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HomeMy WebLinkAbout08-5242IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REBECCA S. B. NEUMANN, CIVIL ACTION Plaintiff No, Qg'- ?oZy ST. vi. MERICK LORIN NEUMANN, CUSTODY Defendant COMPLAINT FOR CUSTODY G w ;l 4e-r44 1. The plaintiff is Rebecca S. B. Neumann who currently resides at 1215 Georgetown Circle, Carlisle, Pennsylvania, which is in Cumberland County, Pennsylvania. 2. The defendant is Merick Lorin Neumann who currently resides at 1113 Shannon Lane, Carlisle, Pennsylvania, which is in Cumberland County, Pennsylvania. 3. The plaintiff is seeking custody of the following children: Name Residence Age Elizabeth Haley Neumann 1215 Georgetown Circle, Carlisle 9 (DOB - 3/10/99) Logan Grier Neumann 1215 Georgetown Circle, Carlisle 7 (DOB --10/21 /00) The children were not born out of wedlock. During the past five years, the child has resided with the following persons and at the following addresses: (List all Persons) (List all Addresses) (Dates) Merick, Rebecca, 1113 Shannon Lane 12/07 - 8/31/08 Elizabeth and Logan Carlisle, PA 17013 Merick, Elizabeth 1113 Shannon Lane 12/06 -12/07 and Logan Carlisle, PA 17013 (During this period of time Rebecca maintained two residences - one being at this home and the other being in Mechanicsburg. Rebecca (mother) was with the children every day, where she either stayed with them at the Carlisle home or they went with her to stay at her home in Mechanicsburg). Merick, Rebecca, 1113 Shannon Lane 9/03- 12/06 Elizabeth and Logan Carlisle, PA 17013 The mother of the children is Rebecca Neumann, currently residing at 1215 Georgetown Circle, Carlisle, PA 17013. She is married but currently separated. The father of the child is Merick Lorin Neumann, currently residing at 1113 Shannon Lane, Carlisle, PA 17013. He is married, but currently separated.. 4. The relationship of plaintiff to the children is that of mother. The plaintiff currently resides with the following persons other than children: Gary Blacksmith, Jr., M.D. and Eldora Blacksmith (her parents). 5. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons other than the children: None 6. Plaintiff has not participated as a party or witness or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a parry 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: Plaintiff is willing and able to perform the primary parental responsibilities for the children. Plaintiff is in the best position to provide the care and nurture which the children need for healthy development. Defendant does not provide for the children's physical, psychological or social needs while they are in his care. 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 as parties to this action. WHEREFORE, plaintiff requests the court to grant him custody of the minor children. #A D. Coover, Esquire Attorney ID 92385 44 S. Hanover Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REBECCA S. B. NEUMANN, CIVIL ACTION Plaintiff . V. MERICK LORIN NEUMANN, CUSTODY Defendant VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein, are made subject to penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. IhA Rebecca Neumann Date: d x c7-. Y ?1 1 i t REBECCA S. B. NEUMANN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MERICK LORIN NEUMANN DEFENDANT 2008-5242 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 John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 14, 2008 at 8:30 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 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: ls/ John j. Mangan, Jr., Esq. 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 r S- ]S 8oz i REBECCA S.B. NEUMANN, Plaintiff V. MERICK LORIN NEUMANN, Defendant III i IN THE COURT OF COMMON 4P EAS OF CUMBERLAND COUNTY, PE SYLVANIA CIVIL ACTION -LAW NO. 08-5242 IN CUSTODY PRAECIPE TO ENTER APPEARANCE i TO THE PROTHONOTARY Please enter my appearance on behalf of the Defendant, Merick Lorin Ne ann, in the above-captioned matter. Date: Mark F. Bayley, Esquite Bayley & Mangan 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Defendant REBECCA S.B. NEUMANN, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA I V1. CIVIL ACTION -LAW NO. 08-5242 MERICK LORIN NEUMANN, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the within Praecipe upon the following by depositing same in the Unitedl? States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Sheri D. Coover, Esquire 44 S. Hanover Street Carlisle, PA 17013 Mark