Loading...
HomeMy WebLinkAbout08-5515GABRIEL D. MITCHELL, Plaintiff V. SHAUNDA A. JOHNSON Defendant : IN THE COURT OF COMMON PLEAS : OF THE 9h JUDICIAL DISTRICT : CUMBERLAND COUNTY, PA CIVIL ACTION - FAMILY NO. OF 2008 09 - SSIS CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Gabriel D. Mitchell, alleged Father of minor child, residing at 221 South 4`h Street, Lemoyne, Cumberland County, Pennsylvania. 2. The Defendant is Shaunda A. Johnson, mother of minor child, residing at 4 F Pfautz Road, Duncannon Pa, 17020. 3. The Plaintiff seeks shared physical custody of the following minor child: Name Present Residence Age Adrienne Rose Mitchell 4 F Pfautz Road, Duncannon, PA Newborn (9/3108) 4. The child is presently in the custody of Plaintiff who resides in Perry County, Pennsylvania. 5. Since birth, the child has resided with the following persons at the following address: Name Shaunda A.Johnson Address 4 F Pfautz Road Date birth to present 6. Since birth, the Defendant has stayed at the 4F Pfautz Road, Duncannon, Pennsylvania, residence overnight to care for the infant child on numerous occasions. 1 7. The natural mother of the children is Shaunda A. Johnson, Defendant. 8. The natural father of the children is Gabriel D. Mitchell, Plaintiff. 9. 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. 10. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 11. Plaintiff does not know of any person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 12. 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. 13. The best interest and permanent welfare of the child will be served by granting shared physical and legal custody to the Plaintiff. Plaintiff has genuine care and concern for the child. WHEREFORE, Plaintiff requests the court to grant him joint physical and legal custody of the minor child. Date: 1 RESPECTFULLY SUBMITTED: KREISHER AND GREGOROWICZ Marianne . leisher Fo lsanger, Esquire Attorney for Plaintiff 401 South Market StreQ Bloomsburg, PA 17815 (570) 784-5211 PA Supreme Court ID# 78106 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS Gabriel D. Mitchell, hereby states that he is the Plaintiff in this action and that the statements of fact made in the foregoing Complaint are true and correct to the best of his information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.Cons. Stat. Section 4904 relating to unsworn falsification to authorities. Date: GABRIEL D. MITCHELL N V l t..J .v p a (a p r q r ? GABRIEL D. MITCHELL, Plaintiff V. SHAUNDA A. JOHNSON Defendant : IN THE COURT OF COMMON PLEAS : OF THE 9" JUDICIAL DISTRICT : CUMBERLAND COUNTY, PA CIVIL ACTION - FAMILY NO. OF 2008 CUSTODY EMERGENCY PETITION FOR SPECIAL RELIEF NOW COMES, Gabriel D. Mitchell, Plaintiff, by and through her attorney Marianne K. Fogelsanger, Esquire, of KREISHER & GREGOROWICZ, and files this Emergency Petition for Special Relief, and in support thereof, avers as follows: 1. The Plaintiff is Gabriel D. Mitchell, father of minor child, residing at 221 South 0 Street, Lemoyne, Cumberland County, Pennsylvania. 2. The Defendant is Shaunda A. Johnson, mother of minor child, residing at 4 F Pfautz Road, Duncannon Pa, 17020. 3. The minor child, Adrienne Rose Mitchell, was born on September 2 ,2008. 4. Since the minor child's birth, the minor child has been residing with mother at 4 F Pfautz Road, Duncannon, PA. 5. Since the minor child's birth, father has been staying at the 4 F Pfautz Road, Duncannon, PA residence overnight to care for the infant. 6. Father has bonded with the minor child, enjoys spending time with the child, and wishes to care for and nurture his child. 7. On September 17, 2008, Plaintiff filed a Complaint for Custody requesting joint physical and legal custody of the minor child. 1 8. Defendant has indicated that she anticipates relocating with the minor child to Maryland, as soon as this upcoming weekend, and to remain at least several months there. 9. If Defendant relocates to Maryland, it will be very difficult for Plaintiff to maintain the level of contact with the minor child which he currently has. WHEREFORE, based on the aforementioned reasons, Plaintiff respectfully requests this Honorable Court to enter an Order prohibiting the relocation of the minor child outside the Perry, Cumberland, Dauphin County areas until the pending Custody Petition can be resolved. Respectfully submitted, Marianne K. p lsanger quire Attorney for Plaintiff 401 S. Market Street Bloomsburg, PA 17815 (570) 784-5211 Attorney ID # 78106 Date: September 17, 2008 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS Gabriel D. Mitchell, hereby states that he is the Plaintiff in this action and that the statements of fact made in the foregoing Emergency Petition for Special Relief are true and correct to the best of his information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.Cons. Stat. Section 4904 relating to unworn falsification to authorities. Date: GABRIEL D. MITCHELL _ T7 Q ^` rn -04 . p JK,' 1 Y r(w` v'y f GABRIEL D. MITCHELL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SHAUNDA A. JOHNSON DEFENDANT 2008-5515 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, September 22, 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 Thursday, October 30, 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ John . Mangan, r. Es . 