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HomeMy WebLinkAbout08-5241FRIEDMAN & KING, P.C. Richard S. Friedman, Esquire ID #07176 3820 Market Street Camp Hill, PA 17011 Tel.: (717) 236-8000/Fax: (717) 236-8080 E-mail: friedmanandking_@hotmail.com CASSANDRA K. BARILLA, Plaintiff V. EDWARD M. BARILLA, III, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 0 K 5-aL Ctln " { Yr. CIVIL ACTION - LAW CUSTODY/VISITATION COMPLAINT FOR CUSTODY 1. The Plaintiff is Cassandra K. Barilla, residing at 127 E. Simpson Street, Mechanicsburg, PA 17055. 2. The Defendant is Edward M. Barilla, III, residing at 611 Mallard Road, Camp Hill, PA 17011. 3. Plaintiff seeks custody of the following child: NAME PRESENT RESIDENCE AGE DOB Dakota L. Barilla 127 E. Simpson Street 5 years 09/07/2002 Mechanicsburg, PA 17055 The child was not born out of wedlock. The child is presently in the custody of Plaintiff/Mother, who resides at 127 E. Simpson Street, Mechanicsburg, PA 17055. During the past five (5) years, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATE Cassandra K. Barilla 127 E. Simpson Street 08/29/2008 to present Bonnie Pearl (maternal grandmother) Mechancisburg, PA 17055 Cassandra K. Barilla 611 Mallard Road 02/2007 to 08/29/2008 Edward M. Barilla, III Camp Hill, PA 17011 Cassandra K. Barilla 127 E. Simpson Street 03/2006 to 02/2007 Edward M. Barilla, III Mechancisburg, PA 17055 Bonnie Pearl (maternal grandmother) Cassandra K. Barilla 330 W. Allen Street 08/2004 to 03/2006 Edward M. Barilla, III Mechanicsburg, PA 17055 Tammy Berger (paternal grandmother) Sam Gipe and Patricia Gipe (paternal great-grandparents) Cassandra K. Barilla 130 Summer Lane 08/2003 to 08/2004 Edward M. Barilla, III Enola, PA The mother of the child is Cassandra K. Barilla, currently residing at 127 E. Simpson Street, Mechanicsburg, PA 17055. She is married. The father of the child is Edward M. Barilla, III, currently residing at 611 Mallard Road, Camp Hill, PA 17011. He is married. 4. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: NAME Bonnie Pearl Dakota L. Barilla RELATIONSHIP Mother Daughter 5. The relationship of the Defendant to the child is that of Father. The Defendant currently resides by himself. 6. Plaintiff has not participated as a parry or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child 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 child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because Mother has been the primary caregiver of child since birth. 8. Each parent whose parental rights to the child have not been terminated, and the person who has physical custody of the child, have been named a party to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the child. Respectfully submitted, Date: 2Z2 Lo S FRIEDMAN & KING, P.C. Richard S. Friedman, Esquire 3820 Market Street Camp Hill, PA 17011 (717) 236-8000 Attorney for Plaintiff VERIFICATION I, Cassandra K. Barilla, hereby acknowledge that I am the ?Plaintiff in the foregoing action; that I have read the foregoing Custody Complaint; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Dated: ? ? Z2J 0 0?0'? 1?- bal )Ca. Cassandra K. Barilla 44- LA U) Of? Friedman & King, P.C. Richard S. Friedman, Esq. ID#07176 3820 Market Street Camp Hill, PA 17011 (717) 236-8000 (717) 236-8080 FAX friedmanandking_na,hotmail.com CASSANDRA K. BARILLA, Plaintiff V. EDWARD M. BARILLA, III , Defendant Attorney for Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CUSTODY/VISITATION EMERGENCY PETITION FOR SPECIAL RELIEF PENDING RESOLUTION OF A CUSTODY COMPLAINT AND NOW comes the Petitioner, Cassandra K. Barilla, pursuant to Pa.R.C.P. 1915.13, and petitions this Honorable Court as follows: 1. The Petitioner is Cassandra K. Barilla, who currently resides at 127 E. Simpson Street, Mechanicsburg, PA 17055. 2. The Respondent is Edward M. Barilla, III, who currently resides at 611 Mallard Road, Camp Hill, PA 17011. 3. The Petitioner is the natural mother of the minor child, Dakota L. Barilla, date of birth September 7, 2002. 4. The Respondent is the natural father of the minor child. 5. On September 2, 2008, Mother/Petitioner filed a Complaint for Custody, requesting primary physical custody of the minor child with periods of partial physical custody for purposes of visitation to the Father/Respondent. See copy of Complaint for Custody, attached. 6. Prior to the filing of the Complaint for Custody, Father/Respondent signed the minor child out of school on Friday, August 29, 2008, at 11:00 AM, stating there was a family emergency and Father/Respondent has not returned the child to Mother/Petitioner. 7. Since that time, the child has been allowed to speak to Mother on the phone and the child has cried and pleaded to come back to Mother. 8. Father agreed to bring the child to school on Tuesday, September 2, 2008, at which time Mother could meet with child and take the child into the school. Father did not show up at the school with child and now child is absent from school. 