the presence of the Child.
7. In the event of a medical emergency, the custodial party shall notify the other parties as soon
as practicable after the emergency is handled.
8. During any periods of custody or visitation, the parties shall not possess or use non-prescribed
controlled substances or consumelbe under the influence of alcoholic beverages to the point of
intoxication. The parties shall likewise assure, to the extent possible, that other household
members and/or house guests comply with this provision.
9. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify
the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of
this Order shall control.
10. A status update conciliation conference is hereby scheduled for June 20th, 2008 at 1:00 pm.
the Court,
J.
Distribution:
./Michael Whare, Esq.
,,,""Glennda Myers, PO Box 437, Boiling Springs, PA 17007
, 4ohn J. Mangan, Esq.
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NICHOLAS MARTIN,
Plaintiff
V.
GLENNDA MYERS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 08-1829 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCELIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL. PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information pertaining to the Child who is the subject of this litigation is as
follows:
Name Date of Birth Currently in the Custody of
Amber Ann Martin 5/10/2007 Mother
2. A Conciliation Conference was held with regard to this matter on April 11, 2008 with
the following individuals in attendance:
The Mother, Glennda Myers, pro se
The Father, Nicholas Martin, with his counsel, Michael Whare, Esq.
3. The parties agreed to the entry of an Order in the form as attached.
Date
John. angari, Esquire
Cu od Conciliator
JUN s 7 2008,r? 6 3
NICHOLAS MARTIN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 08-1829 CIVIL ACTION LAW
GLENNDA MYERS, IN CUSTODY
Defendant
Prior Judge: Edward E. Guido, J.
lk ` ORDER OF COURT
AND NOW this day of June 2008, upon consideration of the attached Custody
Conciliation Report, it is Ordered and Directed as follows:
1. The prior Order of Court dated April 16, 2008 is hereby VACATED.
2. Legal Custody: The Father, Nicholas Martin, and the Mother, Glennda Myers, shall have
shared legal custody of Amber Ann Martin, born 5/10/2007. The parties shall have an equal right to
make 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. Pursuant to the terms of 23
Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child
including, but not limited to, medical, dental, religious or school records, the residence address of the
Child and of the other parent. To the extent one parent has possession of any such records or
information, that parent shall be required to share the same, or copies thereof, with the other parent
within such reasonable time as to make the records and information of reasonable use to the other
parent.
3. Physical Custody: Mother shall have primary physical custody of the Child subject to Father's
partial physical custody as follows:
a. Commencing July 3, Father shall have physical custody of the Child from
Thursday after day care until Monday morning July 7, 2008. Father shall pick
up and drop off Amber from/at day care.
b. Commencing Thursday July 10, 2008 Father shall have physical custody of the
Child from Thursday (picking the Child up from day care on Thursday before he
goes to work) until Saturday at 3:00 pm. The exchange on Saturday shall occur
at McDonald's on Walnut Bottom Rd. in Carlisle.
C. Commencing Thursday July 17, 2008, Father shall have physical custody of the
Child picking the Child up from day care on Thursday before work until
Monday morning on July 21, 2008, dropping Amber off at day care.
d. Father shall have physical custody of the Child on Thursday July 24, 2008,
whereby Father shall pick the Child up at day care and return the Child to day
care on Friday July 25, 2008.
e. The schedule set forth in the above sub-paragraphs 3 (a) through (d) shall
continue in subsequent weeks absent mutual agreement or further Order of
Court.
f. The parties may alter/expand said times and days as mutually necessary or
proper as long as it is in Amber's best interest.
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4. The custodial parent shall ensure that the Child goes to bed at an appropriate time and that
appropriate child restraints are used when transporting the Child.
5. Holidays: In even years, Mother shall have custody of the Child on the Child's birthday and
Father shall have the following day from 9:00 am until 6:00 pm or one day the next weekend
from 9:00 am until 6:00 pm. In odd years, Father shall have custody of the Child on the
Child's birthday and Mother shall have the following day from 9:00 am until 6:00 pm or one
day the next weekend from 9:00 am until 6:00 pm. All other holidays shall be arranged
pursuant to the attached holiday schedule.
6. The non-custodial parent shall have telephone contact with the Child four times per week or as
mutually agreed upon.
