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Home My WebLink About09-0016IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SARESA D. FOSTER, PLAINTIFF vs. RICHARD A. BARRICK, DEFENDANT CIVIL ACTION - AT LAW CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Mother, Saresa D. Foster, who currently resides at 1395 Louther Road, Camp Hill in Cumberland County, Pennsylvania 17011. 2. Defendant is Father, Richard A. Barrick, who currently resides at 180 Alters Road, Carlisle, in Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks confirmation of custody of the following child: NAME AGE SEX DATE OF BIRTH Cody M. Uglow-Barrick 6 years old Male May ~, 2002 4. During the past five years, the child has resided with the individuals and at the addresses herein indicated: FROM TO WITH WHOM ADDRESSES 05/2002 04/2004 Mom, Austin Uglow-Farabaugh 75 Bonnybrook, Carlisle, PA 04/2004 07/2004 Mom, Austin 324 West Penn, Carlisle, PA 07/2004 10/2004 Mom, Austin, Clarence &Kaylee Chestnut 324 W. Penn 10/2004 08/2006 08/2006 02/2007 Mom, Clarence &Kaylee Chestnut 324 W. Penn Mom C~~~ ~-~C' I~Y(~@. c~nd ~S~ ° h 324 W. Penn 02/2007 07/2007 Mom, Austin 324 W. Penn 07/2007 present Mom, Austin, Kevin Leggore 1395 Louther, Camp Hill, PA 5. Plaintiff has not participated in any other litigation concerning the child in this or any other state. 6. There are no other proceedings pending involving custody of the child in this or any other state. 7. Plaintiff knows of no person not a party to these proceedings who has physical custody of the child or who claims to have custody; partial custody or visitation rights with respect to the child. 8. The best interests of the child will be served if primary physical custody of him is confirmed in plaintiff, Mother. 9. Any sudden change in primary physical custody of the child is disruptive to their educational, social and developmental well-being. 10. The best interests and permanent welfare of the child require that open and meaningful access be maintained with each parent and that he have a relationship with each parent. 11. The child has developed emotional attachment to each parent and the severing of either attachment is not in the child's best interest. 12. Permitting each parent to remain involved in the life of the child enables the child to share with each parent the intimate contact necessary to strengthen a true parent-child relationship. WHEREFORE, plaintiff respectfully requests that, pursuant to Sections 3104(a)(2) and 3323(b) of the Divorce Code, the Court enter an order awarding shared legal custody of the child to the parties, primary physical custody of the child to Mother, and reasonable periods of partial physical custody and visitation to Father. 1 ~ Date Matthew ~`. Eshelman, Esquire, Pa. Id. 72655 Attorney for Plaintiff, Saresa D. Foster PO Box 1080, Camp Hill, PA 17001-1080 (717)249-6900 M.Eshelman@hotmail.com r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SARESA D. FOSTER, PLAINTIFF vs. RICHARD A. BARRICK, DEFENDANT No. CIVIL ACTION - AT LAW CUSTODY VERIFICATION TO COMPLAINT Plaintiff verifies that the statements made in this Complaint are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date Plaintiff, Saresa D. Foster 1'b ~ '~' t° ~) j ~- C - .rs J ^ ~, . { v ! 4 t r ~ 0 ~ ~ _ ~V `~ } ..~ ~/ y i {'. ' f"'~ ~; e ~ SARESA D. FOSTER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. . RICHARD A. BARRICK, CIVIL ACTION - LAW Defendant NO. 2009-0016 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 12th day of June, 2009, after hearing in the above-captioned matter, the Court finds that the best interest of the child will be served by the father being awarded primary physical custody in this case. The first exchange of custody under this order will take place at 7:00 p.m. on Sunday, June 14, 2009. The location of the exchange will be the intersection of Route 114 with Interstate 81. IT IS FURTHER ORDERED AND DIRECTED that the parties shall submit to the Court on or before June 26th, 2009, a proposed order regarding all proposed holidays, vacations, etc., for inclusion in the final permanent order. Mr. Leggore shall not be present for any transfers of custody of the child. By the Court, "` M. L. Ebert, Jr., / Matthew J. Eshelman, Esquire For the Plaintiff Paul B. Orr, Esquire For the Defendant :lfh CoP~ Es ~~~~, ~~~Z~a9 ~~ f l 1.