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HomeMy WebLinkAbout08-3759MICHAEL GOOD and BARBARA GOOD Plaintiff V. JANEL GOOD and EDWIN PABON Defendant. COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Michael and Barbara Good, by and through their attorney, Mark F. Bayley, Esquire, and presents the within complaint for custody, representing as follows: 1. The Plaintiffs, Michael and Barbara Good, are married and reside at 1 Robert Lane, Carlisle, PA 17013. 2. The Defendant, Janel Good, is an adult individual residing at 309 West Ridge Street, Carlisle, PA 17013. 3. The Defendant, Edwin Pabon, is an adult individual incarcerated at SCI Coal : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08- 3 75 CIVIL TERM IN CUSTODY Township, 1 Kelley Drive, Coal Township, PA 17866. 4. Plaintiff seeks custody of the following child: Name Present Residence Age D/O/B Christian Pabon 309 West Ridge Street (hereafter "Child") Carlisle, PA 17013 5. The child was born out of wedlock. 5 years old 12-10-02 6. The relationship of the Plaintiffs to the child is that of maternal grandparents. Plaintiffs are married. J 7. The relationship of the Defendant, Janel Good, to the child is that of natural mother. She currently resides with Cameron Stever (Mother's boyfriend), Mecca Stever (Child's Half-Sister), Montaga Stever (Child's Half-Brother). Defendant, Janel Good, is not married. 8. The relationship of the Defendant, Edwin Pabon, to the child is that of natural father. He is currently incarcerated at SCI Coal Township. It is unknown to Plaintiffs whether or not Defendant, Edwin Pabon, is married. 9. During the past five years the child has resided with: Name Address Date Janel Good 309 West Ridge St., Carlisle, PA 8/2007-Present Michael and Barbara Good 1 Robert Lane, Carlisle, PA 5/2007-7/2007 Janel Good North 19th St., Harrisburg, PA 9/2006-4/2007 (spent every weekend with Michael and Barbara Good) Janel Good North 18th St., Harrisburg, PA 11/2005-8/2006 (spent every weekend with Michael and Barbara Good) Janel Good Booser Ave, Harrisburg, PA 5/2005-10/2005 (spent every weekend with Michael and Barbara Good) Michael and Barbara Good 1 Robert Lane, Carlisle, PA 1/2004-4/2005 Janel Good and North Pitt St., Carlisle, PA Birth-12/2003 Edwin Pabon (50% of nights were spent with Michael and Barbara Good) 10. Plaintiffs have not participated as parties or witnesses, or in another capacity in other litigation concerning the custody of the child in this or any other Court. 11. Plaintiffs have no information of a custody proceeding concerning the child pending in any Court of this Commonwealth or any other state. 12. Other than as noted above, Plaintiffs do not know of a person nor a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the children. 13. Plaintiffs have genuine care and concern for the child. 14. Plaintiffs' relationship with the child began with the consent of the child's natural mother. 15. Plaintiffs have assumed the role and responsibilities of the child's parent, providing for the physical, emotional and social needs of the child for a period in excess of twelve months, as well as during other shorter periods. 16. It is in the best interests of the child for Plaintiffs to have physical custody at times which may be agreed upon by the parties at a conciliation or otherwise be determined by the Court. WHEREFORE, Plaintiffs respectfully request this Honorable Court to schedule a custody conciliation conference. Date: 60 - Respectfully submitted, BEY GAN Mar k F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Plaintiffs MICHAEL GOOD and : IN THE COURT OF COMMON PLEAS OF BARBARA GOOD : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION - LAW JANEL GOOD and EDWIN PABON : NO. 08- CIVIL TERM Defendant. : IN CUSTODY VERIFICATION We verify that the statements made in the foregoing document are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Michael Good, Plaintiff -? 6 ?