7. Neither party may say or do anything nor permit a third party to do or say anything that may
estrange the Child from the other party, or injure the opinion of the Child as to the other party,
or may hamper the free and natural development of the Child's love or affection for the other
party. To the extent possible, both parties shall not allow third parties disparage the other
parent in the presence of the Child.
8. In the event of a medical emergency, the custodial party shall notify the other party as soon as
possible after the emergency is handled.
9. During any periods of custody or visitation, the parties shall not possess or use non-prescribed
controlled substances or consume/be under the influence of alcoholic beverages to the point of
intoxication. The parties shall likewise assure, to the extent possible, that other household
members and/or house guests comply with this provision.
10. Each parent shall have two non-consecutive weeks of vacation with the Child per year. The
requesting parent shall give the other parent at least 30 days advance notice of the requested
time and this vacation week shall supersede the regular physical custody schedule. In the event
the parties schedule conflicting vacations, the party first providing written notice shall have the
choice of vacation. Prior to departure, the parties will provide each other with information
regarding the intended vacation destination and a telephone number at which they can be
reached during their vacation. The parties may expand/alter this vacation time by mutual
agreement. It has been agreed that Mother shall have Amber from 9:00 am Friday July 18,
2008 until Saturday July 19, 2008 at 6:00 pm. The Saturday exchange shall be at the
McDonald's on Walnut Bottom Rd. Mother shall also have vacation with Amber from August
16, 2008 through August 23, 2008.
11. In the event the custodial parent should take the Child out of state, the custodial parent shall
notify the non-custodial parent within twenty-four hours of departure of the intended
destination and a telephone number at which they can be reached.
12. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify
the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of
this Order shall control.
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I?rstribution:
Y ichael Whare, Esq.
./C91ennda Myers, 192 Big Spring Terrace, Newville, PA 17241
ohn J. Mangan, Esq.
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HOLIDAYS AND
SPECIAL DAYS TBMS EVEN
YEARS ODD
YEARS
Easter Da Is Half From 8 am until 2 m Father Mother
Easter Da 2° Half From 2 m until 8 m Mother Father
Memorial Da From 8 am until 8 m Mother Father
Independence Da From 8 am until 8 m Father Mother
Labor Da From 8 am until 8 m Mother Father
Halloween From one hour before trick or
treating to one hour after trick or
treating Father Mother
Thanksgiving 1
Half From 8 am Thanksgiving Day to 2
m on Thanksgiving Da Father Mother
Thanksgiving 2°
half From 2 pm on Thanksgiving Day to
noon the day after Thanksgiving Da Mother Father
Christmas 1 s Half From noon on 12/24 to noon on
12/25 Father Mother
Christmas 2° Half From noon on 12/25 to noon on
12/26 Mother Father
Mother's Da From 8 am until 8 m Mother Mother
Father's Da From 8 am until 8 m Father Father
NICHOLAS MARTIN,
Plaintiff
V.
GLENNDA MYERS,
Defendant
Prior Judge: Edward E. Guido, J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 08-1829 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUNEVIARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information pertaining to the Child who is the subject of this litigation is as
follows:
Name Date of Birth Currently in the Custody of
Amber Ann Martin 5/10/2007 Mother
2. A Conciliation Conference was held with regard to this matter on April 11, 2008, an
Order of Court was issued April 16, 2008 and an updated conference was held on June 26, 2008 with
the following individuals in attendance:
The Mother, Glennda Myers, pro se
The Father, Nicholas Martin, with his counsel, Michael Whare, Esq.
3. The parties agreed to the entry of an Order in the form as attached.
Date John angan, E e
Cust d Conciliat
NICHOLAS MARTIN IN THE COURT OF COMMON PLEAP)F
PLAINTIFF CUMBERLAND COUNTY, PENNSYA,NI' ?i
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V. 2008-1829 CIVIL ACTION LAW
GLENNDA MYERS
' ...
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Thursday, May 10, 2012 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, June 12, 2012 at 9:30 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/ jacgueline M. Verney, Esq
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
7tv 460
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NICHOLAS MARTIN,
Plaintiff
V.
GLENNDA MYERS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008-1829
CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this 2,1 N ay of L/ u n/ f . , 2012, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Order of Court dated June 30, 2008 is hereby vacated.
