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Home My WebLink About04-1300THERESA E. COOK, Plaintiff BRANDON H. GREENE, Defendant IN THE COURT OF COMMON PLEAS CUMBE~O~,PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY AND COMES NOW, THERESA E. COOK, by and through her attorney, Bradley A. W'nmick, Esquire, of Wiley, Lenox, Colgan & Marzzaceo, P.C., and files thc instant Complaint for Custody, and in support thereof, avers as follows: 1. The Plaintiffis Theresa E. Cook, who currently resides at 6 Green Circle, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Brandon H. Greene, who is believed to be residing at 3207 Vickers Road, Baltimore, Maryland 21216. 3. The above parties are the natural parents of one minor child: Mikayla H. Greene, date of birth, June 3, 1998. The child was born out of wedlock. 4. The child is currently in the care and custody of Plaintiff. 5. During the past five years, the child has resided with the following persons and at the following addresses: A. 6 Green Circle, Camp Hill, Cumberland County, Pennsylvania, with Plaintiffand her boyfriend, Darren Burton, fi.om March 2002 until the present. B. 2423 North 3rd Street, Harrisburg, Dauphin County, Pennsylvania, with Plaintiff and her boyfriend, Darren Burton, fi.om January 2002 until March 2002. C. 3930 Federal Hill Road, Jarrettsville, Maryland, with Plaintiff, Plaintiffs parents, Christine and Russell Cook, and PlaintifFs brother, Nathan Cook, from March 1999 until January 2002. 6. The mother of the child is Theresa E. Cook, currently residing at 6 Green Circle, Camp Hill, Cumberland County, Pennsylvania. 7. The father of the child is Brandon H. Greene, believed to be residing at 3207 Vickers Road, Baltimore, Maryland. 8. The relationship of Plaintiff to the child is that of mother. Plaintiff currently resides with her daughter, Mikayla H. Greene, and her boyfriend, Darren Burton. 9. The relationship of Defendant to the child is that of father. Defendant currently resides with person or persons unknown. 10. Plalntiffhas no information of a custody proceeding concerning the chad pending in a court of this Commonwealth. 11. Plalntiffhas participated as a party in other litigation concerning the custody of the chad in another court. On January 23, 2002, Defendant filed a Petition for Custody in the Circuit Court of Maryland for Harford County, Maryland, docketed to No. 12~P-99-130. On May 9, 2002, the parties signed a Parenting Plan in which it was agreed that Plaintiff would have primly physical custody and Defendant would have partial physical custody on alternating weekends from Friday at 10:00 a.m. until Sunday at 6:00 p.m. This Parenting Plan specifically stated that the agreement contained therein was neither binding nor enforceable until submitted for Court approval and entered as an Order of Court. Upon reasonable investigation, it appears that the Parenting Plan was never entered as an Order of Court. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the chad or who claims to have custody or visitation fights with respect to the chad. 13. The hest interest and permanent welfare ofthe child will he served by granting Plaintiff p~'m~y physical custody of the child and limiting Defendant's periods of partial physical custody so the child does not spend overnights with him. Plaintiff submits the following in support of this request for relief: a) Plaintiffhas concerns regarding Defendant's unknown living environment. b) Plaintiff has learned that on January 17, 2003, the Circuit Court for Baltimore County, Maryland granted Defendant's estranged wife an Order for Protection from Domestic Violence. c) The child is expressing extreme fear when presented with the prospect of having to spend time with her father. This circumstance, in conjunction with the recent question of domestic violence, gives Plaintiff extreme concern for her daughter's safety. 14. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff respectfully requests This Honorable Court to award her primary physical custody of the minor child with partial physical custody to Defendant. Respectfully submitted, WILEY, LENOX, COLGAN & MARZZACCO By: 'a~l .