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HomeMy WebLinkAbout08-2247 LEE C. HALL, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008 CIVIL TERM MELODY HOPE HALL, Defendant CIVIL ACTION-LAW NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 LEE C. HALL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008 - CIVIL TERM MELODY HOPE HALL, CIVIL ACTION-LAW Defendant DIVORCE COMPLAINT 1. Plaintiff is Lee C. Hall, an adult individual who currently resides at 20 Round Hill, Apt. 1, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Melody Hope Hall, an adult individual who currently resides at 355 St. Johns Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 15, 1988 in Thurmont, Alabama. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in Counseling. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Date: lq 4 .9 N Respectfully submitted, O'BRIEN, BARIC & SCHERER Mica .. Scherer, Esquire I.D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. Date: Yt 7 ?O g 4L aC//' Lee C. Hall Fn Cf1 " 1? J } co d t-n LEE C. HALL, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA MELODY HOPE HALL, Defendant NO. 2008 - 2247 CIVIL TERM CIVIL ACTION-LAW ACCEPTANCE OF SERVICE AND NOW, this 3 day of &Vit , 2008, I, Samuel L. Andes, Esquire, on behalf Melody Hope Hail, accept service of the Divorce Complaint in the above-captioned case. Samuel L. Andes, Esquire cA ? cc? LEE C. HALL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. MELODY HOPE HALL, Defendant NO. 2008 - AA '7 CIVIL TERM CIVIL ACTION-LAW CUSTODY COMPLAINT 1. Plaintiff is Lee C. Hall, an adult individual who currently resides at 20 Round Hill, Apt. 1, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Melody Hope Hall, an adult individual who currently resides at 355 St. Johns Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The parties are the parents two minor children, namely, Savannah Hope Hall, born October 10, 1994 and Tristan Charles Hall, born February 11, 2005. The children were born in wedlock. The children are presently in the custody of Defendant at 355 St. Johns Drive, Camp Hill, Cumberland County, Pennsylvania. During the past five years, the child has resided with the following persons at the following addresses: Persons Residences Dates Lee and Hope Hall 355 St. Johns Drive 2003 to Present Camp Hill, Pennsylvania 17011 The natural father of the children is Lee C. Hall, currently residing at 20 Round Hill, Apt. 1, Camp Hill, Cumberland County, Pennsylvania 17011. He is married to the Defendant. The natural mother of the children is Melody Hope Hall, currently residing at 355 St. Johns Drive, Camp Hill, Cumberland County, Pennsylvania 17011. She is married to the Plaintiff. 4. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with the following persons: Names Relationship Amy Katherman Girlfriend 5. The relationship of the Defendant to the children is that of natural mother. The Defendant currently resides with the following persons: Names Relationship Alyxandra Lee Hall Daughter Savannah Hope Hall Daughter Tristan Charles Hall Son 6. 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. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings 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 parties shared legal and shared physical custody. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children 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 children will be given notice of the pendency of this action and the right to intervene: none WHEREFORE, Plaintiff requests your Honorable Court to grant him shared legal and shared physical custody of Tristan Charles Hall and shared legal and partial physical custody of Savannah Hope Hall. Date: I. l o " o ' Respectfully submitted, O'BRIEN, BARIC & SCHERER Michael A. Scherer, Esquire 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff VERIFICATION I verify that the statements made 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. § 4904, relating to unsworn falsification to authorities. Date: E lgi f Lee C. Hall 3 Fie (yV?? ? v ? ?' C ? S mil 5 1 = LEE C. HALL . IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-2247 CIVIL ACTION LAW MELODY HOPE HALL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, September 16, 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 Tuesday, October 14, 2008 at 10:00 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/ ohn . Man an r. ES O. 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 --Ap- . ov?4p Awe IV- ?rbR??t 'NN3 LEE C. HALL, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA MELODY HOPE HALL, Defendant NO. 2008 - 2247 CIVIL TERM CIVIL ACTION-LAW ACCEPTANCE OF SERVICE AND NOW, this Z% day of , 2008, I, Samuel L. Andes, Esquire, on behalf Melody Hope Hall, accept service of the Custody Complaint in the above-captioned case. rQw'? " amuel L. Andes, Esquire CD r y cn LEE C. HALL, v. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA MELODY HOPE HALL, Defendant NO. 2008-2247 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on April 9, 2008. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree in divorce without notice. 4. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 6. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 1 /dy - ?_a Lee C. Hall C> ? -ia ??? `?` -; ?? ; E'?^a Tw:?:_ _` -` t ,.. ?? ::a ,. __ ,.?. ' , . ?: ;, ,?? ,,.?t .?", .? . OCT 14 200 u LEE C. HALL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-2247 CIVIL ACTION LAW MELODY H. HALL, IN CUSTODY Defendant ORDER OF COURT 11? AND NOW this ? day of October 2008, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Lee C. Hall, and the Mother, Melody H. Hall, shall have shared legal custody of Savannah Hope Hall, born 10/10/1994 and Tristan Charles Hall, born 02/11/2005. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their 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 Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children 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 Children subject to Father's physical custody as follows: a. Father shall have liberal physical custody of Savannah as the parties may agree. b. In week one, commencing October 14, 2008, Father shall have physical custody of Tristan Tuesday picking Tristan up at day care at 5:00 pm and have custody until Thursday morning October 16, 2008 dropping Tristan off at day care at 8:00 am. C. In week two, commencing October 23, 2008, Father shall have physical custody of Tristan Thursday picking Tristan up from day care at 5:00 pm and have custody until Sunday October 26, 2008 dropping Tristan off at Mother's residence at 5:00 pm. d. Father's physical custodial schedule outlined above shall be repeated in subsequent weeks. e. Father shall have additional periods of physical custody of the Children at such other times as the parties may mutually agree. 3. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 4. Holidays: The parents shall alternate the holidays and arrange the holiday schedule as attached unless otherwise mutually agreed upon. .i 5. In the event the custodial parent should take the Children 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. 6. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. 7. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible 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 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. 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 conference is hereby scheduled before the assigned conciliator January 20, 2009 at 9:00 am at the Court of Common Pleas. The parties may cancel/reschedule said conference as desired or necessary upon written notification to the assigned conciliator. By the Court, J. Distribution: Michael Scherer, Esq. Samuel Andes, Esq. .n1 u ?Zo?t Ln /? is-- John J. Mangan, Esq. N Id ZZ e5 WV S 1 130 8002 3, Hl J0 HOLIDAYS AND TEVIES EVEN ODD SPECIAL DAYS YEARS YEARS Thanksgiving I' From 8 am Thanksgiving Day to 2 Father Mother Half m on Thanksgiving Da Thanksgiving 2° From 2 pm on Thanksgiving Day to Mother Father half noon the day after Thanksgiving Da Christmas 1 S Half From 2 pm on 12/24 to 2 pm on Mother Father 12/25 Christmas 2" Half From 2 pm on 12/25 to 2 pm on Father Mother 12/26 LEE C. HALL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-2247 CIVIL ACTION LAW MELODY H. HALL, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Savannah Hope Hall 10/10/1994 Primary Mother Tristan Charles Hall 02/11/2005 Primary Mother 2. A Conciliation Conference was held with regard to this matter on October 14, 2008 with the following individuals in attendance: The Mother, Melody H. Hall, with her counsel, Samuel Andes, Esq. The Father, Lee C. Hall, with his counsel, Michael Scherer, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date 'langan, Esquire Conciliator LEE C. HALL, Plaintiff vs. MELODY HOPE HALL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-2247 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 9 April 2008 and served upon the Defendant on or about 23 April 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. 1 consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. 1 understand that i will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. kt ce oS (K D? P-0 5iq Date : MELODY H E HALL N_ C m F ?. " C..W CD ?C3 LEE C. HALL, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA MELODY HOPE HALL, Defendant NO. 2008-2247 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant's counsel, Samuel L. Andes, Esquire signed an Acceptance of Service on behalf of Defendant on April 23, 2008. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff on September 11, 2008; and Defendant on November 6, 2008. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: The parties signed Waivers of Notice of Intent to Request Entry of Divorce Decree. Respectfully submitted, O'BRIEN, BARIC & SCHERER IX& 4k Mich el A. Scherer, Esquire 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 T 9, ) LEE C. HALL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ; MELODY HOPE HALL NO. 2008-2247 CIVIL TERM DIVORCE DECREE AND NOW, Na-4t-%)b .r 1a 1601-, it is ordered and decreed that LEE C. HALL , plaintiff, and MELODY HOPE HALL bonds of matrimony. defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, ,?07? iv e An JAN 212009 LEE C. HALL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-2247 CIVIL ACTION LAW MELODY H. HALL, IN CUSTODY Defendant Prior Judge: M.L. Ebert, Jr., J ORDER OF COURT th AND NOW this *1 D day of January 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: The prior Order of Court dated October 15, 2008 is hereby VACATED and replaced with this Order. 