/ 2,, -, ?' Barbara Good, Plaintiff "bpi C5 -* MICHAEL GOOD AND BARBARA GOOD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JANEL GOOD AND EDWIN PABON DEFENDANT 2008-3759 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, July 01, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, August 01, 2008 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. y J48 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 f MICHAEL GOOD and BARBARA GOOD Plaintiff V. JANEL GOOD and EDWIN PABON Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 08-3759 CIVIL TERM IN CUSTODY PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT AND NOW, comes Defendant, Janel Good, by and through her attorneys, MidPenn Legal Services, and files these Preliminary Objections to Plaintiff's Complaint for Custody and in furtherance thereof states as follows: 1. Defendant, Edwin Pabon, hereinafter "Father," and Defendant, Janel Good, hereinafter "Mother," are the natural parents of one minor child, Christian Pabon, born December 10, 2002. 2. Plaintiffs Michael and Barbara Good are the maternal grandparents of Christian. 3. Plaintiffs have only sporadically and with mother's consent taken care of Christian. 4. Plaintiffs have never been authorized to make educational, medical or religious decisions about Christian's upbringing. 5. Plaintiffs have shown a propensity for interfering with Mother's custodial rights and decisions as Christian's mother. 6. Mother does not need or desire that Christian have any contact with Plaintiffs. 7. The question of Plaintiffs' standing should be resolved before any further proceedings in custody occur. 8. Plaintiffs have not assumed the role and responsibilities of the child's parent for a 12 month period. 9. Pursuant to 23 Pa.C.S. §5313, Plaintiffs do not have standing to petition for custody of Christian Pabon. WHEREFORE, Defendant Janel Good requests this Court to issue a Rule to Show Cause why this Complaint should not be dismissed for lack of standing and to suspend all proceedings in custody until the issue of standing is resolved. Respectfully Submitted, ra a D' Alo i enn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717:243-9400 MICHAEL GOOD and BARBARA GOOD Plaintiff V. JANEL GOOD and EDWIN PABON Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 08-3759 IN CUSTODY CIVIL TERM VERIFICATION The above-named DEFENDANT, Janel Good, verifies that the statements made in the attached PRELIMINARY OBJECTIONS are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: Q' Cl Good MICHAEL GOOD and BARBARA GOOD Plaintiff V. JANEL GOOD and EDWIN PABON Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 08-3759 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE I, Grace D'Alo, Esquire, of MidPenn Legal Services hereby certify that I have served a copy of the foregoing Preliminary Objections to Plaintiffs Complaint on counsel for the Plaintiffs on the following date and in the manner indicated below: U.S. First Class Mail Mark F. Bayley 17 West South Street Carlisle, PA 17013 Date: C t /0? -1'? ace D'Alo M enn Legal Services 1 East Louther Street Carlisle, PA 17013 (717:243-9400' 0 C3 ? C CZ cn ET ' r y+ G -?i C- co sp 2 6 2008 MICHAEL GOOD and BARBARA GOOD, Plaintiffs v JANEL GOOD and EDWIN PABON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-3759 IN CUSTODY ORDER V? AND NOW, this aG' day of September, 2008, the Conciliator attending the custody conciliation and none of the parties or attorneys being in attendance, the Conciliator relinquishes jurisdiction. . Gilroy, Esquire ustody Conciliator p ' "t? f t7 ? . C?7 ^C MICHAEL GOOD and BARBARA GOOD Plaintiff VS. JANEL GOOD and EDWIN PABON Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - 3759 CIVIL TERM IN CUSTODY ANSWER BY PLAINTIFFS TO PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT AND NOW, comes Michael Good and Barbara Good, by and through their attorney, Mark F. Bayley, and in response to Defendants' Preliminary Objections answer as follows: 1. Admitted. 2. Admitted. 3. Denied. 4. Denied. 5. Denied. 6. Denied. By way of further answer, Plaintiffs are hopeful that Mother will change her position with regard to their contact with Christian. 