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 ,OA cFp' 1 8 2008 Cn GABRIEL D. MITCHELL, Plaintiff V. SHAUNDA A. JOHNSON Defendant : IN THE COURT OF COMMON PLEAS : OF THE 9' JUDICIAL DISTRICT : CUMBERLAND COUNTY, PA : CIVIL ACTION - FAMILY : NO. OF 2008 : 03'.5-51,5 : CUSTODY 4t RULE AND NOW, this 0' day of , 2008, upon consideration of the within Emergency Petition for Special Relief, the Defendant is ruled to show cause why the relief requested by the Plaintiff should not be granted. RULE RETURNABLE, /INCA Slf' .. )..????? •r 4?... T+ ? ¦w¦¦. ::: ww??issa S > Muifflu, FV1H15y!VK11!M 0- It is hereby ORDERED and DIRECTED that neither party shall ? - permanently remove the minor child from the Commonwealth of Pennsylvania until resolution of the Emergency Petition for Spei -tic-rl"7,7or-s 0 S :C wd ZZ d3S 80OZ ,f NOV 0 3 2008Cn GABRIEL D. MITCHELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-5515 CIVIL ACTION LAW SHAUNDA A. JOHNSON, IN CUSTODY Defendant ORDER OF COURT AND NOW this day of November 2008, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Gabriel D. Mitchell, and the Mother, Shaunda A. Johnson, shall have shared legal custody of Adrienne Rose Mitchell, born 09/02/2008. The parties shall have an equal right 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. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has.possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody: The Mother and the Father shall share physical custody of the Child as follows: a. Commencing Thursday 10/30/2008, Father shall have physical custody of Adrienne from Thursday until Monday morning. Father shall pick the Child up after day care Thursday and return the Child to day care on Monday morning. b. Mother shall then pick up Adrienne Monday after day care and have physical custody Monday through Thursday morning. Mother shall pick the Child up after day care Monday and shall return the Child to day care Thursday morning. C. Father shall then pick up Adrienne after day care Thursday and have physical custody until Monday morning, returning the Child to day care. d. Mother shall then pick up the Child after day care on Monday and have physical custody until Friday morning, returning the Child to day care. e. Father shall then pick the Child on Friday after day care and have physical custody until Saturday morning at 9:00 am. f. Mother shall pick up the Child Saturday morning at Father's residence and have physical custody of the Child until Sunday 7:00 pm, returning the Child to Father's residence. g. Father shall then have physical custody of the Child from Sunday 7:00 pm until Monday morning, returning the Child to day care. h. Mother shall then pick up the Child Monday after day care and have physical custody of the Child until Thursday morning, returning the Child to day care. i. This physical custodial schedule outlined in subparagraphs 2 (a) through 2 (h) shall continue in subsequent weeks. j. The parties may alter said schedule by mutual agreement in writing. v 3. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. 4. Holidays: The parents shall arrange and alternate holidays as mutually agreed to. 5. Each parent shall have two non-consecutive weeks of vacation with the Child per year. The requesting parent shall give the other parent 30 days advance written notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 6. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other parry, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 8. In the event of a medical emergency, the custodial parry shall notify the other party as soon as practicable after the emergency is handled. 9. During any periods of custody or visitation, the parties shall not possess or use non-prescribed controlled substances or consume/be under the influence of 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 provision. 10. Relocation: This Order based upon the parties' residence in Cumberland County. If either party intends to establish residency a greater distance from where they presently reside and said move would impact the parties' ability to exercise their respective custodial periods, he or she must give to the other parent at least ninety (90) days' written notice in advance of the proposed move, in order to allow the parties to confer prior to the move and to establish a mutually satisfactory arrangement in light of the changed circumstances. In the event the parties are unable to reach an agreement, the Court of Common Pleas of Cumberland County shall have jurisdiction over them to fashion an appropriate custody Order. 11 This Order is entered pursuant to a Custody Conciliation Conference. the provisions of this Order by mutual consent. In the this Order shall control. The parties may modify consent, the terms of J. ?' ?,hzr,,? ,? ; ,P ?. ? _, 1 _? "? P, t" ?'I . i r,. • , , ? v ?? ";. ;,, ??? ?? ?Q??ooz Distribution: Robert B. Lieberman, Esq., 500 North Third Street, Twelfth Floor, P.O. Box 1004, Harrisburg, PA 17108-1004 Marianne Kreisher Fogelsanger, Esq., 401 South Market Street, Bloomsburg, PA 17815 John J. Man gan, Esquire Xf4ee 404,36,4_ 11 Q S o ?' 