~~k ~3r , Esquire ID # 78413 130 W. Church Street Dilisburg, PA 17019 (717) 432-9666 Dated: /iS/o q VERIFICATION I verify that the statemems made in this 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 unswom falsification to authorities. THERESA E. COOK THERESA E. COOK PLAINTIFF V. BRANDON H. GREENE DEFENDANT iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1300 CIVIL AC'IION LAW : : IN CUSTODY ORDER OF COURT AND NOW, Thursday, April 01, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear befbre Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 22, 2004 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. All children age five or older may also be present at the conference. Failure to appem' 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/ ]acqueline M. Verney, Esq. Custody Conciliator mhc The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infbrmation about accessible facilities and reasonable accommodations available to disabled individuals having business beibre 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 hear/ng. YOU SItOULD TAKE THIS PAPER TO YOUR NITORNEY 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 THERESA E. COOK, Plaintiff VS. BRANDON II. GREENE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04-1300 Civil Action Law IN CUSTODY CERTIFICATE OF SERVICE I, Bradley A. Winnick, Esquire, hereby certify that I am this day serving a copy of the Order of Court scheduling a Conciliation Conference for April 22, 2004, at 10:30 a.m., at the 4th floor of the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania, upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States mail, first-class postage prepaid, as follows: Date: Brandon Greene 3207 Vickers Road Baltimore,/vid 21216 WILEY, LENOX, COLGAN & MARZZACCO, P.C. By: Brac~ck, Esquire Supre[~ Court I.D. #78413 1 South Baltimore Street Dillsburg, PA 17019 (7171432-9666 (Attorney for Plaintiffs) THERESA E. COOK, BRANDON H. GREEN, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. O~" I~OO CML ACTION -- IN CUSTODY AggmAvrr Og SERVICE COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF YORK : I HEREBY CERTIFY that before me, the undersigned authority, a Notary Public in and for the Commonwealth of Pennsylvania, County of York, aforesaid, personally appeared Edgar J. Siptroth, Jr., who made oath in duc form of law that on the 19th day of March, 2004, at L2.',c~o I~bS/o'clock ~ .M., he personally served a true and correct copy of the Complaint for Custody and Order of Court filed herein upon the Defendant, Brandon H. Greene, at Mulberry Day Care Center, 3710 Trindle Road, Camp Hill, Pennsylvania. Sworn to and subscribed before me on / day o(fT J-- , 2004. Notarial Seal S. Dawn Gladfelter, Notary Public Dillsbur~l Bore, York County My Commission Expires May 17, 2005 Member, Pennsylvania Asscc~at~on of Notaries City oe Counly Plaintiff Defendant ANSWER TO O COMPLAINT 13 PETITION MOTION ~p~ntin~ mTselr, a~wcrin~ the fil~ against me, state: I. Anaw~fing P~ph No. I (eh~k one): ~it all oftha s~temant(s) in P~ph No. I. ~ I deny all of the s~t~ments(a) in P~gmph No. l., ~xg~pt { admit that ~ [ do not have enough info~tion m ~ow whether or not the s~ement(s) in Pa~g~h 1 ~ ~e. 2. ~wefing P~ph No. 2 (check one): ~it all ofthg mtem~(s) in Pm~ph No. 2. ~ [ deny all of&e smt~ent(s) M P~ph No. 2, except I ~it ~ I do not ~ve enough Mfo~tion to ~ow wh~er or not ~e s~temm~s) ~ T~ ~ no P~ph No. 2. 3. ~fing P~gmph No. 3 (ch~k one): ~[ ~it all of~e s~temen~s) in Pm~ph No. 3. ~ I deny all of&e s~tement(s) M P~ph No. 3, except I a~it ~at ~ I do not ~ve enou~ i~omfion m ~o~ whe~ m' not ~esUtem~t(s) in Pm~h 3 ~ ~e. ~ ~e~ b no P~ph No. 3. 