7. Admitted. 8. Denied. 9. Denied. It is denied that the Plaintiffs lack standing in accordance with 23 Pa. C.S. §5313. By way of further answer, it is averred that Plaintiffs additionally have standing under 23 Pa. C.S. § 5312. WHEREFORE, Plaintiffs request the Court to dismiss Defendant's Preliminary Objections. Date: (0-'N -0 A Respectfully submitted, BAYLEY & MANGAN I -?- - Mark F. Bayley, E uire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Plaintiffs MICHAEL GOOD and BARBARA GOOD Plaintiff VS. JANEL GOOD and EDWIN PABON Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - 3759 IN CUSTODY CIVIL TERM VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Plaintiffs in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: 1 al N'/C) L/ Mark F. Bayley, quire Attorney for Plaintiffs MICHAEL GOOD and : IN THE COURT OF COMMON PLEAS OF BARBARA GOOD : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. : CIVIL ACTION - LAW JANEL GOOD and EDWIN PABON : NO. 08 - 3759 CIVIL TERM Defendant. : IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Plaintiffs, do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Grace D'Alo, Esquire 401 East Louther Street, Suite 103 Carlisle, PA 17013 Mark F. Bayley, Esquire r Dated: f - -C c _o? Attorney for Plaintiffs _ l lJ `l €?? , ? = < ? i -;.? ._." __. t) T'g . r^? ^"?-_ ?„;' ?' 'l , CT&A MICHAEL GOOD and BARBARA GOOD Plaintiff vs. JANEL GOOD and EDWIN PABON Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 08 - 3759 CIVIL TERM IN CUSTODY ORDER AND NOW, this day of 2008 upon consideration of the Defendant, Janel Good's Preliminary Objections To Plaintiffs Complaint and Plaintiffs' Answer, it is hereby ordered and directed that: A hearing/argument solely on the Grandparents' standing shall be held on the _ day of , 200?in Courtroom No. S of the Cumberland County ak 001P ?-' Courthouse in Carlisle, Pennsylvania. The parties shall file memorandums of law on this issue on or before the day of 200f I}istribution to: Mark F. Bayley, Esquire -..-&ace D'Alo, Esquire l0?3o/d8 .rr C?i•;th;?? ta,.t,.,ww r I S =ZI wd oz 130 0001 MICHAEL GOOD AND IN THE COURT OF COMMON PLEAS OF BARBARA GOOD, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS V. JANEL GOOD AND EDWIN PABON, DEFENDANTS NO. 08-3759 CII ?IL ORDER OF COURT AND NOW, this 17th day of December, 2008, upon consideration of the oral request of the Counsel for Plaintiffs' that the argument currently scheduled for February 13, 2009, be rescheduled, and with thel concurrence of Defendants' counsel, IT IS HEREBY ORDERED AND DIRECTED that argument will be held on Tuesday, January 6, 2009, at 3:30 p.m. in Courtroorb No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Cou ? Mark Bayley, Esquire /Grace Attorney for Plaintiffs D'Alo, Esquire Attorney for Defendants 1* OL, M. L. Eber Jr., J. bas I ., ?^?4, -a';-?.1. at-? + ,?...? J.J'° „' MICHAEL GOOD and BARBARA GOOD, Plaintiffs V JANEL GOOD and EDWIN PABON, Defendants IN RE: ARGUMENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-3759 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this 6th day of January, 2009, upon consideration of the preliminary objections to the plaintiffs' complaint, and the plaintiffs' answer thereto, and after status conference with counsel, IT IS HEREBY ORDERED AND DIRECTED that either party or on before January 30, 2009, may submit case law, letter briefs or regular legal briefs on the issue of standing of the grandparents to file for custody and/or visitation under 23 Pa. C.S.A. Section 5312 and 13. By the Court, ZMark F. Bayley, Esquire For the Plaintiffs ? Grace D'Alo, Esquire MidPenn Legal Services For Defendant Janel Good :mtf 1 es /?Ylc`?i.! ISL 126P 1aIUrr tz/Y7 '%"t ?'4 - M. L. Ebert, Jr., J. 1 } (? ?'1 ?? ' ? .., ?.t?? =?? .., ?? MICHAEL GOOD AND IN THE COURT OF COMMON PLEAS OF BARBARA GOOD, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS V. JANEL GOOD AND EDWIN PABON, DEFENDANTS NO. 08-3759 CIVIL ORDER OF COURT AND NOW, this 4th day of February, 