4- GABRIEL D. MITCHELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-5515 CIVIL ACTION LAW SHAUNDA A. JOHNSON, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH 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: Name Date of Birth Currently in the Custody of Adrienne R. Mitchell 9/02/2008 Primary Mother 2. A Conciliation Conference was held with regard to this matter on October 30, 2008 with the following individuals in attendance: The Mother, Shaunda A. Johnson, with her counsel, Robert Lieberman, Esq. The Father, Gabriel D. Mitchell, with his counsel, Marianne Kreisher Folgelsanger, Esq. 3. The parties agreed to the entry of an Order in the form as attached. ll Date John . M gan, Esquire Cust dy nciliator GABRIEL D. MITCHELL, IN THE COURT OF COMMON PLEAS Plaintiff OF THE 9' JUDICIAL DISTRICT CUMBERLAND COUNTY, PA V. CIVIL ACTION - FAMILY - CUSTODY SHAUNDA A. JOHNSON NO. 5515 OF 2008 Defendant MOTION FOR MODIFICATION OF A CUSTODY ORDER NOW COMES, the Plaintiff, Gabriel D. Mitchell, by and through his attorney, Marianne K. Fogelsanger, Esquire, and files this Motion for Modification of Custody Order, and in support thereof, avers as follows: 1. The petition of Plaintiff, Gabriel D. Mitchell, father of minor child, respectfully represents that on November 4, 2008 a Custody Order of Court was entered. (Order is attached hereto as "Exhibit A"). 2. The Plaintiff is Gabriel Mitchell, an adult individual currently residing at 155 East Columbia Street, Enola, Cumberland County, Pennsylvania. 3. The Defendant is Shaunda A. Johnson, mother of minor child, an adult individual currently residing at 4 F Pfautz Road, Duncannon Pa, 17020. 4. The attached Order should be modified because: a. On March 27, 2009, Mother provided Father with notice that she intended to move to Baltimore with the minor child and would be transferring her work to Baltimore. b. Since the conciliator meeting and entry of the court order, father has had physical custody of the minor child 114 days out of 145 days - approximately 79% of the time. WHEREFORE, Plaintiff requests that the Court modify the existing Order because it will be in the best interest of the child. RESPECTFULLY SUBMITTED: Date: #"21 "20 Marianne i[reisher ogelsanger, Esquire Attorney for Plain f 401 South Market Street Bloomsburg, PA 17815 (570) 784-5211 PA Supreme Court ID# 78106 GABRIEL D. MITCHELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-5515 CIVIL ACTION LAW SHAUNDA A. JOHNSON, IN CUSTODY Defendant ORDER OF COURT AND NOW this day of November 2008, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Gabriel D. Mitchell, and the Mother, Shaunda A. Johnson, shall have shared legal custody of Adrienne Rose Mitchell, born 09/02/2008. The parties shall have an equal right 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. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has.possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody: The Mother and the Father shall share physical custody of the Child as follows: O a. Commencing Thursday 10/30/2008, Father shall have physical custody of Adrienne from Thursday until Monday morning. Father shall pick the Child up after day care Thursday and return the Child to day care on Monday morning. b. Mother shall then pick up Adrienne Monday after day care and have physical custody Monday through Thursday morning. Mother shall pick the Child up after day care Monday and shall return the Child to daycare Thursday morning. C. Father shall then pick up Adrienne after day care Thursday and have physical custody until Monday morning, returning the Child to day care. d. Mother shall then pick up the Child after day care on Monday and have physical custody until Friday morning, returning the Child to day care. e. Father shall then pick the Child on Friday after day care and have physical custody until Saturday morning at 9:00 am. f. Mother shall pick up the Child Saturday morning at Father's residence and have physical custody of the Child until Sunday 7:00 pm, returning the Child to Father's residence. g. Father shall then have physical custody of the Child from Sunday 7:00 pm until Monday morning, returning the Child to day care. h. Mother shall then pick up the Child Monday after day care and have physical custody of the Child until Thursday morning, returning the Child to day care. i. This physical custodial schedule outlined in subparagraphs 2 (a) through 2 (h) shall continue in subsequent weeks. j. The parties may alter said schedule by mutual agreement in writing. 0 The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. 4. Holidays: The parents shall arrange and alternate holidays as mutually agreed to. Each parent shall have two non-consecutive weeks of vacation with the Child per year. The requesting parent shall give the other parent 30 days advance written notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 6. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other parry, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 8. In the event of a medical emergency, the custodial party shall notify the other party as soon as practicable after the emergency is handled. 9. During any periods of custody or visitation, the parties shall not possess or use non-prescribed controlled substances or consume/be under the influence of 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 provision. 10. Relocation: This Order based upon the parties' residence in Cumberland County. If either party intends to establish residency a greater distance from where they presently reside and said move would impact the parties' ability to exercise their respective custodial periods, he or she must give to the other parent at least ninety (90) days' written notice in advance of the proposed move, in order to allow the parties to confer prior to the move and to establish a mutually satisfactory arrangement in light of the changed circumstances. In the event the parties are unable to reach an agreement, the Court of Common Pleas of Cumberland County shall have jurisdiction over them to fashion an appropriate custody Order. 