F. Bayley, Esq r .?O Attorney for Defendant Dated: C V- r M E En Fil -15 -0 rr, a? REBECCA S. B. NEUMANN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-5242 CIVIL ACTION LAW MERICK LORIN NEUMANN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, September 15, 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 Courtbouse, Carlisle on Thursday, October 16, 2008 at 8:30 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: Is/ Hubert X. Gilroy, g% 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 -71u. .a?l?ealu.4? ?mt,/7/ bd SO •C Wd 61 d3S 8801 A t v is 'W 3A ?O 3101H-1?0 3113 A ICT S0 2JU REBECCA S. B. NEUMANN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW MERICK LORIN NEUMANN, NO. 2008-5242 Defendant IN CUSTODY COURT ORDER AND NOW, this 2 / " day of October, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The mother, Rebecca S. B. Neumann, and the father, Merick Lorin Neumann, shall enjoy shared legal custody of Elizabeth Haley Neumann, born March 10, 1999, and Logan Grier Neumann, born October 21, 2000. 2. The Mother shall enjoy primary physical custody of the minor children. 3. The Father shall enjoy periods of temporary physical custody of the minor children as follows: A. Alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. unless the time for exchange of custody is agreed otherwise by the parties; and B. In addition to the vacation and holiday schedule set forth below, Father shall enjoy periods of temporary custody at such times as agreed upon by the parties. 4. Both parents shall be entitled to at least two weeks of vacation with the minor children during the summer months with the understanding that each parent will give the other parent at least sixty (60) days notice as to when they would intend to exercise that vacation. 5. Holidays shall be handled as follows: A. The Mother shall enjoy the Christmas holiday itself each year with the understanding that Father shall have at least three (3) days set aside during the children's school Christmas holiday to enjoy those days with the children, and those days may be added to one of the weekends Father has over the Christmas holiday. B. For Memorial Day, July 4`h and Labor Day, the parties shall alternate those holidays with the Father getting Memorial Day in 2009 and the parties alternating thereafter. C. The Thanksgiving holiday shall be alternating with the Mother having Thanksgiving in 2008 and the parties alternating thereafter. For the Thanksgiving holiday, custody shall be from the Wednesday before through the evening of Thanksgiving day at a minimum. 6. The parties may modify or alter the custody schedule set forth above if they agree. Absent an agreement, the parties shall follow the Order. In the event either party desires to modify this custody Order, that party may petition the Court to have the case again scheduled with the custody Conciliator for a conference. BY THE COURT, Judge cc: eri D. Cooper, Esquire ? Mark F. Bayley, Esquire en'a t LCL REBECCA S. B. NEUMANN, Plaintiff vs. MERICK LORIN NEUMANN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-5242 IN CUSTODY 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: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Elizabeth Haley Neumann, born March 10, 1999 Logan Grier Neumann, born October 21, 2000 2. A Conciliation Conference was held on October 16, 2008, with the following individuals in attendance: The mother, Rebecca S. B. Neumann, who appeared with her counsel, Sheri D. Coover, Esquire, and the father, Merick Lorin Neumann, with his counsel, Mark F. Bayley, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date October 2008 Hubert X. Gilroy, squire Custody Concil' for ELED -CTF !' ? ? ?. 0r Ts F?F Sheri D. Coover, Esquire Attorney ID 93285 23 -,1 44 S. Hanover Street ' L t _ S FR t Carlisle, PA 17013 ??;..• ` (717) 960-0075 (telephone) (717) 960-0074 (facsimile) shericoover@yahoo.com REBECCA S.B. NEUMANN, Plaintiff V. MERICK LORIN NEUMANN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CASE NO. 08-5242 IN CUSTODY MOTION TO MODIFY CUSTODY AND MOTION FOR CONTEMPT OF COURT ORDER AND NOW, comes Defendant Rebecca Neumann, by and through her attorney, Sheri D. Coover, Esquire, and files the following DEFENDANT'S MOTION TO MODIFY CUSTODY AND MOTION FOR CONTEMPT OF COURT ORDER and in support thereof avers as follows: 1. On or around October 21, 2008, this Court issued an Order which granted Rebecca S. B. Neumann (hereinafter referred to as "Mother") primary physical custody of the minor children Elizabeth Haley Neumann (DOB 3/10/99) and Logan Grier Neumann (DOB 10/21/00) and granted Merick Lorin Neumann 70-00 Pd .a4 y? `i° SS 7 50 (hereinafter referred to as "Father") periods of temporary physical custody on alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. (a true and correct copy of the October 21, 2008 Custody Order is hereby attached to this MOTION). 