4. ~s~g P~h No. 4 (ch~k one)~ ~ I ~it all of &e student(s) M P~h No. 4. . ~dmy all of ~e students) in Pm~ph No 4, except I ~t ~ d ' ' ~ '~ ~ ' ' - [ 0 not ~ve anou~ ~omao~ ~ow wheat o~:not ~ smem~nt(s) M pm~h g~e ~. ~ I do not ~ve enough ~o~adon to ~ow W~er or not ~e s~tem~t(s) iff P~h 5 ~ ~. ~ ~e~ is no P~h No. 5. Pago I 0~3 6. Answering Paragraph No. 6 (check one): ~dmit all of the statement(s) in Paragraph No. 6. O ! deny all oftha statement(s) in Paragraph No. 6, except ! admit that . Stit~ tl~ fic~- that you admit m' [~ [ do not have enough information to know whether or not the statement(s) in Paragraph 6 are true. I"'l There is no Paragraph No. 6. 7. Answ_ering Paragraph No. 7 (check one): ~'~ndmit all of the statement(s) in Parat.,raph No. 7. [~ ! deny all ofthe statement(s) in Paragraph No. 7, except [ admit that [~ [ do not have enough information to know whether or not the statement(s) in Paragraph 7 are true. (~ There is no Paragraph No. 7. 8. Answering Paragraph No. 8 (check one): ~ admit all of the statement(s) in Paragraph No. 8. [~ ! deny all of the statement(s) in Paragraph No. 8, e:ccept I admit that ~ I do not have enough infom,.ation to know whether or not the statement(s) in Paragraph 8 are true. ~ There is no Paragraph No. 8. 9. A_.m..~'ering Paragraph No. 9 (,~heck one): t~[ admit all of the statement(s) in Paragraph No. 9. [~ I deny all of the statement(s) in Paragraph No. 9, except I admit that . {~ I do not have enough information to know whether or not the statement(s) in Paragraph 9 are true. i-I There is no Paragraph No. 9. 10. In my .de.fense,.I also ,w~.t ~e Court to cons!der the following facts (A copy of any court order relating tomyoe~enselsattacnee, ifavallable): t//~---~, ,gL_,,_~-~-- /. f / FOR THESE REASONS, I request the Court (check all that apply): ~ismiss/deny the Complaint/Petition/Motion. {~ Grant the relief requested in the Complaint/Petition/Motion. [~ Grant the relief requested in the Complaint/Petition/Motion except., //I ~ Page 2d3 0R S0. Re~4sed 9 Aix~. 2001 Answer - Col)fimmtion Fonl2 10. Answering Paragraph No. 10 (check one): [ ] I admit all of the statement(s) in Paragraph No. 10. [ ] I deny all of the statement(s) in Paragraph No. I 0, except I admit that (stm thc fa~ that you admit or write "none") not have enough information to know whether or not the statement(s) in Paragraph No. 10 are true. [ ] There is no Paragraph No. 10. 11. Answering Paragraph No.11 (check one): [ ] I admit all of the statement(s) in Paragraph No. 11. [~'t I deny all of the, statement(s) in Paragraph No. 11, except I admit that ~ ~' (Stete~m~ts that yon admit or write "none') .... [ ] I do not have enough information to know whether or not the statement(s) in Paragraph No. 11 are true. [ ] There is no Paragraph No. 11. 12. Answering Paragraph No. 12 (check one): [ ] I admit all of the statement(s) in Paragraph No. 12. [ ] I deny all of the statement(s) in Paragraph No. 12, except I admit that [,d~do not (Statethe facts that you admit or write .none,) have enough information to know whether or not the statement(s) in Paragraph No. 12 are true. [ ] There is no Paragraph No. 12. 13. Answering Paragraph No. 13 (check one): [ ] I admit all of the statement(s) in Paragraph No. 13. [w]'l'deny all of the s~tement(s) in Paragraph No. 13, except /(State the facts that you admit or write 'none") [ ] I do not have enough inforrllafi~n to know ~hether or not the ~ta~tement(s) in Paragraph 14. Answenng Paragraph No. 14 (check one): ,4,, ~o ...... _,,~',,~'7'~w'o ~2, 7~ae~/~eg;e,,/~ [ ] I admit all of the statement(s) in Paraora~h~l~ ~en~all of ~e statement(s)in P~a~&3~ N?.I 4, [ ] I do not have enou~ iffomation to ~ow whe~er or not the statement(s) in P~agraph No. 14 ~e ~e. [ ] ~ere is no P~a~aph No. 14. CERTIFICATE OF SERVICE I HEREBY CERTIFY that off tiffs ~ d:ty of.