11 This Order is entered pursuant to a Custody Conciliation Conference. the provisions of this Order by mutual consent. In the this Order shall control. rRUE COPY f?HOM RECOHLo Testimony WNW, I two unto Id rtri hams a the of saw court at cum, ft ?- , ?.. __ Rf?Ih0111?? The parties may modify consent, the terms of J. Distribution: Robert B. Lieberman, Esq., 500 North Third Street, Twelfth Floor, P.O. Box 1004, Harrisburg, PA 17108-1004 Marianne Kreisher Fogelsanger, Esq., 401 South Market Street, Bloomsburg, PA 17815 John J. Mangan, Esquire GABRIEL D. MITCHELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLND COUNTY, PENNSYLVANIA V. No. 08-5515 CIVIL ACTION LAW SHAUNDA A. JOHNSON, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVII., 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: Name Date of Birth Currently in the Custody of Adrienne R. Mitchell 9/02/2008 Primary Mother 2. A Conciliation Conference was held with regard to this matter on October 30, 2008 with the following individuals in attendance: The Mother, Shaunda A. Johnson, with her counsel, Robert Lieberman, Esq. The Father, Gabriel D. Mitchell, with his counsel, Marianne Kreisher Folgelsanger, Esq. 3. The parties agreed to the entry of an Order in the form as attached. u Date John X. M gan, Esquire Cust dy nciliator COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS Gabriel D. Mitchell, hereby states that he is the Plaintiff in this action and that the statements of fact made in the foregoing Motion to Modify Custody Order are true and correct to the best of his information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.Cons. Stat. Section 4904 relating to unworn falsification to authorities. Date: t/ " 16 - ® q GABRIEL D. MITCHELL FILEC ,C OF ?'roc , `0 TAI 61 2009 AP 21 5,J7 470 . oo M ATT" ev* 4140 ` aa5a GABRIEL D. MITCHELL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-5515 CIVIL ACTION LAW SHUNDA A. JOHNSON DEFENDANT . IN CUSTODY ORDER OF COURT AND NOW, Friday, April 24, 2009 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 Friday, May 29, 2009 at 1:00 PM 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 hearinp-. FOR THE COURT. By: /s/ ohn J. Mangan, Jr., Esq. Custody Conciliator 1 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 Ait- OF T, HE 17FAp 2009 APR 2 7 Al 10. 2 9 nil Cc??y .???s,l?L. ,b ?+?,, 9 . J err ? Luc A+?L, J . r??..,.,>?? ? 1?., JUN 01.2009(1 (J GABRIEL D. MITCHELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-5515 CIVIL ACTION LAW SHAUNDA A. JOHNSON, IN CUSTODY Defendant Prior Judge: Edward E. Guido, J. ORDER OF COURT AND NOW this a,4 day of June 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. All prior Orders of Court are hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, Gabriel D. Mitchell, and the Mother, Shaunda A. Johnson, shall have shared legal custody of Adrienne Rose Mitchell, born 09/02/2008. The parties shall have an equal right 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. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: The Father shall have primary physical custody of Adrienne and Mother and Father shall arrange physical custody of the Child on a repeating basis as follows: a. Commencing May 31, 2009, in week one, Mother shall have custody from Sunday afternoon at 4:00 pm until Wednesday afternoon at 4:30 pm. Mother shall pick the Child up at Father's residence on Sunday and the parties shall exchange custody of the Child on Wednesday at Rutter's convenience store at the North George Street exit in York, PA. Father shall then have custody from Wednesday at 4:30 pm until Sunday at 4:00 pm. Mother shall pick the Child up at Father's residence on Sunday. b. In week two, Mother shall have custody from Sunday afternoon at 4:00 pm until Wednesday aftemoon at 4:30 pm. Mother shall pick the Child up at Father's residence on Sunday and the parties shall exchange custody of the Child on Wednesday at Rutter's convenience store at the North George Street exit in York, PA. Father shall then have custody from Wednesday at 4:30 pm until Sunday at 4:00 pm. Mother shall pick the Child up at Father's residence on Sunday. C. In week three, Mother shall have custody from Sunday afternoon at 4:00 pm until Wednesday afternoon at 4:30 pm. Mother shall pick the Child up at Father's residence on Sunday and the parties shall exchange custody of the Child on Wednesday at Rutter's convenience store at the North George Street exit in York, PA. Father shall then have custody from Wednesday at 4:30 pm until Friday at 4:30 pm. Mother shall pick the Child up at Father's residence on Friday. Mother shall have custody from Friday at 4:30 pm until Wednesday at 4:30 pm. Mother shall pick the Child up at Father's residence on Friday and the parties shall exchange custody of the Child on Wednesday at Rutter's convenience store at the North George Street exit in York, PA. d. In week four, as listed above, Mother shall have custody from Friday at 4:30 pm until Wednesday at 4:30 pm. Father shall then have custody from Wednesday at 4:30 pm until Sunday at 4:00 pm. Mother shall pick the Child up at Father's residence on Sunday. e The arties ma alter said schedule b mutual agree in writing. Week 1 Sunday Monday Tuesday Wednesday Thursday Friday Saturday D Week 2 Sunday Monday Tuesday Wednesday Thursday Friday Saturday M D D Week 3 Sunday Monday Tuesday Wednesday Thursday Friday Saturday D Week 4 Sunday Monday Tuesday Wednesday Thursday Friday Saturday (M (D) (D) (D) (D 4. It is specifically noted that Father's designation of primary care-giver for the Child shall not be held to the detriment or prejudice of the Mother in any future modifications of this Order. 