9. Father has indicated that he is not going to return the child to Mother because his "attorney has advised that he does not have to" return the child. 10. Mother has been the primary caregiver of child since birth. 11. It is in the best interest of the child that she be returned to her Mother for primary physical custody with periods of visitation with Father. 12. No Judge has ruled upon any other issue in the same or related matter. WHEREFORE, it is respectfully requested that this Court grant an Interim Order granting primary physical custody of the minor child with her natural Mother, the Petitioner, pending resolution of the Complaint in Custody. Dated: September 2, 2008 Respectfully submitted, FRIEDMAN & G, P.C. By: 'chard S. Friedman, Esq. ID 07176 3820 Market Street Camp Hill, PA 17011 (717) 236-8000 (717) 236-8080 FAX friedmanandking@hotmail.com Attorney for Petitioner/Mother VERIFICATION I, Cassandra Barilla, hereby acknowledge that I am the Plaintiff/petitioner in the foregoing action; that I have read the foregoing Petition for Special Relief; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Dated: September , 2008 Cassandra Barilla CASSANDRA K. BARILLA, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . NO. EDWARD M. BARILLA, III , : CIVIL ACTION - LAW Defendant : CUSTODYNISITATION ORDER OF COURT AND NOW, , upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on , at _.M. 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: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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, PA 17013 Telephone (717) 249-3166 FRIEDMAN & KING, P.C. Richard S. Friedman, Esquire ID #07176 3820 Market Street Camp Hill, PA 17011 Tel.: (717) 236-8000/Fax: (717) 236-8080 E-mail: friedmanandking@hotmail.com CASSANDRA K. BARILLA, Plaintiff V. EDWARD M. BARILLA, III, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CUSTODY/VISITATION COMPLAINT FOR CUSTODY 1. The Plaintiff is Cassandra K. Barilla, residing at 127 E. Simpson Street, Mechanicsburg, PA 17055. 2. The Defendant is Edward M. Barilla, III, residing at 611 Mallard Road, Camp Hill, PA 17011. 3. Plaintiff seeks custody of the following child: NAME PRESENT RESIDENCE AGE DOB Dakota L. Barilla 127 E. Simpson Street 5 years 09/07/2002 Mechanicsburg, PA 17055 The child was not born out of wedlock. The child is presently in the custody of Plaintiff/Mother, who resides at 127 E. Simpson Street, Mechanicsburg, PA 17055. During the past five (5) years, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATE Cassandra K. Barilla 127 E. Simpson Street 08/29/2008 to present Bonnie Pearl (maternal grandmother) Mechancisburg, PA 17055 Cassandra K. Barilla 611 Mallard Road 02/2007 to 08/29/2008 Edward M. Barilla, III Camp Hill, PA 17011 Cassandra K. Barilla 127 E. Simpson Street 03/2006 to 02/2007 Edward M. Barilla, III Mechancisburg, PA 17055 Bonnie Pearl (maternal grandmother) Cassandra K. Barilla 330 W. Allen Street 08/2004 to 03/2006 Edward M. Barilla, III Mechanicsburg, PA 17055 Tammy Berger (paternal grandmother) Sam Gipe and Patricia Gipe (paternal great-grandparents) Cassandra K. Barilla 130 Summer Lane 08/2003 to 08/2004 Edward M. Barilla, III Enola, PA The mother of the child is Cassandra K. Barilla, currently residing at 127 E. Simpson Street, Mechanicsburg, PA 17055. She is married. The father of the child is Edward M. Barilla, III, currently residing at 611 Mallard Road, Camp Hill, PA 17011. He is married. 4. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: NAME Bonnie Pearl Dakota L. Barilla RELATIONSHIP Mother Daughter 5. The relationship of the Defendant to the child is that of Father. The Defendant currently resides by himself. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child 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 child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because Mother has been the primary caregiver of child since birth. 8. Each parent whose parental rights to the child have not been terminated, and the person who has physical custody of the child, have been named a party to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the child. Respectfully submitted, FRIEDMAN & KING, P.C. Date: °Z a Richard S. Friedman, Esquire 3820 Market Street Camp Hill, PA 17011 (717) 236-8000 Attorney for Plaintiff ?} t1? (? t7 ..i? ? ?' t ?.?. --?r? ? ;; ? t? .'??? ? , ,?- ` ?; ? _?? ) w?.. G.i 1 CASSANDRA K. BARILLA IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. EDWARD M. BARILLA III DEFENDANT 2008-5241 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, September 05, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, October 14, 2008 at 9:00 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. All children age five or older may also be present at the conference. 