~... , t)~ , a copy of'thc tbrugoimt Answer no ~ummons, you musl ~lc your Answer wilhin 15 ~ys a~cr Ib~ing ~¢d, o mn but IhlPORTANT (ADDITIONAk PAPE~ YOU ~IUST ~lL,E): Iflho Op~sinR P~y is ~kin8 child alimony, or ~th, you m~ complc~ ~d atach ~ your A~war ~e appmpda~ financial (child sup~ - us= Fo~ ~M gEL 30 or DOhl RffL 31: alimony - ~= Fo~ DO~I REL 3 I). I~ you want ibc Cou~ to g~ mlic~m you, you must compl=;; page 3 o~this ~o~ and ill= tho appmpd~= additional fo~(s). Page3~3 THERESA E. COOK * PLAINTIFF * VS. * BRANDON GREENE DEFENDANTS * IN THE CIRCUIT COURT FOR HARFORD COUNTY PATERNITY ACTION NO. 99-0130 ORDER The parties to the above entitled action having reached a parenting agreement, it is therefore, ORDERED, this 18va DAY OF MARCH, 2004, tha the parenting agreement entered into by the parties dated MAY 9, 2002 is incorporated in this Order, the same as set forth in full herein, and said agreement shall be binding upon the parties, and shall be enforceable by the Court; and IT IS FURTHER ORDERED, that all of the foregoing shall be subject to the further order of this court. John Getz, Esquire 510 Pulaski Highway Joppa, Md. 21085 Jerome Johnson, Esquire 108 N. Bond Street Bel Air, Md. 21014 JUDGE ~/~ ~ c c rr coeax Te~st; J~nes Re.~Llly, Clerk C C OFFICE OF FAMILY COURT SERVICES The Circuit Court For Harford CountIF Barbara Magness, LCSW-C 101SOUTHM~MNSTREET SUIT~300 BELAm, MARYLAND 21014 410-638-3100 F' AX 410-893-3953 Theresa Ellen Cook 6 Green Circle Camp Hill, Pennsylvania 17011 Brandon Hayes Greene 14 Handworth Way Baltimore, MD 21236 Case #99-130 PARENTING PLAN We, Theresa Ellen Cook and Brandon Hayes Greene have reached an agreement on a parenting plan for our child, Mi~ayla Hayes Greene (d.o.b. 06/03/98). We have developed this parenting plan with the assistance of the Office Of Family Court Services, in good faith and on behalf of the best interest of our child. We acknowledge that this is a draft of our agreement, which is not binding upon us or enforceable by either of us until it is submitted to the Court for approval and entered as an Order and signed and dated by a Judge. ED Typed 04/02/02 DECISION MAKING We agree to share joint legal custody so that we are making major decisions for our child together. We agree to delineate those decisions as follows: Legal Decisions - We agree to share responsibility for all legal decisions. Day-to-Day Decisions - We agree that parenting decisions will rest with the parent with whom Mikayla is residing, including vacation and holiday parenting. Examples of parental day-to-dray decisions include treatment of minor injuries, diet, TV, house rule~ and discipline, bedtime, etc. Education/Daycare Decisions - We agree that we. will make all future educational decisions together. We agree to share all educational information affecting Mikayla. We agree that both may receive duplicate copies of all school records, progress reports, and report cards and we will both be entitled to attend aH parent/teacher conferences and meetings. Further, we will both be listed on the emergency contact list at school and both of us will be entitled to pick Mikayla up from school Medical Decisions - We agree that in the event that emergency medical treatment is required, the parent who is caring for Mikayla will make the necessary decisions and then contact the other parent as soon as possible. We agree that we will both have access to medical records and may speak directly to the pediatrician, as well as any mental health professionals, treating Mikayla. COMMUNICATION Family Communications - We agree that Mikayla will have open telephone contact with both parents. We agree that neither parent shall do anything to estrange Mikayla from the other parent but rather to encourage a natural and continuing relationship between parent and child. We agree not to use Mikayla to relay messages between us and not to air our parental disputes in front of her. We agree to provide one another with residential and office phone numbers and to notify one another immediately if these numbers are changed. LIVING ARRANGEMENT We agree that Mikayla's primary residence will be with mother and that she will visit with father every other weekend from Friday at 10:00 a.m. until Sunday at 6:00 p.m. VACATION We agree that each parent may have two vacation weeks per year. We agree to give each other advance notice of time and place. HOLIDAYS ~- We agree to split this holiday ewery year. Christmas - We agree that in even numbered years, Mikayla will be with father on Christmas Eve and Christmas Day until 12:00 noon, and with mother after 12:00 noon on Christmas Day. In odd numbered years, the schedule will be reversed. ew Ye~g.