5. In the event that Father moves more than fifteen (15) miles from his current residence and the parties can not agree regarding exchange locations, the parties may contact the assigned conciliator to resolve the issue. 6. Cumberland County, PA shall retain jurisdiction of any and all custody disputes, claims, modifications, etc. 7. The parties shall engage in therapeutic family counseling (with the focus on co-parenting issues) in the Cumberland County area to facilitate communication between the parties and to provide for the best interest of the Child. The cost of said counseling, after appropriate payment through insurance, shall be split equally between the parties. 8. Neither party shall seek child support from the other. Both parties shall execute the necessary documents to terminate the support issues currently pending. 9. The Child's primary care physician shall remain in Pennsylvania. The parties shall advise the other party of any and all scheduled doctor's appointments at least forty-eight (48) hours prior to the appointment. If a sick or emergency visit is scheduled, the party having custody shall notify the other party, if possible, before the visit and if not, as soon as possible after the visit occurred. 10. The parties shall alternate years for claiming the Child for tax purposes with Father claiming in even years of 2008 and 2010 and Mother claiming in odd years of 2009 and 2011. 11. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. 12. Holidays: The parents shall arrange and alternate holidays as attached. Additionally, each party shall have time with the Child on or near the Child's birthday and also at or near the parties' birthdays. 13. Each parent shall have two non-consecutive weeks of vacation with the Child per year. The requesting parent shall give the other parent 30 days advance written notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 14. In the event the custodial parent should take the Child out of their respective states, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. It is understood that Mother and Father live in different states and as such, this paragraph does not apply to the custody exchanges. 15. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 16. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 17. Each party shall keep the other party advised of their current address, individuals residing at that address and contact information. 18. During any periods of custody or visitation, the parties shall not possess or use non-prescribed controlled substances or consume/be under the influence of 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 provision. 19. During any periods of custody or visitation, the parties shall not smoke in confined places when the Child is present. The parties shall likewise assure, to the extent possible, that other household members and/or third parties comply with this provision. 20. Relocation: This Order based upon the parties' current residence in Cumberland County and Mother's proposed move to Maryland. If either parry intends to establish residency a greater distance from where they reside and said move would impact the parties' ability to exercise their respective custodial periods, he or she must give to the other parent at least ninety (90) days' written notice in advance of the proposed move, in order to allow the parties to confer prior to the move and to establish a mutually satisfactory arrangement in light of the changed circumstances. In the event the parties are unable to reach an agreement, the Court of Common Pleas of Cumberland County shall have jurisdiction over them to fashion an appropriate custody Order. 21. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence otmutmUQnsent, the terms of this Order shall control. J. Pstribution: obert B. Lieberman, Esq., 500 North Third Street, Twelfth Floor, P.O. Box 1004, Harrisburg, PA 17108-1004 ./Marianne Kreisher Fogelsanger, Esq., 401 South Market Street, Bloomsburg, PA 17815 /John J. Mangan, Esquire GOP I V.s .-anal c LL ?? alai - - LL, c =t cl- Lzi 2- LO HOLIDAYS AND limn EVEN ODD SPECIAL DAYS YEARS YEARS Easter From 4 pm the Friday before the holiday Father Mother until 4 pm Monday after the holiday. The parties shall meet at the Rutter's convenience store at the North George Street exit in York, PA on Friday and Mother shall provide the transportation to Father's residence on the Monday exchange Memorial Day From 4 pm Friday before the holiday until 4 Mother Father pm the day of the holiday. The parties shall meet at the Rutter's convenience store at the North George Street exit in York, PA on Friday and Mother shall provide the transportation to Father's residence on the Monday exchange Independence Day From 4 pm 7/3 until 4 pm 7/4. The parties Father Mother shall meet at the Rutter's convenience store at the North George Street exit in York, PA for the exchanges Labor Day From 4 pm Friday before the holiday until 4 Mother Father pm the day of the holiday. The parties shall meet at the Rutter's convenience store at the North George Street exit in York, PA on Friday and Mother shall provide the transportation to Father's residence on the Monday exchange Thanksgiving From 4 pm Wednesday before the holiday Mother Father until 4 pm the Sunday after the holiday. Mother shall provide