2. Legal Custodv: The Father, Lee C. Hall, and the Mother, Melody H. Hall, shall have shared legal custody of Savannah Hope Hall, born 10/10/1994 and Tristan Charles Hall, born 02/11/2005. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their 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 Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children 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 Children subject to Father's physical custody as follows: a. Father shall have liberal physical custody of Savannah as the parties may agree. b. In week one, Father shall have physical custody of Tristan Wednesday picking Tristan up at day care at 5:00 pm and have custody until Friday morning dropping Tristan off at day care/school at 8:00 am. C. In week two, Father shall have physical custody of Tristan Thursday picking Tristan up from day care at 5:00 pm and have custody until Monday morning dropping Tristan off at day care/school at 8:00 am. d. Father's physical custodial schedule outlined above shall be repeated in subsequent weeks. e. It is understood that once Tristan begins school, the pick up location at 5:00 pm will have to be altered to a parent's residence or care-giver's residence absent mutual agreement. f. Father shall have additional periods of physical custody of the Children at such other times as the parties may mutually agree. 4. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 5. Holidays: The holiday schedule shall supersede the regular physical custodial schedule. The parents shall alternate the holidays and arrange the holiday schedule as attached unless otherwise mutually agreed upon. 6. Counseling: The parties are directed to engage in therapeutic family counseling with a mutually-agreed upon professional. In the absence of agreement, the parties shall engage Dr. Gil. The cost of said counseling, after appropriate payment through insurance, shall be split equally between the parties. 7. Each parent shall have two non-consecutive weeks of vacation with the Child/ren per year. The requesting parent shall give the other parent 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 this vacation time by mutual agreement. 8. In the event the custodial parent should take the Children 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. 9. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. 10. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 11. 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. 12. The instant Order has currently resolved the custodial issues and the parties may file for a modification upon a showing of a significant change in circumstances. 13. 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. By the Court, 0 A n.i ' ! Wv 90 NVIP 6002 3Hi JO Distribution: ,/Michael Scherer, Esq. v6amuel Andes, Esq. J1ohn J. Mangan, Esq. HOLIDAYS AND TIMES EVEN ODD SPECIAL DAYS YEARS YEARS Easter Da 1 g Half From 9 am until 3 m Father Mother Easter Da 2n Half From 3 m until 9 m Mother Father Memorial Day From 6 pm the day before the Mother Father holiday until 6 pm the day of the holiday Independence Day From 6 pm the day before the Father Mother holiday until 6 pm the day of the holiday Labor Day From 6 pm the day before the Mother Father holiday until 6 pm the day of the holiday Halloween From one hour before trick or Father Mother treating to one hour after trick or treating Thanksgiving 1 From 8 am Thanksgiving Day to 2 Father Mother Half m on Thanksgiving Da Thanksgiving 2° From 2 pm on Thanksgiving Day to Mother Father half noon the day after Thanksgiving Day I Christmas 1 s Half From 2 pm on 12/24 to 2 pm on Mother Father 12/25 Christmas 2° Half From 2 pm on 12/25 to 2 pm on Father Mother 12/26 Mother's Day From 6 pm the day before the Mother Mother holiday until 6 pm the day of the holiday Father's Day From 6 pm the day before the Father Father holiday until 6 pm the day of the holiday LEE C. HALL, Plaintiff V. MELODY H. HALL, Defendant Prior Judge: M.L. Ebert, Jr., J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-2247 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL. PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 2. The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Savannah Hope Hall 10/10/1994 Mother and Father Tristan Charles Hall 02/11/2005 Mother and Father 2. A Conciliation Conference was held with regard to this matter on October 14, 2008, an Order issued October 15, 2008 and a status update conference held on January 20, 2009 with the following individuals in attendance: The Mother, Melody H. Hall, with her counsel, Samuel Andes, Esq. The Father, Lee C. Hall, with his counsel, Michael Scherer, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date JohA J an squire Cust y C ciliator