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Home My WebLink About04-1026BRYANT A. MANNING, Plaintiff VS. IRIS M. MOSLEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CUSTODY COMPLAINT FOR CUSTODY AND NOW, this 9~ day of March, 2004, comes the Plaintiff, BRYANT A. MANNiNG, by an through his Attorneys, the Law Offices of BATURIN & BATURIN, and files this Complaint for Custody and respectfully represents as follows: 1. The Plaintiff is BRYANT A. MANNING, an adult individual, suijuris, who currently resides at 328 N. College Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. The Defendant is IRIS M. MOSLEY, an adult individual, suijuris, who currently resides at 328 N. College Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant were never married, and have recently separated. 4. The Plaintiff and Defendant are the natural parents of one (1) child, BRYANT A. MANNING, JR., presently 6 years of age ( born 08/06/1997). Said minor child is the subject of this Custody Complaint. 5. Plaintiff seeks full legal and primary physical custody of the parties' minor child, BRYANT A. MANNiNG, JR. 6. The aforementioned minor child is presently in the physical custody of his natural father and Natural mother, Bryant A. Manning and Iris M. Mosley, the Plaintiffand Defendant, respectively, in the Custody Complaint, and resides at 328 N. College Street, Carlisle, Cumberland County, Pennsylvania 17013. Since birth, said child has lived at the following addresses with the following persons: Birth - present ADDRESS 328 N. College Street Carlisle, PA 17013 CUSTODY Natural Father, Natural Mother, and step-brother The relationship of the Plaintiff in the Custody action to subject minor child is that of natural father. The Plaintiff is single and currently resides with his minor son, Bryant A. Manning, Jr. 9. The relationship of the Defendant in the Custody action to subject minor child is that of natural mother. The Defendant is currently single. 10. The Plaintiffhas not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the aforementioned minor child. 11. The Plaintiff has no information ora custody proceeding concerning the child pending in a Court of this Commonwealth. 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. 12. The best interest and permanent welfare of said minor child will be served by granting the relief requested because: a. Plaintiff/natural father is well able to adequately provide for the continuing health, educational needs and general welfare of said child; b. Plaintiff/natural father is well able to adequately provide for said child with a proper and wholesome environment, physically, emotionally, psychologically and socially, within which to live; Plaintiff/natural father has been a primary caretaker of the child since his birth; d. The Defendant, through the minor child, has informed the Plaintiffthat she is going to move to North Carolina and take the minor child to move in with the Defendant's grandmother. The Plaintiff attempted to discuss this move with the Defendant but she refuses to discuss same. The Defendant has given her two week notice at work and has closed her bank accounts. e. The minor child has numerous family members in the Carlisle?rlarrisburg area and frequently sees them and participates in family functions with them. The minor child has only spent one (1) weekend with Defendant/natural mother's grandmother and has never meet the Defendant's other family members; f. Defendant/natural mother is threatening to take their minor child to North Carolina and not allow Plaintiff/natural father to have any access to the child; g. Defendant/natural mother has needed mental health drugs for daily stresses. Defendant/natural mother will often call Plaintiff/natural father at work after picking up the minor child fi.om school and tell him that she can not control him and that he acts uncontrollable for her. h. The minor child has been having multiple night tremors since Defendant/natural mother informed him that they were leaving to move to North Carolina. i. It is in the best interest of the child generally that primary legal and physical custody be granted to the child's natural father, Bryant A. Manning, Plaintiff herein. WHEREFORE, Plaintiff, Bryant A. Manning, requests this Honorable Court to grant the relief requested, and any other relief deemed appropriate, and enter a Final Order granting primary legal and physical custody of said minor child, Bryant A. Manning, Jr., to the Plaintiff, Bryant A. Manning. Dated: March 9, 2004 Respectfully submitted, BATUR1N & BATURIN By: \ Madelaine N. Baturin Attorney ID #68971 717 North Second Street Harrisburg, PA 17102 (717) 234-2427 Attorney for Plaintiff 4 VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THIS COMPLAINT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, BELIEF, AND INFORMATION. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. BRYANT A. MANNING, Petitioner/Defendant IRIS M. MOSLEY, Respondent/Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. D CIVIL ACTION - CUSTODY EMERGENCY PETITION FOR SPECIAl. RELIEF AND NOW, this 9t~ day of March, 2004, comes the Petitioner, BRYANT A. MANNING, by and through his Attorneys, the Law Offices of BATURIN & BATURIN, and files this Emergency Petition for Special Relief and respectfully represents as follows: 1. The Petitioner is BRYANT A. MANNING, an adult individual, suijuris, who currently resides at 328 N. College Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. The Respondent is IRIS M. MOSLEY, an adult individual, suijuris, who currently resides at 328 N. College Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Petitioner has simultaneously with this Petition filed a Petition for Custody seeking full legal and primary physical custody.. 4. The Petitioner and Respondent are the natural parents of one (1) child, BRYANT A. MANNING, JR., presently 6 years of age ( bom 08/06/1997). The parties were never married but were romantically involved until recently. 5. The minor child is presently in the physical custody of his natural father and Natural mother, Bryant A. Manning and Iris M. Mosley, respectively, as all parties reside at 328 N. College Street, Carlisle, Cumberland County, Pennsylvania 17013. 6. The child has resided at the above address almost since his birth. The child attends school in Cumberland County and is driven to school in the morning by the Petitioner. 7. Petitioner has been a primary caretaker of the child since his birth. 8. The child has recently told the Petitioner that the Respondent is going to take the child and move to North Carolina. When the Petitioner questioned the Respondent about this move, she refused to discuss or deny same. 9. It has came to the Petitioner's attention that the Respondent has given her two (2) week notice at work and has began closing bank accounts in order that she can move to North Carolina with her grandmother. 10. The child was born and raised in the Carlisle area and has numerous family members in the Carlisle/Harrisburg area and frequently sees them and participates in family functions with them. The minor child has only spent one (1) weekend with the Respondent's grandmother and has never met the Respondent's other family members. 11. The Respondent has a history of needing and using mental health medication for daily stresses. The Respondent will often call Plaintiff/natural father at work after picking up the minor child from school and tell him that she can not control him and that he acts uncontrollable for her. 12. The minor child has been having multiple night tremors since the Respondent informed him that they were leaving to move to North Carolina. 13. The Petitioner believes that his son is in emergency situation whereby the Respondent is going to take him out of school and environment he is accustomed to for the past six years and move his to North Carolina. 14. The Petitioner does not want his son to be taken out of the Commonwealth of Pennsylvania. WHEREFORE, Petitioner, Bryant A. Manning, requests this Honorable Court to grant the relief requested, and any other relief deemed appropriate, and enter a Temporary Order granting primary legal and physical custody of said minor child, Bryant A. Manning, Jr., to the Petitioner, Bryant A. Manning and to Order that the child Bryant A. Manning Jr., is not to be removed from the Commonwealth of Pennsylvania until further Order of Court. Dated: March 9, 2004 Respectfully submitted, BATURIN & BATURIN Madelaine N. Baturin Attorney ID #68971 717 North Second Street Harrisburg, PA 17102 (717) 234~2427 Attorney for Plaintiff 3 VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THIS PETITION ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, BELIEF, AND INFORMATION. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. BRYANT A. MANNING, PETITIONER V. IRIS M. MOSLEY, RESPONDENT AND NOW, this : IN THE COURT OF COMMON PLEAS OF · ' CUMBERLAND COUNTY, PENNSYLVANIA : 04-1026 CIVIL TERM ORDER OF COURT day of March, 2004, upon review and consideration of the petition for emergency relief, IT IS ORDERED that neither petitioner nor respondent may relocate and remove said child, BRYANT A. MANNING, JR. out of the Commonwealth of Pennsylvania until further order of court. A hearing on the within petition shall commence at 11:00 a.m., Tuesday, March 23, 2004, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. Edgar B. Bayley, J. :sal BRYANT A. MANNING PLAINTIFF V. IRIS M. MOSLEY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 04-1026 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, Thursday, March 18, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Tuesday, April 20, 2004 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effbrt 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. All children age five or older may also be l~resent at the conference. Failure to al3!oear at the conference ma,/ 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/ Melissa P. Greevy, Esq, mac 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 he 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 SHERIFF'S RETURN - REGULAR CASE NO: 2004-01026 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANNING BRYANT A VS MOSLEY IRIS M ROBERT BITNER Cumberland County, Pennsylvania, says, the within COMPLAINT - CUSTODY MOSLEY IRIS M DEFENDANT at 1409:00 HOURS, at 328 N COLLEGE STREET CARLISLE, PA 17013 ERIC SWAiN-N, FRIEND, Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon on the 19th day of March by handing to ADULT IN CHARGE a true and attested copy of COMPLAINT - CUSTODY ORDER OF COURT, EMERGENCY PETITION FOR SPECIAL RELIEF and at the , 2004 together with the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this 23,c,q day of ~ ~Y30~ A.D. / t~rothonotary / So Answers: R. Thomas Kline 03/19/2004 HARRY BARURIN eputy-Sheri'ff BRYANT A. MANNING, : Petitioner : V. : IRIS M. MOSLEY, : Respondent : IN THE COURT OF COM~MON PLEAS OF CUMERLAND COUNTY, PENNSYLVANIA No. 04-1026 CIVIL TERM ORDER OF COURT AND NOW, this 23rd day of March, 2004, this matter having been called on a petition by the father for special relief, with the mother having moved to North Carolina, and the father objecting to her moving their son, Bryant A. Manning, Jr., born August 6, 1997, there being a conciliation conference scheduled for April 20, 2004, on the merits of a custody complaint filed by father, and the child being in first grade and not scheduled to complete this school term until June 2004, and the parites having reached an interim agreement, without prejudice to either one to make claims for custody in the merits proceeding, it is ordered, that Bryant shall remain with his father until the end of the school year, pending further Order of Court, and that in the interim, the father and the mother will make arrangements for Bryant to see the mother as convenient and available for both parties. By the~'~ Edgar B. Bayley, J. ~adelaine N. Baturin, Esquire For the Petitioner jMichael A. Scherer, Esquire For the Respondent wcy BRYANT A. MANNING, ) Plaintiff : ) vs. : NO. 04-1026 ) IRIS M. MOSLEY, : Defendant ) CUSTODY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CERTIFICATE OF SERVICE I, Madelaine N. Baturin, Esquire, of the Law Firm of Baturin & Baturin, attorneys for the Plaintiff in the above-captioned matter, do hereby certify that on March 17, 2004, I deposited in the United States Mail, Harrisburg, Pennsylvania, an article of Certified Mail, Return Receipt Requested, a clocked-in copy of the Complaint For Custody and a certified copy of the Order of Court scheduling a conciliation conference, beating Article No. 7000 0520 0023 0126 4158, addressed to: Iris M. Mosley, 1426 4 Forks, Elizabeth City, North Carolina 27909. The said article of Certified Mail, as shown by the Postal Return Receipt Card, was received by the Defendant on March 25, 2004, and according to same, was signed, to wit: by Mary Hooks, which card is attached hereto and marked as Exhibit "A", along with the deposit slip dated March 17, 2004, for said article of Certified Mail aforementioned. Date: March 30, 2004 BATUR1N & BATUR1N By: Madelaine N. Baturin Attorney I.D. # 68971 717 North Second Street Harrisburg, PA 17102 (717) 234-2427 Attorney for Plaintiff ~ Postaoo $ .60 ru - ~ 2.30 ~,~aF~ $ 4.65 03/17/04 LO Raalplent's Name (Please Print Clearly) (TO be completed by meller) '= ...... .......................................................... Street, Apt. No.; or PO Box NO. ~ 328 N. College St r~' c/t~, state, ziP+ 4 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Iris M. Mosley ~ 328 N. Colle§~ St C~rlis!e, PA 17013 A. Receivedby0~eesePr/ntC/em~ B. Date of DelNe~ C. Signature ~ ~ [] Agent ~ D Addme~ee ~ [~ Is delivery address different from item 17 [] yes ~ If YES, enter delivery a~ldress ~3elo_w: [] No I 3. ~,rvice Typ~ ~ Cer~ifiad Mail [] Express Mail '~ [] Registered [] R~urn Receipt for Merchandise [] Insured Mail [] C,O.D. 4. Restricted Delivery? (Extra Fee) [] Yes 2. Article Number (Copy from service label) 7000 0520 0023 0126 4158 PS Form 3811, Ju~y 1999 Domestic Return Receipt Exhibit "A" BRYANT A. MANNING Plaintiff V. IRIS M. MOSLEY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1026 CIVIL ACTION LAW IN CUSTODY ANSWER TO COMPLAINT FOR CUSTODY .WITH NEW MATTER IN THE NATURE OF A REQUEST FOR RELOCATIO,'.' AND NOW, comes the Defendant, Iris M. Mosley, by and through her attorney, Michael A. Scherer, Esquire, and respectfully responds to the Plaintiff's complaint as follows: 1. Admitted. 2. Denied. Defendant resides at 1426 Nixonton Road, Elizabeth City, North Carolina 27909-7298. 3-11. Admitted. 12. Denied. a. Mother is best able to provide for the health, educational needs and general welfare of the child; b. Mother is best able to provide the child with a wholesome living environment; c. Mother has been the primary caretaker of the child since the child's birth. d. Mother has moved to North Carolina. Mother attempted to discuss her move with father many times; however, Father would not discus..; the matter. e. The minor child has a stepbrother in Carlisle, but no other family in Carlisle. The minor child rarely sees Father's family, which is located in the Harrisburg, Pennsylvania a rea. f. Mother has moved to North Carolina and is. willing to allow Father liberal access to the child. I g. Mother does not rely on medications for mental health issues. h. The child has expressed no anxiety regarding moving to North Carolina. i. The best interest of the child dictates that he be placed with Mother for purposes of primary physical custody and that Father be awarded periods of partial physical custody. WHEREFORE, Mother requests that she be awarded primary physical custody and that Father be awarded partial physical custody with the child. NEW MATTER IN THE NATURE OF A RECIUEST FOR RELOCATIC;.' 13. The parties have lived together since approximately 1994. 14. The parties never married. 15. Father has admitted to having a relationship with another woman during the time the parties lived together. 16. Father is often unavailable in the evenings, alleging that he is working, and his whereabouts are often unknown. 17. For approximately the last two years, Mother' has indicated to Father that she is unhappy with their relationship and has attempted over that period of time to discuss the termination of their relationship. 18. In January, 2004, Mother indicated to Father that she would be separating from him, resigning from her employment and taking the child to North Carolina to be with Mother's family. Mother, thereafter, proceeded to resign from her employment, withdraw the child from school and make arrangements for the child to attend school in North Carolina all with Father's knowledge. 19. Immediately prior to Mother leaving with the child, Father filed a Petition for Custody to prevent mother's move with the child and a Petition for Emergency Relief asking for partial custody and an order that the child not be removed from Pennsylvania. 20. Mother has no family from this area, and her relationship with the Father is over. 21. Mother has family in North Carolina, and she is able to live with her grandmother until she secures employment in North Carolina. 22. 23. Carolina. Mother has made arrangements for the chi:Id to attend school in North Carolina. The child has repeatedly told Mother that he wants to live with Mother in North WHEREFORE, Mother respectfully requests this Honorable Court permit her to relocate with the child in North Carolina and award Father partial physical custody at such times as the child could return to Pennsylvania. Respectfully submitted, Date: April f¢6" , 2004 Michael A. Scherer, Esquire O'BRIEN, BARIC & SCHERER 19 West South Street Carl'isle, PA 17013 (717) 249-6873 VERIFICATION I verify that the statements made in the foregoing Answer to Complaint for Custody and New Matter 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: April 2004 Iris M. Mosley BRYANT A. MANNING IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA IRIS M. MOSLEY Defendant 04-1026 CIVIL ACTION LAW IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on April /..~ , 2004, I, Tina M. Ascani, of O'Brien, Baric & Scherer, did serve a copy of the Answer to Complaint for Custody and New Matter, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Madelaine N. Baturin, Esquire 717 North Second Street Harrisburg, Pennsylvania 17102 Tina M. Ascani, Secretary T A. MANNING, Plaintiff Vo IRIS M. MOSLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1026 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY : : BAYLEY, J.