2. The Mother, Glennda Myers and the Father, Nicholas Martin, shall have
shared legal custody of Amber Ann Martin, born May 10, 2007. Each parent shall have
an equal right, to be exercised jointly with the other parent, to make 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. Pursuant to the terms of
Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to
the child including, but not limited to medical, dental, religious or school records, the
residence address of the child and the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent. Both parents shall be
entitled to full participation in all educational and medical/treatment planning meetings
and evaluations with regard to the minor child. Each parent shall be entitled to full and
complete information from any physician, dentist, teacher or authority and copies of any
reports given to them as parents including, but not limited to: medical records, birth
certificates, school or educational attendance records or report cards. Additionally, each
parent shall be entitled to receive copies of any notices which come from school with
regard to school pictures, extracurricular activities, children's parties, musical
presentations, back-to-school nights, and the like.
3. During the school year, Mother shall have primary physical custody of the
child.
4. During the school year, Father shall have partial physical custody of the
child on alternating weekends, from Friday at 5:00 p.m. to Monday when Father shall be
responsible for transporting the child to school. In the event that the child has an
unexcused tardy or absence from school on Father's Monday, then Father's alternating
weekend shall end on Sunday at 5:00 p.m. In the event of a Monday school holiday
falling on Father's weekend, Father shall have physical custody of the child until Monday
at 5:00 p.m.
5. During the summer the parties shall have shared physical custody on a
week on/week off schedule except that Father shall not have more than 4 weeks in the
summer. It is contemplated that Father's week on/week off schedule shall begin the first
week after school ends and Father will end his week on/week off schedule in early
August. The exchange day and time shall be Sundays at 5:00 p.m.
6. Holidays:
A. Thanksgiving shall be alternated with Mother having physical custody
of the child in even numbered years and Father having physical
custody of the child in odd numbered years. The times shall be from
9:00 a.m. to 7:00 p.m.
B. Christmas shall be divided into two Blocks. Block A shall be from
Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block
B shall be from Christmas Day at 12:00 noon to December 26 at 12:00
noon. Father shall have Block A in even numbered years and Block B
in odd numbered years. Mother shall have Block A in odd numbered
years and Block B in even numbered years.
C. Easter shall be alternated with Mother having physical custody of the
child in odd numbered years and Father having physical custody of the
child in even numbered years. The times shall be from 9:00 a.m. to
7:00 p.m.
D. The following holidays shall be alternated among the parties:
Memorial Day, July 4`h, Labor Day. Father shall have July 4a' 2012
and the parties shall alternate the aforementioned holidays thereafter.
E. Mother shall have physical custody of the child on Mother's Day and
Father shall have physical custody of the child on Father's Day from
9:00 a.m. to 7:00 p.m.
7. Except as set forth otherwise in this Order of Court, the parties shall share
transportation by meeting at the Applebee's parking lot in Carlisle, Pennsylvania.
8. The non-custodial parent may initiate telephone contact with the child on
alternating days.
10. RELOCATION. No party shall be permitted to relocate the residence of
the child which significantly impairs the ability to exercise custody unless every
individual who has custodial rights to the child consents to the proposed relocation or the
court approves the proposed relocation. A person proposing to relocate MUST comply
with 23 Pa.C.S.§5337.
11. 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
Edward E. Guido J.
cc Jane Adams, Fsquire, Counsel for Mother
?Michael J. Whare, Esquire, Counsel for Father
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NICHOLAS MARTIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008-1829 CIVIL ACTION - LAW
GLENNDA MYERS,
Defendant : IN CUSTODY
PRIOR JUDGE: Edward E. Guido, J.
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
Amber Ann Martin May 10, 2007 Mother
2. A Conciliation Conference was held in this matter on June 19, 2012, with
the following in attendance: The Mother, Glennda Myers, with her counsel, Jane Adams,
Esquire, and the Father, Nicholas Martin, with his counsel, Michael J. Whare, Esquire.
3. The Honorable Edward E. Guido previously entered an Order of Court
dated June 30, 2008 providing for shared legal and shared physical custody.
4. The parties agreed to an Order in the form as attached.
Date Jac eline M. Verney, Esquire
Custody Conciliator