~~ _i,,f C I ~~ i ~~ 2~fl9 ~~~l~~ l G f'~ t.,. Richard Barrkk IN THE COURT OF COMMON PLEAS Petitioner CUMBERLAND COUNTY, PENNSYLVANIA r. VS. NO: 2009-0016 CIVIL TERM 3 r -+ M? rn ? ` e-l O r Saresa D. Foster CIVIL ACTION - LAW -TI Respondent IN CUSTODY EMERGENCY PETITION FOR CONTEMPT OF CUSTODY COURT ORDER AND NOW, This 8 h day of August, 2011, Petitioner Richard Barrick, Pro Se, respectfully represents the following: 1. Petitioner is Richard Barrick, natural father of minor child, Cody Barrick with a date of birth of May 13, 2002. 2. Respondent, Saresa Foster, is the natural mother of the child referred to in paragraph one (1). 3. On June 12"', 2009, an Order of Court was issued by the Honorable Judge M. L. Ebert Jr., whereby it was ordered that the Petitioner would have Primary Physical Custody and Mother would have periods of Partial Physical Custody on alternating weekends from Friday at 5:30 pm to Sunday at 5:30 pm, of aforementioned minor child. This same Order of Court specified Summer Vacation, limited to the summer of 2009 only. (See copy of Order Attached) 4. With regards to the Summer Vacation, Respondent has requested one week summer vacation for the week of August 7 h through August 10, 20111 through U.S. Mail. Petitioner denied request for one week summer vacation due to sports obligations and no current Order of Court for summer vacations after year 2009. On August 7, 2011, Respondent sent Message via Cellular Phone to Petitioner informing Petitioner that Respondent will not be complaint with Current Order of Court and will not be returning, aforementioned minor child at the specific time and place set forth in Current Order of Court. On August 7, 2011 at 5:30 pm, Petitioner arrived at the specific Exchange of Custody destination and the Respondent did not arrive for Exchange of Custody. Lower Allen Township Police Department was immediately notified by Petitioner, in regards to the safety of the minor child, and Corporal Williams stated that Petitioner needs an Emergency Petition for Contempt of Custody Order to remove aforementioned minor child from the Respondent. WHEREFORE, Petitioner respectfully requests that this Honorable Court find the Respondent in Emergency Contempt of the previously issued Order and respectfully requests a court order which orders the immediate return of the minor child, Cody Barrick, from the Respondent and be rightfully returned to his Father per the previous issued Order. L ?7o,DG P c aaffi`k Respectfully Submitted, Richard Barrick, Pro Se 180 Alters Road Carlisle, Pa 17015 717-440-3757 VERIFICATION I verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S § 4904, relating to unsworn falsification to authorities. DATE: Richard Barrick, Plaintiff/Petitioner s ' NOV-25-2009 10:03AM FRO"aul 8. Orr Law Otticas 7172585289 I-194 P 0021004 F-982 SARESA D. FOSTER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA RICHARD A. BARRICK, CIVIL ACTION - LAW Defendant NO. 2009-0016 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 12th day of June, 2009, after hearing in the above-captioned matter, the Court finds that the best interest of the child will be served by the father being awarded primary physical custody in this case. The first exchange of custody under this order will take place at 7:00 p.m. on Sunday, June 14, 2009. The location of the exchange will be the intersection of Route 114 with Interstate 81. IT IS FURTHER ORDERED AND DIRECTED that the parties shall submit to the Court on or before June 26th, 2009, a proposed order regarding all proposed holidays, vacations, etc., for inclusion in the final permanent order. Mr. Leggore shall not be present for any transfers of custody of the child. By the Court, Matthew J. Eshelman, Esquire For the Plaintiff au1 B. Orr, Esquire the Defendant : lfh * M. L. Ebert, Jr., TRUE &%4~1%PY FROM RECORU in laNno w wWW, I hire wft sit my h" MW me at Cafte, P& '? a NOV-25-2009 10:03AM FROM-Paul S. Orr Law Office: 7IT2585289 T-194 P_003/004 F-982 • ?.L4Uz?VL?a JUL 0 0 2009 SARESA D. FOSTER, IN THE COURT OF COMMON PLFASYCJF'""-` `t5-----.--- Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No.: 2009-0016 RICHARD A. BARRICK, CIVIL ACTION - LAW - CUSTODY Defendant ORDER OF COURT AND NOW, this day of , 2009, upon review of the attac heed Defendant's Proposed Holiday Schedule, this Court Orders the following: MOTHER'S DAYWATHER'S DAY: Mother will always have the child on Mother's Day from 9:00 am until 7:00 pm and Father will always have the child on Father's Day from 9:00 am until 7:00 pm. 2. ALTERNATE HOLIDAYS: The parents shall share custody on alternate holidays throughout the year, the said holidays being New Years Day, Easter, Memorial Day, independence Day, Labor Day and Thanksgiving Day. Custody on these holidays shatI be exercrsed? from 9:00 am until 5:00 pm, commencing with Father exercising rights on Independence Day 2009 and Mother exercising rights on Labor Day 2009. 