the transportation to Father's residence on the Wednesday exchange and the parties shall meet at the Rutter's convenience store at the North George Street exit in York, PA for the Sunda exchange- Christmas 1 Half From 4 pm 12/24 until 4 pm 12/29. The Father Mother parties shall meet at the Rutter's convenience store at the North George Street exit in York, PA for the exchanges Christmas 2 Half From 4 pm 12/29 until 4 pm 01/02. The Mother Father parties shall meet at the Rutter's convenience store at the North George Street exit in York, PA for the exchanges Mother's Day From 4 pm the Friday before the holiday Mother Mother until 4 pm the day of the holiday. The parties shall meet at the Rutter's convenience store at the North George Street exit in York, PA for the exchanges Father's Day From 9 am until 9 pm. From 4 pm the Father Father Friday before the holiday until 4 pm the day of the holiday. The parties shall meet at the Rutter's convenience store at the North George Street exit in York, PA for the exchanges GABRIEL D. MITCHELL, Plaintiff V. SHAUNDA A. JOHNSON, Defendant Prior Judge: Edward E. Guido, J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-5515 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVEL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Adrienne R. Mitchell 9/02/2008 Primary Mother 2. A Conciliation Conference was held with regard to this matter on October 30, 2008, an Order issued November 4, 2008 and a conciliation conference was held May 29, 2009 with the following individuals in attendance: The Mother, Shaunda A. Johnson, with her counsel, Robert Lieberman, Esq. The Father, Gabriel D. Mitchell, with his counsel, Marianne Kreisher Folgelsanger, Esq. 3. In the event it is not necessary to have the designation of primary care-giver to procure insurance and other benefits, either party may contact the undersigned to amend the instant proposed Order 4. The parties agreed to the entry of an Order in the form as attached. Date John Jandan, Esquire Custody Conciliator 1 GABRIEL D. MITCHELL, Plaintiff/Petitioner V. SHAUNDA A. JOHNSON Defendant IN THE COURT OF COMMON PLEAS OF THE 9th JUDICIAL DISTRICE ) 1 CUMBERLAND COUNTY PA-q 0 a? , • CIVIL ACTION - FAMILY T NO. 08-5515' CUSTODY < Z- PETITION FOR MODIFICATION OF CUSTODY ORDER 1. The petition of Gabriel D. Mitchell respectfully represents that on November 4, 2008, an Order of Court was entered with respect to custody and visitation of the minor child, Adrienne Rose Mitchell, a true and correct copy of which is attached as "Exhibit A." 2. This Order should be modified because the parties have entered into a stipulation to alter the custody agreement on March 23, 2010. 3. A notarized custody stipulation signed by all parties involved is attached hereto as "Exhibit B." WHEREFORE, Petitioner requests that the Court modify the existing Order for Custody because it will be in the best interest of the child. Marianne K. Fogelsanl Attorney for etitioner KREISHER & GREG( 401 S. Market Street Bloomsburg, PA 1781 (717) 784-5211 ID# 78106 Esquire ?abriel Mitchell oo P o ATt 4 ?`? 51(v0 NOV GABRIEL D. MITCHELL, Plaintiff V. SHAUNDA A. JOHNSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-5515 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW this day of November 2008, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: Legal Custody: The Father, Gabriel D. Mitchell, and the Mother, Shaunda A. Johnson, shall have shared legal custody of Adrienne Rose Mitchell, born 09/02/2008. The parties shall have an equal right 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. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has.possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody: The Mother and the Father shall share physical custody of the Child as follows: a. b. C. d. e. f. 9. h. EXHIBIT j Commencing Thursday 10/30/2008, Father shall have physical custody of Adrienne from Thursday until Monday morning. Father shall pick the Child up after day care Thursday and return the Child to day care on Monday morning. Mother shall then pick up Adrienne Monday after day care and have physical custody Monday through Thursday morning. Mother shall pick the Child up after day care Monday and shall return the Child to day care Thursday morning. Father shall then pick up Adrienne after day care Thursday and have physical custody until Monday morning, returning the Child to day care. Mother shall then pick up the Child after day care on Monday and have physical custody until Friday morning, returning the Child to day care. Father shall then pick the Child on Friday after day care and have physical custody until Saturday morning at 9:00 am. Mother shall pick up the Child Saturday morning at Father's residence and have physical custody of the Child until Sunday 7:00 pm, returning the Child to Father's residence. Father shall then have physical custody of the Child from Sunday 7:00 pm until Monday morning, returning the Child to day care. Mother shall then pick up the Child Monday after day care and have physical custody of the Child until Thursday morning, returning the Child to day care. This physical custodial schedule outlined in subparagraphs 2 (a) through 2 (h) shall continue in subsequent weeks. The parties may alter said schedule by mutual agreement in writing. f1 The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. 