2. The parties were to share legal custody of the minor children according to the Court Order. 3. During Father's period of custody that he exercised on the weekend of February 11, 2011, Elizabeth became very ill. 4. Elizabeth told Father that she was feeling ill, but Father refused to pay attention to her and refused to get her medicine. 5. After three hours of begging Father to get her medicine with no success, Elizabeth called Mother and asked Mother if she would come to pick her up. 6. Mother informed Elizabeth that it was Father's period of custody with her, but that Mother would attempt to discuss the situation with Father to see if there were any options available that Father would be agreeable to. 7. Mother tried to call Father three times and sent him two text messages, but Father did not respond to Mother's calls or text messages. 8. Later that day, Elizabeth contacted Mother again because she was still feeling ill, was not getting any care from Father and wanted for Mother to pick her up. 9. At that time, Elizabeth put Mother on speaker phone so that Mother could speak to Father. 10. Father became irate at Elizabeth's request to be returned to Mother's care and yelled at Mother (who was on speaker phone), Logan and Elizabeth that he would return the children in thirty minutes, that he would no longer give them lunch money, help with fundraisers, go to any sporting events that they are involved in and that the only thing that he wanted to do with any of them was the $53.00 per week that he paid in child support. 11. Mother further asserts that it is appropriate to modify the custody Order for the following reasons: a. Father refuses to take medicine for his bipolar and OCD, which causes him to treat the children in a negative manner; b. Father has had his own apartment for six months which he has refused to clean and now has dried urine on the floor of the bathroom; c. Father refuses to prepare food for the children while they are in his custody and makes the children prepare their own food if they are hungry; d. Elizabeth expresses that she is ignored by Father while she is in his care and she does not want to go on further visitations with Father; e. Father refuses to take care of the children when they are sick and refuses to make an effort to get the children medicine when necessary; f. Father does not properly supervise the children while they are in his care and allows the children to stay up very late; g. Father makes promises to the children to take them to their extra- curricular activities, but will refuse to take them at the last minute; h. Father refuses to help the children do any of their school work or work on their school projects during his periods of custody; i. Father does not show up on time for custody exchanges and at times refuses to take both of the children during his periods of custody. 12. Father refuses to effectively communicate with Mother on issues concerning the children, including what time, when and for how long he intends to exercise his periods of custody on his custodial weekends and makes custody arrangements through the children. 13. On or around February 6, 2011, while in Father's custody, Logan had an important activity with the Cub Scouts in the early morning. 14. It was very important to Logan to attend the activity because it was being held at the church which paid for Logan to attend camp the previous summer and a group picture with the Cub Scouts was scheduled to be taken at the event. 15. Since Logan was in Father's custody at the time, it was planned that Father was to provide Logan transportation to the event. 16. On the morning of the activity, Father decided that he did not feel like taking Logan to his Cub Scout activity, so Logan missed the event and was not included in the group picture which was taken. 17. Father plays mind games with the children and will withhold and refuse to return the children's property (such as Logan's computer). Father refuses to return the children's property for his own personal reasons and not as punishment to the children for bad behavior. 