3. CHRISTMAS: in 2009 and all odd numbered years hereafter, Father shall have custody of the child from 3:00 pm on December 20 through 3:00 pm on December 25th and Mother shall have custody of the child from 3:00 pm on December 25th through 3:00 pm on December 26th. In 2010 and all even numbered years thereafter, Mother shall have custody of the child from 3:00 pm on December 24th through 3:00 pm December 2Vh and Father shall have custody of the child from 3:00 pm on December 25th through 3:00 pm on December 26th. ' 011.4. totj'ji r NOV-25-1009 10:03AM FROM-Paul B, Orr Lair Offices 4. St11YWER VACATIONS: 7172585289 T-194 P. 004/004 F-982 Mother shall have right to one (1) week of Starner 0 d en notice to Fair for Summer 2009- 5. SPECIAL EVENTS: The child is scheduled to attend Bible Camp from July 316t until August e, 2009. During this time, the child will remain in the custody of the Father in order for him to attend this event which he is both excited and looking forward to. 6. TRANSPORTATION: AN transportation shall be shared between the parties with the non-custodial parent and the custodial parent meeting at 1-81 and Route 114 pull off as has been previously acceptable to the parties. At NO time shall Kevin Leggors transport the child. Kevin Leggore shall no be present during custodial transfers. By the Gaut: Paul Bradford Orr, Esquire Attorney for Defendant Matthew J. Eshelman, Esquire Attorney for Plaintiff P-L . -E-b-, Judge iii. onM?ry RICHARD BARRICK, PLAINTIFF V. SARESA D. FOSTER, DEFENDANT IN THE COURT OF COMMON PLEAS Cm CUMBERLAND COUNTY, PENNSYLVAR NO. 09-0016 CIVIL ORDER OF COURT r.? c? 3710 e: E5 AND NOW, this 8th day of August, 2011, upon consideration of Richard Barrick's Pro Se Petition for Contempt of Court; IT IS HEREBY ORDERED AND DIRECTED that: 1. Mother, Saresa D. Foster, shall file an Answer to the Petition on or before August 19, 2011. 2. The Court Administrator shall schedule this matter to be heard before a custody conciliator. By the Court, Richard Barrick 180 Alters Road Carlisle, PA 17015 Saresa Foster 1395 Lowther Street Camp Hill, PA 17011 Court Administrator ?op Ma4d fqj bas IN THE COURT OF COMMON PLEAS RICHARD BARRICK PLAINTIFF M'. t PENNSYLVI CUMBERLAND COUNTY rw t 7n , -- V. 2009-16 CIVIL ACTION LAW SARESA D. FOSTER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, August 11, 2011 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, September 16, 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/ ac ueline M. Verne 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 Ode 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 F, 7e - 6orfArA --r _612-1!/ #/c 0 RICHARD BARRICK, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY,? =;W : PENNSYLVANIA -O = = --1 zrn c =::0 VS. NO. 2009-0016 CIVIL TERM c-) r -, ' <o SARESA D. FOSTER, : CIVIL ACTION - CUSTODY > ? ? Z Z=; DEFENDANT :3 C= o ' -r c? 2y DEFENDANT'S ANSWER TO PLAINTIFF'S EMERGENCY PETITION FOR CONTEMPT OF CUSTODY COURT ORDER AND NOW, comes the Defendant, SARESA D. FOSTER, by her counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and files this Answer to Plaintiff's Emergency Petition for Contempt of Custody Court Order and in support thereof asserts as follows: 1. Admitted. 2. Admitted. 3. Admitted in part and Denied in part, by way of further explanation, the Honorable Judge Ebert Jr. did issue an order on June 12th, 2009, but the summer vacation given to Defendant, was not limited to the year of 2009. 4. Admitted in part and Denied in part, by way of further explanation, Defendant did request a vacation in writing and Plaintiff did deny this vacation request, but, not due to sports obligations and the lack of a court order for vacation. 5. Admitted in part and Denied in part, by way of further explanation, Defendant did text Plaintiff telling Plaintiff she was taking the child on the vacation which she had requested in accordance with the current custody order. Defendant did not violate the custody order. 