2009, upon consideration of Defendant Janel Good's Preliminary Objections to Plaintiffs' Complaint, the Plaintiffs' Answer thereto, and consideration of the legal memorandums provided by the parties, IT IS HEREBY ORDERED AND DIRECTED that Janel Good's Preliminary Objections are DISMISSED. IT IS FURTHER ORDERED AND DIRECTED that Plaintiffs do have standing to proceed with their complaint for custody. Mark Bayley, Esquire Attorney for Plaintiffs Grace D'Alo, Esquire Attorney for Defendants bas 06P6es maiL( By the Court, M. L. Ebert, Jr., J. viNYMMMIld S S :1 ! Wn S- 93.E AbK M-WHIOW 3Hl..40 30 LJ40-G31U C? MAR 2 0 2% MICHAEL GOOD and IN THE COURT OF COMMON PLEAS OF BARBARA GOOD, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. : CIVIL ACTION - LAW JANEL GOOD and EDWIN PABON, NO, 2008-3759 Defendant IN CUSTODY PRIOR JUDGE: M.L. Ebert, Jr. COURT ORDER AND NOW, this day of March, 2009, upon consideration ofthe attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in the above referenced case for Thursday, May 28, 2009, at 1:30 p.m. in Court Room No. 5 of the Cumberland County Courthouse. At this hearing, the Plaintiffs, maternal grandparents, shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, the following TEMPORARY Custody Order is entered: A. The mother, Janel Good, shall enjoy legal and physical custody of Christian Pabon, born December 10, 2002. B. Pending further Order of this court to be entered after the hearing referenced above, the maternal grandparents, Michael Good and Barbara Good, shall enjoy visitation with the minor child as follows: i. On March 28 and April 4 from 2:00 p.m. until 6:00 p.m.; on April 18 and April 25, from 2:00 p.m. until 6:00 p.m.; and on May 9 and May 16 from noon until 6:00p.m. C. The maternal grandparents shall handle transportation for exchange of custody and shall pick up the minor child at the mother's home at the scheduled time of pick up and shall deliver the minor child back to the mother's home at the scheduled time for the end of their visitation. 3. In the event the father, Edwin Pabon wants to participate in the hearing in this matter from SCI Coal Township, Mr. Pabon should make arrangements with the appropriate officials at the prison to allow telephone access for him and he should notify the Cumberland County Court Administrator along with legal counsel in this case to participate. Upon receiving such notification, the Cumberland County Court Administrator shall make arrangements for telephone access for Mr. Pabon in Courtroom Number 5 at the time of the hearing scheduled above. BY THE COURT, sv-?- \ Judge M. L. Ebert, Jr. cc: F. Bayley, Esquire ace E. D'Alo, Esquire r. Edwin Pabon ,o o? ';;t ? GeV s ??.`???? ?.±`???i? r.. 1? 1'A? J? ?© t It ... MICHAEL GOOD and IN THE COURT OF COMMON PLEAS OF BARBARA GOOD, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION - LAW JANEL GOOD and EDWIN PABON, NO. 2008-3759 Defendant IN CUSTODY PRIOR JUDGE: The Honorable M.L. Ebert, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE 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: Christian Pabon, born December 10, 2002. 2. The Conciliator conducted a Conciliation Conference with legal counsel and the parties, spoke directly with Judge Ebert, and then had a telephone conference with the attorneys for the parties. 3. This is a difficult case involving the maternal grandparents opposing their daughter in an effort to obtain some visitation with their granddaughter. The child's father is incarcerated. 4. Procedurally, the mother filed preliminary objections to the complaint for custody filed by the maternal grandparents. Those preliminary objections were dismissed by Order of Court of February 4, 2009. A, •n 5. Admittedly, the maternal grandparents have not seen the minor child for well over a year. However, prior to that time, the mother lived with the maternal grandparents on and off with the daughter, and the minor child had a good deal of contact with the maternal grandparents. The mother is currently adamant that she does not want the maternal grandparents having any contact whatsoever with the minor child. Based on the lack of an agreement, a hearing is necessary and there is a hearing scheduled on May 28. 