-- I~NTERIM ORDER OF COUF. L.T ~ ~,~ 2004, upon consideration AND NOW, this ~ day of -' of the attached Custody Concilia~on Sure'nary Rff~ort, it is hereby ordered and directed as follows: tinue to reside with Fat~er pending a hearing or further 1. The child sha con . · · tod which shall agreement of the parties. Mother shall be entlt ed to per ods of partial cus y be arranged as follows: A. May 28, 2004 through May 31,2004. B. Following the dismissal from school until July 2, 2004. C. From July 24, 2004 through August 6, 2004. D. At such other times as the parties agree. 2. ~' The parties will share transportation by meeting in Woodbridge, Virginia for the custodial exchange. 3. ~. A hea~ng is scheduled in Courtroom Number 2 of the Cumberland County Courthouse, on the 23 day of July, 2004, at 1:3.0 P.M., at which time testimony will be taken. For the purposes of the hearing, the Father, Bryant A. Manning, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum NO. 04-1026 CIVIL TERM setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least ten days prior to the hearing date. Edgar B. Bayley J. Dist: Madelaine N, Batudn, Esquire, 717 North Second Street, Harrisburg, PA 17102 Michael A. Scherer, Esquire, 19 West South Street. Ca~tisle, PA 17013 BRYANT A. MANNING, Plaintiff IRIS M. MOSLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-1026 CIVIL TERM CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19'15.3-8, 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 Bryant A. Manning, Jr. DATE OF BIRTH August 6, 1997 CURRENTLY IN THE CUSTODY OF Father 2. A Custody Conciliation Conference was held on April 20, 2004 following Father's filing of a Complaint for Custody and Petition for Special Relief filed on Mamh 10, 2004. On March 23, 2004, a Temporary Order was issued by the Court prohibiting either parent from removing the child from the jurisdiction pending custody conciliation. On March 15, 2004, the Defendant filed an answer to the Complaint for Custody and raised a New Matter requesting relocation to North Carolina. Present for the conference were: the Father, Bryant A. Manning, and his counsel, Madelaine N. Baturin, Esquire; the Mother, Iris M. Mosley, and her counsel, Michael A. Scherer, Esquire. 3. The parties were not able to reach an agreement regarding primary custody of the child in light of Mother's March 20, 2004 relocation to Elizabeth City, North Carolina. The parties were able to reach an agreement for temporary periods of custody around the Memorial Day weekend and during a substantial portion of the summer school recess, pending a hearing before the Court. Both parties prefer to Ihave primary physical custody. 4. Mother's position on custody is as follows: Mother reports that she has no family in the Harrisburg area, but that she has numerous cousins and her maternal grandmother in Elizabeth City, North Carolina. She relocated to Elizabeth City on March 20, 2004 after having quit her job with Sprint after 13 years of employment there. She reports that she had planned a relocation and advised Father of her intended relocation in January of 2004. She is presently unemployed. She resides with her grandmother and 13 year old son, Frankie. Because of her extensive work experience i~n "customer service" she believes that she will promptly find new employment. NO. 04-1026 CIVIL TERM 5. Father's position on custody is as follows: Father seek primary physical custody alleging that Mother had quit her job and relocated to North Carolina after refusing to discuss the matter with him. According to Father, both p-qrents had cared for the child the five years that they lived together in Carlisle. Father presently works for Rite Aid Corporation from 8:00 a.m. to 5:00 p.m. Occasionally, he is on call and may have to go into work on short notice. Father reports that he has family in the area which he claims to see on a frequent basis. Father reports that the child participates in t-ball and ju jetsu. The child is presently in the Father's custody pursuant to a Temporary Emergency Order. 6. Counsel for the parties agreed that a full day hearing will be required and prefer that this matter be resolved during the summer months so that the parties will have time to make plans for the child to attend school with whichever parent he resides during the 2004/2005 academic year. Date Melissa Peel Greevy, Esquire Custody Conciliator :227738