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/ Daum S. Sunday, Esq. / (Xj 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 lw? -, y1 CASSANDRA K. BARILLA, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 08-5241 EDWARD M. BARILLA, III, : CIVIL ACTION - LAW Defendant : CUSTODYNISITATION STIPULATION THIS AGREEMENT, made this '>I} day of September, 2008, by and between Cassandra K. Barilla, hereinafter referred to as "Mother" and Edward M. Barilla, III, hereinafter referred to as "Father", WHEREAS, the parties are the parents of a minor child, Dakota L. Barilla, born September 7, 2002, and WHEREAS, the parties hereto desire to set forth herein their respective rights as to custody of the aforesaid minor child in a manner as to facilitate continued contact by both parents, and WHEREAS, the parties hereto have reached an agreement concerning the custodial rights of the parties with respect to the child and the parties desire to set forth the terms of such an agreement herein, and WHEREAS, each of the parties have had the full opportunity to seek the advice of counsel in regard to his or her respective rights, duties and obligations arising out of the parental status, NOW, THEREFORE, in consideration of the mutual covenants, promises and undertakings herein, as hereto set forth, and Mother and Father, each intending to be legally bound hereby, agree as follows: 1. SHARED LEGAL CUSTODY: The parties agree to share joint legal custody of the child. Joint legal custody means the rights of both parents to control and to share in making decisions of importance in the life of their child, including educational, medical and religious decisions. Both parents shall be entitled to equal access to the child's school, medical, dental and other important records. As soon as practicable, after receipt by a party, copies of the child's school schedule, special events notifications, report cards and similar items, shall be provided to the other party. Each party shall notify the other party of any medical, dental, optical and other appointments with healthcare providers sufficiently in advance thereof, so the other party can attend. Notwithstanding that both parents share legal custody, non-major decisions regarding the child's day to day living shall be made by the parent then having custody, consistent with other provisions of this stipulation. 2. PHYSICAL CUSTODY: A. Mother shall have primary physical custody of the child. B. Father shall have physical custody of the child for purposes of visitation as follows: L. Every other weekend, from Friday at 6:30 PM to Sunday at 6:30 PM. ii. One evening per week from 5:00 PM to 7:00 PM, the day of his choosing. It is intended that Father, as a general rule, will choose the same day each week. iii. During the summer vacation from school, Father shall have the child every other week, beginning Sunday, at 6:00 PM until Saturday, at 6:00 PM. These periods of visitation will begin at the end of the first full week off school and will end five (5) days before the beginning of school year. 3. HOLIDAYS: The parties will alternate the following major holidays: Easter, Memorial Day, Fourth of July, Labor Day, and Thanksgiving. The custodial period shall run from Noon until 6:00 PM. This schedule will begin with Mother having the child on Thanksgiving. Christmas will be divided into two segments. These segments will alternate with Mother having Segment A in even numbered years and Father having Segment A in odd numbered years. Segment A is from December 23rd at the end of the school day until December 25`h at Noon. Segment B is from December 25 h at Noon until December 271 at 6:00 PM. Father shall have custody on Father's Day and Mother shall have custody on Mother's Day. 4. TRANSPORTATION: Father is to transport the child at the beginning of the period of visitation and Mother is to transport the child at the end of the period of visitation. 5. LATE FOR EXCHANGE: In the event any party is more than thirty (30) minutes late for a scheduled custody exchange, said party shall contact the other party to advise of the delay. In the absence of a telephone call or other communication from the parent picking up the Child, the other party may assume that the parent who is late has chosen not to exercise that period of custody, the period will be forfeited, and the other party will be free to make other plans with the Child. 6. RIGHT OF FIRST REFUSAL: The non-custodial parent shall have the right of first refusal in any instance in which the custodial parent requires daycare/babysitting. 7. SCHOOL: The child shall attend school in the School District in which Mother resides. 