18. Father calls to speak to the children every night, but he often does so after 10:00 p.m. at night despite the fact that Mother has repeatedly requested that all calls be prior to 9:30 p.m. so that the children can get to bed. 19. The Honorable Judge Guido was previously assigned to this case. MOTION TO MODIFY CUSTODY 20. Mother incorporates paragraphs 1 through 19 above as contained in their entirety. 21. Mother believes that due to Father's untreated medical condition and his failure to properly care for the children during his periods of custody, that it is in the best interest of the children for Father's periods of custody of the children to be limited to times that he can be supervised with the children or at times as the parties otherwise mutually agree. 22. Mother believes that it is in the best interest of the children to modify the current custody Order as she requests. WHEREFORE, Mother requests that Father modify the current Custody Order to grant her primary physical custody of the minor children and to grant Father supervised periods of partial custody as the parties mutually agree. MOTION FOR CONTEMPT OF COURT ORDER 23. Mother incorporates paragraphs 1 through 22 above as contained in their entirety. 24. According to the current custody Order, Mother and Father are to have shared legal custody of the minor children. 25. Father refuses to communicate with Mother above issues regarding the children's education, medical treatment and the children's extra-curricular activities. 26. Since the date of the original custody Order, Father fails to meet Mother at the times designated for the custody exchange in the Current Order and will change plans on Mother at the last minute which allows Mother no time to properly plan for the children. WHEREFORE, Mother respectfully requests that this Court: a. Find Father in contempt of the current custody Order; b. Assess Father a $500.00 penalty for contempt of the Court's Custody Order pursuant to 23 Pa.C.S. § 4346; c. Mother's Petition for Contempt of Court Order should be addressed at a hearing before the Court; d. Other relief as this Court deems to be just and proper. submitted, Coover, Esquire ID 93285 44 S. Hanover Street Carlisle, PA 17013 Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) shericoover@,yahoo.com REBECCA S.B. NEUMANN Plaintiff V. MERICK LORIN NEUMANN, : Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA CASE NO. 08-5242 : IN CUSTODY ATTORNEY VERIFICATION I, Sheri D. Coover, Esquire, hereby verify that I reviewed the foregoing MOTION TO MODIFY CUSTODY AND FOR CONTEMPT OF COURT with the Plaintiff who verified that the facts contained therein are true and correct to the best of my knowledge, information and belief. I understand that I can be liable under Pennsylvania and federal law both civilly fd criminally for any false statements contained therein. I 1 . Sheri D. Coover, ESQ. Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) shericoover@yahoo.com REBECCA S.B. NEUMANN Plaintiff V. : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : CASE NO. 08-5242 MERICK LOREN NEUMANN, Defendant : IN CUSTODY CERTIFICATE OF SERVICE now) I, Sheri D. Coover, Esquire hereby certifies that on this OP day of 2011, I caused the foregoing MOTION TO MODIFY CUSTODY A OR CONTEMPT OF COURT to be served upon counsel for the Defendant via United States first class mail addressed as follows: Mark Bayley, Esquire Bayley & Mangan 17 W. South Street Carlisle, PA 17013 submitted, Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 r . WT so REBECCA S. B. NEUMANN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW MERICK LORIN NEUMANN, NO. 2008-5242 Defendant IN CUSTODY COURT ORDER AND NOW, this A • " day of October, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The mother, Rebecca S. B. Neumann, and the father, Merick Lorin Neumann, shall enjoy shared legal custody of Elizabeth Haley Neumann, born March 10, 1999, and Logan Grier Neumann, born October 21, 2000. 2. The Mother shall enjoy primary physical custody of the minor children. 3. The Father shall enjoy periods of temporary physical custody of the minor children as follows: A. Alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. unless the time for exchange of custody is agreed otherwise by the parties; and B. In addition to the vacation and holiday schedule set forth below, Father shall enjoy periods of temporary custody at such times as agreed upon by the parties. 