4. Holidays: The parents shall arrange and alternate holidays as mutually agreed to. 5. Each parent shall have two non-consecutive weeks of vacation with the Child per year. The requesting parent shall give the other parent 30 days advance written notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 6. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 8. In the event of a medical emergency, the custodial party shall notify the other party as soon as practicable after the emergency is handled. During any periods of custody or visitation, the parties shall not possess or use non-prescribed controlled substances or consume/be under the influence of 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 provision. 10. Relocation: This Order based upon the parties' residence in Cumberland County. If either party intends to establish residency a greater distance from where they presently reside and said move would impact the parties' ability to exercise their respective custodial periods, he or she must give to the other parent at least ninety (90) days' written notice in advance of the proposed move, in order to allow the parties to confer prior to the move and to establish a mutually satisfactory arrangement in light of the changed circumstances. In the event the parties are unable to reach an agreement, the Court of Common Pleas of Cumberland County shall have jurisdiction over them to fashion an appropriate custody Order. 11 This Order is entered pursuant to a Custody Conciliation Conference the provisions of this Order by mutual consent. In the this Order shall control. CRUE COPY i-HtlM RECOHLO Testimony whored. I here unto set my hams d the seai of said Court at CUM, PL q% day za L «T __ -?TT? :itT? Prdh0lwt?r?t The parties may modify itual consent, the terms of J. Distribution: Robert B. Lieberman, Esq., 500 North Third Street, Twelfth Floor, P.O. Box 1004, Harrisburg, PA 17108-1004 Marianne Kreisher Fogelsanger, Esq., 401 South Market Street, Bloomsburg, PA 17815 John J. Mangan, Esquire REC'EI'?- #1?1 0 ? 1AR-23-2010 09:00 From:KREISHER & GREGOROWI 5703871477 To:17179759993 P.2/7 - GABRIEL D. MITCHELL, Plaintiff' V. SHAUNDA A. JOHNSON Defendant IN THE COURT OF COMMON PLEAS OF THE 9`h JUDICIAL DISTRICT CUMBERLAND COUNTY, PA CIVIL ACTION -- FAMILY NO. 08-5515 CUSTODY !QMSrCUDY ST'[FULAMN day of 1r1 r 2010, the parties AND NOW, to wit, this _C1.,....-? hereto, Gabriel D. Mitchell, Plaintiff, and Shaunda A. Johnson, Defendant, stipulate and agree as follows: 1. Primary physical and legal custody of the minor child, Adrienne Rose Mitchell, born September 2, 2008, shall be with Father. 2. So long as Mother has a residence where child will have a bed, Mother shall have partial physical custody as follows: EXHIBIT b- a. Every other weekend - Mother shall have partial physical custody of the minor child from Friday at 4:00 p.m.. until Sunday at 6:00 p.m. b. Wednesday- Mother shall have visitation with the minor child on Wednesdays from 9;00 a.m. to 8:00 p.m. at her residence. Mother shall provide all transportation for Wednesday visits. If mother is unable to keep Wednesday visitation she shall notify father at least 24 hours in advance. 03/23/2010 08:06 RECEIVED FROM: 5703871477 #0719-002 1AR-23-2610 09:00 From:KREISHER & GREGOROWI 5703871477 To:17179759993 P.3/7 Mother's Day -- Mother shall have partial physical custody of the rninor child from Friday at 4:00 p.m. until Sunday at 6:00 p.m. on the weekend of Mother's Day. e. Mother's Birthday - Mother shall have partial physical custody of the minor child from Friday at 4:00 p.m. until Sunday at 6:00 p.m of the weekend of or after her birthday. d. Adrienne's Birthday -Mother shall have partial physical custody of the minor child from Friday at 4:00 p.m, until Sunday at 6:00 p.m of the weekend of or after the minor child's birthday. Mother shall provide 2 weeks prior notice as to the weekend to be exercised for Mother's and Adrienne's birthday weekend. This provision is intended to allow Father to schedule a birthday celebration for the minor child either the weekend before or the weekend aver the minor child's birthday. e, Mother shall have additional periods of partial physical custody with the minor child at such. other times and places acid under such circumstances as the parties may mutually agree upon from time to time. 3. Father shall have custody of the minor child on the weekend of Father's Day. 4, Except where listed above,the parties shall share transportation to maintain the schedule of contacts set forth herein, Page 2 of 6 03/23/2010 08:06 RECEIVED FROM: 5703871477 #0719-003 1AR-23-2010 09:00 From:KREISHER & GREGOROWI 5703871477 To:17179759993 P.4/7 - S. The parties shall exchange all information pertaining to the health, education, and welfare of the minor child; including without limitation, report cards, progress reports from school, approval of extraordinary medical and dental treatment, summer school and summer camp, 6. The parties shall have equal access to all school and medical records of the minor child and each shall have the ability to consent to emergency medical treatment when the child is in the custody of such party, 7. If circumstances from time to time prevent the exercise of partial physical custody or visitation, the parties shall provide one another with timely and reasonable notice as to the existence of such. circumstances and an equal amount of make- up time partial physical custody or visitation shall be provided at the earliest mutually agreeable date and time. 8, The parties shall notify one another by telephone of any serious illness of the child. 