8. ILLNESS OF CHILD: Emergency decisions regarding the child shall be made by the parent then having custody. However, in the event of -any emergency or serious illness of the child at any time, any party then having custody of the child shall immediately communicate with the other party by telephone or any other means practical, informing the other party of the nature of the illness or emergency, so the other parent can become involved in the decision making process as soon as practical. "Serious illness" of the child to be defined as "Any disability which confines the child to bed for a period in excess of seventy-two (72) hours and which places the child under the direction of a licensed physician." 9. MUTUAL CONSULTATION: Each party shall confer with the other on all matters of importance relating to the child's health, maintenance, and education with a view towards obtaining and following a harmonious policy in the child's education and social adjustments. Each party agrees to keep the other informed of his or her residence and telephone number to facilitate communication concerning the welfare of the child and visitation. Each party agrees to supply the name, address and phone numbers of any persons in whose care the child will be for a period in excess of seventy-two (72) hours, and for each person or entity which may provide day care for the child. 10. RELOCATION: If either party desires to establish a residence more than fifty (50) miles from the present residences, he or she shall give the other party at least ninety (90) days written notice in advance of the proposed move and all information requested by the other party about the proposed move. If the parties are unable to agree to a modification of terms necessitated by said move, the Court of Common Pleas of Cumberland County, Pennsylvania, shall have exclusive jurisdiction of the parties and the child to enter an appropriate primary custody/partial custody Order. 11. TELEPHONE/MAIL ACCESS: Each party shall have reasonable telephone and mail access to the child when in the custody of the other parent. 12. NON-INTERFERENCE: Neither party shall impair the other party's right to custody or interfere with the other parent's custody when the child is with that parent. 13. DISPARAGING REMARKS: Each of the parties and any third party in the presence of the child shall take all measures deemed advisable to foster a feeling of affection between the child and the other party. Neither party shall do nor shall either parent permit any third person to do or say anything which may estrange the child from the other parent, their spouse or relatives, or injure the child's opinion of the other party or which may hamper the free and natural development of the child's love and respect for the other parent. The parties shall not use the child to convey verbal messages to the other parent about the custody situation or changes in the custody schedule. 14. REASONABLE NOTICE OF TRAVEL: Each party shall promptly notify the other of any travel plans, travel arrangements, and any delays which might affect the custodial arrangements. Each party shall provide the other party notice reasonably in advance of any scheduled extended trip with an itinerary including names of hotels or residence addresses and telephone numbers for the applicable periods of time. 15. CONTROLLED SUBSTANCES/ALCOHOL: During any period of custody or visitation, the parties to this Order shall not possess or use controlled substances or consume 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 prohibition. Neither party will smoke cigarettes or tobacco products nor allow others to smoke in the presence of the child. 16. TELEPHONE CALLS: Both parties are expected to use common sense in scheduling telephone calls to talk to the child. Both parties are hereby directed to refrain from preventing the parent who may be calling from talking to the child, or preventing the child from calling the other parent, provided that the phone calls are not excessively frequent nor too long in duration that they disrupt the child's schedule. 17. EXTRACURRICULAR ACTIVITIES: Each party shall provide the other with at least forty-eight (48) hours advance notice of school or other activities whenever possible. Both parties shall agree to honor and participate in the activities in which the child wishes to engage. During the times that the parents have custody of the child, they will make certain that the child attends any extracurricular activities. The parties are directed to be supportive of the activities and will transport the child to and from such activities and the preparations and practice for the activities that are scheduled, in such time so that the child is able to participate in those events. Neither parent, however, shall commit the child to any activity unless the child definitely desires to attend that activity. Participation in activities, which take place during the school year, is contingent upon the child maintaining passing grades in school. Neither parent shall commit the child