~..g~.~ _ We agree to split this holiday. Easter - We agree that in odd numbered years, Mikayla will be with father and in even numbered years, she will be with mother. Mother's Day/Father's Day - We agree that Mikayla will spend Mother's Day with mother and Father's day with father every year. July 4th - We agree to split this holiday. Mika la's Birthda -We agree to celebrate Mikayla's birthday on the days we have her that fall closest to her birthday. ...MAJOR DISPUTE/CHANGE IN CIRCUMSTANCE~ In the event of.a major .dispute or changes in circumstances regarding the terms of this parenting plan, we agree to return to the Office of Family Court Services in an attempt to resolve our dispute before bringing action before the court We understand that by mutual consent we can change this agreement at any time. Theresa Ellen Cook (Mother) Date Brandon Ha~'~¢cn~ (Father) / l~ate Theresa, For your information and records, I have moved from Nottingham, MD to Baltimore, MD. I am renting a home at: 3207 Vickers Road Baltimore, MD 21216. A hard line has not been installed in my name yet, but my cell phone number remains the same. On Sunday's the girls will be dropped offat the Shoppers Food Market at 8212 Liberty Road, Randallstown at 5pm. Please inform me of any changes that may have been made for my Friday pick-up from the school, otherwise I will assume the same murine. I now have room for the girls to play and maneuver around and they have their own personal space as well as stability with Dad during our special time together. Thank you for your cooperation and you are doing a wonderful job witht our daughter. Brandon / (443) 996..9600 APR 2 3 7004 THERESA E. COOK, Plaintiff V. BRANDON H. GREENE, Defendant IN THE COURT O]? COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-1300 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT ANDNOW, this ~t~ dayof ~ ,2004, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Theresa E. Cook, and the Father, Brandon H. Greene, shall have shared legal custody of Mikayla H. Greene, born June 3, 1998. 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. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial physical custody as follows: A. Beginning April 30, 2004, alternating weekends from Friday at 12:00 noon to Sunday at 6:00 p.m. Father shall pick up the child from daycare on Fridays. B. Such other times as the parties agree. 4. Holidays. The parties shall have physical custody of the Child as indicated below: A. Mother's Day/Father's Day- Mother shall have physical custody of the Child on Mother's Day from 9:00 a.m. to 6:00 p.m. Father shall have physical custody of the Child on Father's Day from 9:00 a.m. to 6:00 p.m. B. Memorial Day/Fourth of July-alternate with Father having Memorial Day in 2004. 5. Transportation shall be shared such that the receiving party shall transport the Child. 6. Each party shall have the opportunity to walk through the other party's home. 7. Both parties shall cooperate with the Child's counseling. the Child. Both parties shall be entitled to reasonable, ]liberal telephone contact with 9. Neither party shall do or say anything or permit a third party to do or say anything which may estrange the Child from the other parem, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Each party shall encourage a meaningful relationship with the other party. 