6. At issue is whether the maternal grandparents should have some type of visitation prior to the mentioned hearing. Again, the mother is not willing to agree to any visitation. However, based upon the information the Conciliation has obtained from the conference and from discussions with the attorneys, the Conciliator does not see any real danger to the minor child if the maternal grandparents have some limited visitation prior to the hearing. In fact, the Conciliator believes that such limited visitation will ultimately aid the court at the hearing in determining whether the maternal grandparents should have visitation and, if so, how much visitation. Accordingly, the Conciliator recommends an Order in the form as attached. Date: 6-'a D , 2009 i MICHAEL GOOD AND IN THE COURT OF COMMON PLEAS OF BARBARA GOOD, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS V. JANEL GOOD AND EDWIN PABON, DEFENDANTS NO. 08-3759 CIVIL ORDER OF COURT AND NOW, this 28th day of May, 2009, the parties having appeared this date for a custody hearing and having reached an agreement as indicated by their signatures below, IT IS HEREBY ORDERED AND DIRECTED that mother shall have sole legal custody and primary physical custody subject to grandparents' visitation as follows: 1. Every other Saturday from 8:00 a.m. until 8:00 p.m. commencing this Saturday, May 30, 2009. 2. During the summer school recess, beginning in 2010 for an uninterrupted 4 day period. This 4 day period will be granted upon 3 months notice to the mother. 3. Grandparents will be responsible for all transportation. 4. Grandparents will be permitted to attend any sporting event, school function, etc. relating to the child that are open to the public. 5. Counsel for mother will provide supplemental provisions regarding grandparents conduct during visits by Tuesday, June 2, 2009. 14 9 6. Parties may modify this order by agreement but without such agreement this ord hall c rol. Ja I Good, Mothik Michael and Barbara Good, Grandparents C?SZZR Dat Date By the Court, "` 1 M. L. Ebert, Jr., J. Mark Bayley, Esquire Attorney for Plaintiffs Jessica Hoist, Esquire Attorney for Defendant bas MICHAEL GOOD AND BARBARA GOOD, PLAINTIFFS V. JANEL GOOD AND EDWIN PABON, DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3759 CIVIL ORDER OF COURT AND NOW, this P day of June, 2009, IT IS HEREBY ORDERED AND DIRECTED the following supplemental provisions are to be considered part of the Order of Court dated May 28, 2009, 1. While the child is with the Grandparents, they will not give him pork or pork products. 2. When Grandparents buy items for the child, those items will stay at their residence rather than be brought back to Mother's residence. 3. Grandparents will ensure that the child is not exposed to cigarette smoke. This includes in their residence, the residence of any family members or friends they may visit while with the child, or in a vehicle when the child is being transported. 4. Grandparents will give Mother pertinent information about where they will be taking the child during their periods of visitation. 5. Grandparents will not discuss the child's biological father either with the child or with others when the child is in Grandparents' care. • t . . 6. Grandparents will not denigrate or undermine Mother's role as the child's parent. This includes any suggestions that the child keep secrets from Mother about his activities with Grandparents, derogatory remarks about Mother's rules or any expression of disagreement with Mother's parenting decisions. 7. Grandparents will refrain from making derogatory remarks about Mother's boyfriend either to the child or to others while the child is in Grandparents' care. ?Mark Bayley, Esquire Attorney for Plaintiffs essica Hoist, Esquire Attorney for Defendant bas By the Court, V?W -?, U'A M. L. Ebert, Jr., J. s r? _?'v