to activities that fall on the other parent's period of custody, without the consent of the other parent, which consent shall not be unreasonably withheld. If the child is involved in activity which occurs during both parents' periods of custody, both parents shall cooperate in providing transportation of the child to the activity. However, the custodial parent shall not be required to take the child to that activity if the custodial parent and child are out of town during that activity, for a previously scheduled vacation. In the event that the custodial parent is unable to deliver the child to the particular activity, the parent who has custody of the child at that time shall notify the non-custodial parent, who shall be entitled to pick up and deliver the child to the designated activity. The custodial parent shall make certain that the child is ready for pickup in time sufficient to enable the child to timely attend the activity. 18. WELFARE OF CHILD TO BE CONSIDERED: The welfare and convenience of the child shall be the prime consideration of the parties in any application of the provisions of this Stipulation. Mother and Father shall listen carefully and consider the wishes of the child in addressing the custodial schedule, any changes to the schedule, and any other parenting issues. 19. MODIFICATION OF ORDER: The parties are free to modify the terms of this Order, but in order to do so, the Court makes it clear that both parties must be in complete agreement to any new terms. That means both parties must consent on what the new terms of the custody arrangement or visitation schedule shall be. In the event that one or the other does not consent to a change, that does not mean each follows your own idea as to what you think the arrangements should be. The reason this Court Order is set out in detail is so both parties have it to refer to and to govern your relationship with the child and with each other in the event of a disagreement. 20. The parties agree that this Stipulation may be entered as an Order of the Court. Date: Edward M. Barilla, III, Father Date: q SDI PmAa ? ? . &T. Cassandra K. Barilla, Mother In the event that the custodial parent is unable to deliver the child to the particular activity, the parent who has custody of the child at that time shall notify the non-custodial parent, who shall be entitled to pick up and deliver the child to the designated activity. The custodial parent shall main certain that the child is ready for pickup in time sufficient to enable the child to timely attend the activity, 18. WELFARE OF CHILD TO BE CONSIDERED: The welfare and convenience of the child shall be the prime consideration of the parties in any application of the provisions of this Stipulation. Mother and Father shall listen carefully and consider the wishes of the child in addressing the custodial schedule, any changes to the schedule, and any other parenting issues. 19. MODIFICATION OF ORDER: The parties are free to modify the terms of this Order, but in order to do so, the Court makes it clear that both parties must be in complete agreement to any new terms. That means both parties must consent on what the new terms of the custody arrangement or visitation schedule shall be. In the event that one or the other does not consent to a change, that does not mean each follows your own idea as to what you think the arrangements should be. The reason this Court Order is set out in detail is so both parties have it to refer to and to govern your relationship with the child and with each other in the event of a disagreement. 20. The parties agree that this Stipulation may be entered as an Order of the Court. Date: V .!E a Date: Edward M. Barilla, III, Father -C"? i - &a. Cassandra K. Barilla, Mother Date: 04 la s I.,& Date: ! ?ZgL4, K Harry Baturin, Esq. Attorney for Fath Ric . Fri Esq. Attorney for Mother c: - "'r .? LJ J8 r-7 CASSANDRA K. BARILLA, Plaintiff V. EDWARD M. BARILLA, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 08-5241 CIVIL ACTION - LAW CUSTODYNISITATION ORDER AND NOW, this < < day of , 2008, upon stipulation of the parties, it is hereby ORDERED and DECREED that the terms, conditions and provisions of the attached Stipulation for custody entered into by the parties, and executed by the parties and their counsel, are adopted as an Order of Court. J. (VIMYYT-, tt i AlN 4iJo +?;?Yf??Y? nt,P-lH L O .6 WV ?I d3S sa'tt/b m ?o b7L/ t Vp 2 2 2008 CASSANDRA K. BARILLA IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2008-5241 CIVIL ACTION LAW EDWARD M. BARILLA, III Defendant IN CUSTODY ORDER AND NOW, this 16th day of September, 2008 , the conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for October 14, 2008 is cancelled. FOR THE COURT, Dawn S. Sunday, Esquire 61 Custody Conciliator C :) +'vv ° =:? ? a `? r- '' ? ? ?7 ( ? r t? Z -,? f?' r.. ? ?? µ ?...? ? .> ` ? .? ? :? ?"`