10. This Order is entered pursuant 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. Another Conciliation Conference is scheduled for July 23, 2004 at 1:30 p.m. on the fourth floor of the Cumberland County Courthouse. cc: Bradley A. Winnick, Esquire, Counsel for Mother Brandon H. Greene, pro se 3207 Vickers Road Baltimore, MD 21216-1941 THERESA E. COOK, Plaintiff V. BRANDON H. GREENE, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2004-1300 CIVIL TERM : : CIVIL ACTION - iLAW : : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Ctfild who is the subject of this litigation is as follows: NAME Mikayla H. Greene DATE OF BIRTH CURKENTLY IN CUSTODY OF June 3, 1998 Mother 2. A Conciliation Conference was held in this matter on April 22, 2004, with the following individuals in attendance: The Mother, Theresa E. Cook, with her counsel, Bradley A. Winnick, Esquire and Father, Brandon H. Greene, pro se. 3. The parties agreed to an Order in the form as attached. Date /~cqt(e~ine M. Vemey, Esquire Custody Conci][iator JUL 2 6 2004 THERESA E. COOK, Plaintiff V. BRANDON H. GREENE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2004-1300 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this ~.,'X day of '~ t~(/ ~, ,2004, upon consideration of the attached Custody Conciliation Rep~, it i~ ordered and directed as follows: 1. The prior Order of Court dated April 27, 2004 is hereby vacated. 2. The Mother, Theresa E. Cook, and the Father, Brandon H. Greene, shall have shared legal custody of Mikayla H. Greene, born June 3, 1998. 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-bei[ng including, but not limited to, all decisions regarding her health, education and religion. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial physical[ custody as follows: A. Alternating weekends, from Friday at 12:00 noon to Sunday at 6:00 p.m. during the summer. Once school is in session, pick up time on Fridays shall be at 4:00 p.m. Pick up e.n Fridays shall be at the day care center. Father, however, shall accommodate the Child's extracurricular activity schedule and assure that the Child will participate in the activity if it falls on his weekend. B. Such other times as the parties agree. Holidays: A. Mother's Day/Father's Day- Mother shall have physical custody of the Child on Mother's Day from 9:00 a.m. to 6:00 p.m. Father shall have physical custody of the Child on Father's Day from 9:00 a.m. to 6:00 p.m. B. The parties shall alternate the following holidays: Labor Day, Thanksgiving, Easter, Memorial Day m~d July 4th. Father shall have Labor Day in 2004. C. The Christmas holiday shall be divided into two blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. 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. D. Each party shall be entitled to two non-consecutive weeks in the summer provided they give the other party 30 days prior written notice of the exercise of said time, except said 30-day notice is not required for the summer of 2004. the Child. Transportation shall be shared such that the receiving party shall transport 6. Both parties shall cooperate with the Child's counseling. the Child. Both parties shall be entitled to reasonable, liberal telephone contact with 8. Neither party shall do or say anything or permit a third party to do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Each party shall encourage a meaningful relationship with the other party. 9. This Order is entered pursuant 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 ofthiis Order shall control. cc~radley A. Winnick, Esquire, Counsel for Mother ~randon H. Greene, pro se 3207 Vickers Road ,,~ ~~ Baltimore, MD 21216-1941 THERESA E. COOK, Plaintiff V. BRANDON H. GREENE, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .. : 2004-1300 CIVIL TERM : : CIVIL ACTION- LAW : : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information conceming the Child who is the subject of this litigation is as follows: NAME Mikayla H. Greene DATE OF BIRTH June 3, 1998 CURRENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on July 23, 2004, with the following individuals in attendance: The Mother, Theresa E. Cook, with her counsel, Bradley A. Winnick, Esquire. Father did not appear, although he received notice of the conference. 3. A prior Order of Court was entered by the Honorable Edgar B. Bayley, dated April 27, 2004 providing for shared legal custody, Mother having primary physical custody with Father having alternating weekends and alternating holidays. 4. Mother requested an Order in the form as attached. Date · Vemey, Esquire Custody Conciliator