4. Both parents shall be entitled to at least two weeks of vacation with the minor children during the summer months with the understanding that each parent will give the other parent at least sixty (60) days notice as to when they would intend to exercise that vacation. 5. Holidays shall be handled as follows: A. The Mother shall enjoy the Christmas holiday itself each year with the understanding that Father shall have at least three (3) days set aside during the children's school Christmas holiday to enjoy those days with the children, and those days may be added to one of the weekends Father has over the Christmas holiday. B. For Memorial Day, July 4`h and Labor Day, the parties shall alternai a those holidays with the Father getting Memorial Day in 2009 and the parties alternating thereafter. C. The Thanksgiving holiday shall be alternating with the Mother having Thanksgiving in 2008 and the parties alternating thereafter. For the Thanksgiving holiday, custody shall be from the Wednesday before Ihrough the evening of Thanksgiving day at a minimum. 6. The parties may modify or alter the custody schedule set forth above if they agree. Absent an agreement, the parties shall follow the Order. In the eveff either party desires to modify this custody Order, that party may petition the Court to have the case again scheduled with the custody Conciliator for a conference. BY THE COURT, Judge cc: ?*f' D. Cooper, Esquire ? Mark F. Bayley, Esquire I IDIZll08 REBECCA S.B. NEUMANN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA r 7:- s i-rT_ V. 2008-5242 CIVIL ACTION LAW -a; MERICK LORIN NEUMAN IN CUSTODY -- DEFENDANT ORDER OF COURT AND NOW, Thursday , March 03, 2011 , upon consideration of the attached Co mplai nt, 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 Wednesday, April 06, 2011 at 9:30 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, 011 - 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 3-3 ty9? 32 South Bedford Street av?'j Carlisle, Pennsylvania 17013 `LA Telephone (717) 249-3166 ?? 0 °Wa rr?"aid ?'Q°i REBECCA S. B. NEUMANN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANI A vs. CIVIL ACTION - LAW MERICK LORIN NEUMANN, NO. 2008-5242 .? Defendant IN CUSTODY cr ?" COURT ORDER :r cn as AND NOW, this day of May, 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's prior Order of October 21, 2008, shall remain in place subject to the following modifications: 1. Communications between the parties shall be limited to discussions on custody issues and pertaining directly to the children. Along these lines, Father is specifically advised that he should communicate with Mother on these issues, and Mother is specifically advised that she should limit her communications to Father along the lines of custody only. BY THE COURT, 2. Neither parent shall allow the children to be in the presence of anyone who has consumed alcohol to a degree of intoxication. 3. Exchange of custody shall take place at 6:00 p.m. at the WaWa store in Wyomissing. 4. Unless otherwise agreed upon, Father's next period of alternating weekend custody shall start on May 13, 2011. 5. Legal counsel for the parties shall have a telephone conference with the Custody Conciliator on Tuesday, June 14, 2011, at 8:30 a.m. cc-Sheri D. Coover, Esquire Mark F. Bayley, Esquire . r 0OP4- Kevin A. ess, Judge REBECCA S. B. NEUMANN, Plaintiff vs. MERICK LORIN NEUMANN Defendant Prior Judge: The Honorable Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-5242 IN CUSTODY 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 children who are the subject of this litigation is as follows: Elizabeth Haley Neumann, born March 10, 1999 Logan Grier Neumann, born October 21, 2000 2. A Conciliation Conference was held on April 29, 2011, with the following individuals in attendance: the mother, Rebecca S. B. Neumann, with her counsel, Sheri D. Coover, Esquire, and the father, Merick Lorin Neumann, with his counsel, Mark F. Bayley, Esquire 3. There are a number of issues swirling around the parties including a potential relocation by the Mother. Accordingly, the Conciliator believes that the existing Order should generally remain in place subject to some minor modifications and that legal counsel for the parties should have a conference call with the Conciliator at some point in June for purposes of updating the case to determine the status of the Mother's relocation. The Conciliator recommends an Order in the form as attached. Date: May, 2011 Z4- ?9 Hubert X. ilroy, Esquire Custody onciliator