6. Defendant does not have any ability to know what the Plaintiff did or did not do. NEW MATTER 7. Paragraphs 1 through 6 of this Answer are incorporated herein by reference thereto. 8. In 2009, Defendant did not receive a copy of the custody order until her request for a vacation with her son would have only been twenty-nine (29) days prior to the start of her vacation, because of this lack of one (1) day Plaintiff refused to allow Defendant to have any vacation with her son in 2009. 9. In 2010, Defendant sent a request for a vacation with her son, more than thirty (30) days prior to her vacation via certified mail to the Plaintiff. Defendant was "allowed" by the Plaintiff to take a vacation with her son in 2010. 10. June 24, 2011, Defendant sent to Plaintiff a request for a vacation with her son August 7th through August 14th, 2011. Plaintiff received and signed for this notice via certified mail, June 27th, 2011. (Please see a copy of Defendant's request for a vacation and the certified mail receipt, attached hereto and made a part hereof at Exhibit "A"). 11. July 14, 2011, Defendant's work schedule changed so that she was not able to pick up her son at 5:30 p.m. as stated in the court order, she was not able to pick up her son until 7:00 p.m. Plaintiff refused to agree to change the Defendant's pick up time. Defendant then worked out an arrangement with her Mother to take care of her son until she is able to get home from work. This angered Plaintiff even more. Shortly after Defendant requested a time change for her work, Plaintiff texted Defendant her vacation was "denied". Plaintiff was very angry with Defendant because of this need for a time change, Plaintiff absolutely refuses to allow Defendant any deviation from the custody order. 12. August 21, 2011, it was the child's Great-Grandmother's birthday, she was 87. The entire family was attending a birthday for the child's Great-Grandmother, Plaintiff flatly refused to even consider allowing the child to attend the birthday party. This has happened on numerous occasions, Father refuses to allow the child and the Defendant even one minute of additional time for any reason. WHEREFORE, the Defendant, SARESA D. FOSTER, respectfully requests this Honorable Court to deny the Plaintiff, RICHARD BARRICK'S Emergency Petition for Contempt of Custody Court Order and to Review the current custody order. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: August 25, 2011 Susan Kay Candiel Attorney for the PA I.D. # 6499 4010 Glenfinn nl ,c Mechanicsburg PA 17055 (717) 724-2278 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of his knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. DATED: 1 vD. FOSTER EXHIBIT "A" rJ _ .J P . j. I/X ,d <o -3,414 64 IJ r :? /-Y- All r,, f1 ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can retum the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: I C"? C.t^E l per i' C . k" air h-5 0611 A. B. Received by (Printed Marne) . Date of Delivery r5H?. A0PW Z'a6C 6 ';).2 D. Is delivery address different from item 1? C] Yes If YES, enter delivery address below: EJ No 3. Service Type ? Certifled Mail ? B press Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail 13 C.O.D. 4. Restricted Delivery/? (Extra Fee) ? Yes 2. Article Number - (r aster from service fabef) 7 010 1670 0001 5124 2324 PS Form 3811, February 2004 Domestic Return Receipt 102595.024&1,' UNITED STATES POSTAL SERVICE first-Class Mail -Postage & Fees Paid ,f - USPS P..ennit.No. G-10 • Sender: Please print your name, address, and?IP+4 in this boz c I r1' 15-, &iLAA4AC1_ 3 . z1_ SARESA D. FOSTER, Plaintiff V. RICHARD A. BARRICK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-0016 : IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW C -V 3 MM m :r= ?r ?E AND NOW, this I I day of S f Jp tw tc " , 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: Father hereby withdraws his Petition for Contempt. h11 Z-' Coe) rri -a N) C7 2. The prior Orders of Court dated June 12, 2009 and July 9, 2009 are hereby vacated. 3. The Father, Richard A. Barrick and the Mother, Saresa D. Foster, shall have shared legal custody of Cody Barrick, born May 13, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding their 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 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 4. Father shall have primary physical custody of the child. Ff 7) 7 tz:) -TI 5. Mother shall have periods of partial physical custody as follows: A. Alternating weekends from Friday at 5:30 p.m. to Sunday at 6:30 p.m. B. Such other times as the parties agree. 