9. In. the event of any serious illness of a child, each party shall have the right to visit the child as frequently as he or she desires, consistent with her proper medical care. 10. The term "illness", as used herein, shall mean. any disability which confines a child to bed under the direction of a licensed physician for a period in excess of forty-eight (48) hours. Page 3 of 6 03/23/2010 08:06 RECEIVED FROM: 5703871477 #0719-004 IRR-23-2010 09:00 From:KREISHER & GREGOROWI 5703871477 To:17179759993 P.5/7 U. If any period of partial custody has to be missed due to an illness of the child, Father will provide Mother with at least twenty-:four (24) hours notice of said illness, if possible, and Father will provide to Mother make-up time for said visit. Additionally, each party shall notify the other at the time of transfer of the child of any medication, either over the counter or prescription, that has been administered to the child in the preceding twenty-four (24) hours and shall also provide to the other party said medication if it is necessary that the child remain on said medication. 12. Each party shall. have two (2) non-consecutive weeks of uninterrupted custody during the sumnrner. The parties must provide at minimum a thirty (30) day written notice of intent to exercise summer visitation. The first party requesting said visitation shall have priority:. 13. The parties shall exert reasonable efforts to maintain free access and unhampered contact between the child and each of the parties and to promote a feeling of love and affection between the child and the other party. 14. The parties shall not harass, molest, or malign each other, or their respective families in the presence of their child. 15. Neither party shall engage in a pattern or course of conduct designed to interfere with the free and natural development of the child's love and respect for the other party. Page 4 of 6 03/23/2010 08:07 RECEIVED FROM: 5703871477 #0719-005 IRR-23-2610 09:00 From:KREISHER & GREGOROWI 5703871477 To:17179759993 P.6/7 16, Each party shall have reasonable access to minor child by telephone when in the custody and care of the other party. Such telephone communications shall not interfere with the custody of the parent who has custody at the time. 17. If either party intends to relocate from their present address, he or she shall provide the other party with a minimum of thirty (30) days advance written notice or relocation to permit modification of the terms and conditions of this Stipulation, if necessary. 18. Both parties shall keep the other party informed at al.l times of their respective addresses and telephone .numbers, 1.4. Neither party will abuse alcohol while caring for the minor child and each shall maintain a sake living environment for the child. 20, Each party shall maintain a journal containing a. listing of dates and times when the child is :in the partial physical custody of Mother. 21. The natural father hereby agrees to maintain health insurance coverage covering the minor child at all times during their minority and will furnish the natural. mother with evidence of that coverage and claim procedures so that she may obtain medical treatment and care for the child while in her custody, 22. The parties agree that this Stipulation shall be submitted to the Court and the terms of same shall be confirmed and the Stipulation shall have the same force and effect as an Order of Court and shall in fact become an Order, Page 5 of 6 03/23/2010 08:07 RECEIVED FROM: 5703871477 #0719-006 1AR-23-2010 09:00 From:KREISHER & GREGOROWI 5703871477 To:17179759993 P.7/7 W WITNESS WHEREOF, the .Parties hereto have set their hands and seals the day and year first written above. SWORN AND SUBSCRIBED TO $ RB ME T141S DAY OF 2010. Gabriel D. Mitchell OF PENNSYLVANIA Notary PWbli COMMONLi AL SEAL MICHAENCI, Nota ry Public L emoyne umberland County My Commpires June 15, 2010 SWORN AND SUBSC BEFORE MB THIS Z - AY OF Shaunda A. Jo 1175` 2010. -194INotary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MICHAEL R. CARANCI, Notary Public Lemoyne Boro. Cumberland County My Commission Expires June 15, 2010 Page b of 6 03/23/2010 08:07 RECEIVED FROM: 5703871477 #0719-007 RECEIVED MAR 2 ? 2011 GABRIEL D. MITCHELL, IN THE COURT OF COMMON PLEAS Plaintiff OF THE 9`i' JUDICIAL DISTRICT CUMBERLAND COUNTY, PA V. CIVIL ACTION -FAMILY SHAUNDA A. JOHNSON NO. 08-5515 Defendant CUSTODY CERTIFICATE OF SERVICE I, Brandy Hampton, hereby state that a true and correct copy of said Petition for Modification of Custody Order has been sent first class mail this day of March, 2010, to the following: Shaunda A. Johnson c/o Deirdra A. Feeney 1100 Glemsford Road Essex MD 21221 Respectfully submitted, Law Office Kreisher and Gregorowicz bokk 14 111 ?vl ) Brandy H ton Paral gal for Marianne K. ogelsanger, Esquire Attorney for Plaintiff 401 South Market Street Bloomsburg, PA 17815 (570) 784-5211 Attorney ID # 78106 SHAUNDA A. JOHNSON Defendant IN THE COURT OF COMMON PLEAS OF THE 9th JUDICIAL DISTRICT CUMBERLAND COUNTY, PA CIVIL ACTION -FAMILY NO. 08-5515 CUSTODY ORDER OF COURT AND NOW, to-wit, this 7 day of kk-J, 2010, upon consideration of the attached Custody Agreement regarding the minor child, Adrienne Rose Mitchell date of birth: September 2, 2008 signed by the parents, Gabriel D. Mitchell, Father and Shaunda A. Johnson, Mother, it is hereby approved and entered as an Order of Court. BY T COURT: J. C) 12 r„ IBS rn?t o = r A41', Lr J j O v o APR U d. 2010 GABRIEL D. MITCHELL, Plaintiff v. o.