6. HolidaysNacation: A. New Year's Day, Easter, Memorial Day, July 4th Labor Day, and Thanksgiving shall be alternated from 6:30 p.m. the evening before the holiday to 6:30 p.m. the day of the holiday. Father shall have physical custody of the child on New Year's Day, Memorial Day and Labor Day in even numbered years and physical custody of the child for Easter, July 4th and Thanksgiving in odd numbered years. Mother shall have physical custody of the child on New Year's Day, Memorial Day and Labor Day in odd numbered years and physical custody of the child on Easter, July 4th and Thanksgiving in even numbered years. B. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 3:00 p.m. to Christmas Day at 3:00 p.m. and Block B shall be from 3:00 p.m. on Christmas Day to December 26 at 3:00 p.m. Mother shall have physical custody of the child for Block A in even numbered years and Block B in odd numbered years. Father shall have physical custody of the child for Block A in odd numbered years and Block B in even numbered years. C. Each party shall have physical custody of the child for up to seven (7) consecutive days of vacation provided they give the other party thirty (30) days notice. Said vacation period shall not interrupt the child's scheduled extracurricular activities, such as sports practices, Bible camp and the like. D. Mother shall have physical custody of the child for Mother's Day from 9:00 a.m. to 7:00 p.m. Father shall have physical custody of the children for Father's Day from 9:00 a.m. to 7:00 p.m. 7. Transportation shall be shared such that the receiving party transport. At NO time shall Kevin Leggore transport the child. Kevin Leggore shall not be present during custodial transfers 8. The parties shall cooperate with therapeutic family counseling, the cost of which shall be shared by the parties. Counsel for the parties shall agree to the counselor. In the event that counsel cannot come to agreement, a telephone conference can be scheduled with the conciliator. 9. Mother shall have reasonable telephone contact with the child which shall be private. 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for November 15, 2011 at 2:30 p.m. BY THE COURT, M.L. Ebert, Jr., cc: Marlin L. Markley, Esquire, Counsel for Father pak Susan K. Candiello, Esquire, Counsel for Mother 00PO's qlgl'01(b SARESA D. FOSTER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-0016 CIVIL ACTION - LAW RICHARD A. BARRICK, Defendant : IN CUSTODY PRIOR JUDGE: M. L. Ebert, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Cody Barrick May 13, 2002 Father 2. A Conciliation Conference was held in this matter on September 16, 2011, with the following in attendance: The Father, Richard A. Barrick, with his counsel, Marlin L. Markley, Esquire, and the Mother, Saresa D. Foster, with her counsel, Susan K. Candiello, Esquire. 3. The Honorable M.L. Ebert, Jr. previously entered Orders of Court dated June 12, 2009 and July 9, 2009 providing for shared legal custody, Father having primary physical with Mother having alternating weekends and a holiday schedule. 4. Father filed for Contempt and Mother filed an Answer and New Matter. The parties agreed to an Order in the form as attached. Date: 'Paclqline M. Verney, Esquire Custody Conciliator Marlin L. Markley, Jr., Esquire l S? 2? AM 8: 31PR 3920 Market Street, Suite 303 20 Camp Hill, PA 17011 Attorney ID No. 84745 CUMBERLAW GOW 1 `` (717)635-9538-Telephone PENNS MANIA (717) 635-9578 -Facsimile Attorney for Defendant SARESA D. FOSTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2009 -16 CIVIL TERM V. RICHARD BARRICK, Defendant TO THE PROTHONOTARY: CIVIL ACTION -CUSTODY ENTRY OF APPEARANCE Kindly enter my appearance on behalf of the Defendant, Richard Barrick, in the above captioned matter. Respectfully submitted, Date: September 29, 2011 Marlin L. M ey, Jr., Esquire 3920 M t treet, Suite 303 Camp dA 17011 Attorney No.84745 (717) 635 9538 -Telephone (717) 635-9578 - Facsimile Attorney for Defendant RICHARD BARRICK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. NO.2009-16 CIVIL ACTION - LA SARESA D. FOSTER, CO CD r Defendant IN CUSTODY ORDER OF COURT AND NOW,this 17th day of July 17, 2013,being advised that the parties do not need the conciliation conference,the Conciliator hereby relinquishes jurisdiction i I n this matter. FOR THE COURT, )Zc—qj�re, Custody onciliator ne M. Verney,