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HomeMy WebLinkAbout09-1556 9 hn M. <err II 5020 FtRW Road SLae 108 Mechani[sbtag. PA 17o5s Allow 717.788.4008 FAx: 717.788.4088 SABRINA M. GRADY, Plaintiff V. JEFFREY LAMBERT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. D IS S?? cU." CIVIL ACTION - CHILD CUSTODY COMPLAINT IN CUSTODY 1. Plaintiff is Sabrina M. Grady, an adult individual residing at 22 Queen Avenue, Enola, Pennsylvania 17025. 2. Defendant is Jeffrey Lambert, an adult individual residing at 22 Palmer Drive, Camp Hill, Pennsylvania 17011. 3. The parties are the natural parents of the following minor child: Kayden L. Lambert, born June 26, 2005. 4. The child was born out of wedlock. 5. The child is presently in the custody of Plaintiff, who resides at 22 Queen Avenue, Enola, Pennsylvania 17025. 6. During the past five years, the child has resided with the following persons and at the following addresses: Names Addresses Dates Sabrina M. Grady 22 Queen Avenue 1/09 - Present Kayden L. Lambert Enola, PA 17025 Sabrina M. Grady 22 Queen Avenue 3/08 -1/09 Kayden L. Lambert Enola, PA 17025 Jeffrey Lambert Sabrina M. Grady 45 E. Crestwood Drive 7/07 - 3/08 Kayden L. Lambert Camp Hill, PA 17011 Sharon Grady Sabrina M. Grady 444 Meadow Drive 4/07 - 7/07 Kayden L. Lambert Camp Hill, PA 17011 Jeffrey Lambert Sabrina M. Grady 946 Limekiln Road 4/06 - 4/07 Kayden L. Lambert New Cumberland, PA 17070 Sabrina M. Grady 45 E. Crestwood Drive 6/05 - 4/06 Kayden L. Lambert Camp Hill, PA 17011 Sharon Grady Steve Grady Don Walters - Oms d hn M. err 5020 Rtl1G Road Strife 108 Med1 *;sbw9. PA 17055 PROM: 717.788.4008 FAx: 717.788.4088 7. The mother of the child is Plaintiff Sabrina M. Grady, residing with the child at 22 Queen Avenue, Enola, Pennsylvania 17025. She is not married. 8. The father of the child is Defendant, Jeffrey Lambert, who resides at 22 Palmer Drive, Camp Hill, Pennsylvania 17011. He is not married. 9. The relationship of the Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: Name Kayden L. Lambert Relationship Son 10. The relationship of the Defendant to the child is that of father. The Defendant currently resides with the following persons: Name Relationship Parents 11. 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. 12. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 13. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the child. r` 14. 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. 15. The best interest and permanent welfare of the children will be served by granting the relief requested because: Father has been abusive to his son and has little relationship with him, having been in and out of prison on drug and other charges. Mother has provided security and consistency to this child as the primary custodian since his birth. As visitation rights for Father should be only as supervised by an appropriate agency. WHEREFORE, Plaintiff requests that the Court grant to her primary physical and shared legal custody of the child, Kayden L. Lambert. Respectfully submitted, John M. Kerr, Esquire Attorney I. D. # 26414 Law Office of John M. Kerr, Esquire 5020 Ritter Road, Suite 109 Mechanicsburg, Pennsylvania 17055 (717) 766-4008 Attorney for Plaintiff, Sabrina M. Grady offi-I hn M. err 5020 Potter Road sldte 109 Medw4cstxug. PA 17055 Prior: 717.788.4008 FAx: 717.788.4088 Dated: March 12, 2009 VERIFICATION The undersigned, Sabrina Grady, hereby states that she is the Plaintiff in the foregoing Custody action and, as such, is authorized to execute this Verification, and that any factual statements contained in the preceding Complaint in Custody are true to the best of her knowledge, information and belief. She understands that any false statements are subject to the penalties prescribed at 18 Pa.C.S.§4904, relating to unsworn falsification to authorities. na C OY ? ?-' \n < SABRINA M. GRADY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-1556 CIVIL ACTION LAW JEFFREY LAMBERT CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, March 17, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, April 14, 2009 at 3:30 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 hearing. FOR THE COURT, By: /s/ Dawn S. Sunday, Esq. 40_1 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 Jam1 A QWP' 61 Nbd 6Q? r4 t r 4 .,[! ZU -il ', ? 4010/. r r• i SABRINA M. GRADY Plaintiff V. JEFFREY LAMBERT Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-1556 CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance as attorney in the above-captioned action for the Defendant, Jeffrey Lambert, per his request. submitted, Date: _'2009 a R. Mehbftie carmgi & Scaringi, P.C. Attorney ID #90951 2000 Linglestown Road, Suite 103 Harrisburg, Pennsylvania 17110 (717) 657-7770 (O) (717)-657-7797 (F) debragscaringilaw.com r. SABRINA M. GRADY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 09-1556-CIVIL TERM JEFFREY LAMBERT, : CIVIL ACTION - LAW Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Amanda L. Emerson, Paralegal, do hereby certify that on this, the I01h day of April, 2009, I served a true and correct copy of the foregoing Praecipe to Enter Appearance upon the following individual(s) by way of First Class Mail, Postage Prepaid: John M. Kerr, Esquire Law Office of John M. Kerr, Esquire 5020 Ritter Road, Suite 109 Mechanicsburg, PA 17055 Dawn S. Sunday, Esquire - Custody Conciliator 39 West Main Street Mechanicsburg, PA 17055 ° jp v? r Dat Amanda L. Emerson, Paralegal PILED- -ri?: i`i"r- OF THE PRA H bTARY 2009 APR 14 PM 1: 06 APR 2,d 2009, SABRINA GRADY Plaintiff vs. JEFFREY LAMBERT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 09-1556 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this zg day of h I , 2009, upon consideration of the attached Custody Conciliation Repo , it is ordered and directed as follows: 1. The Mother, Sabrina Grady, and the Father, Jeffrey Lambert, shall have shared legal custody of Kayden L. Lambert, born June 26, 2005. Major decisions concerning the Child including, but not necessarily limited to, his health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 2. Pending the follow-up custody conciliation conference scheduled in this Order and further agreement of the parties or Order of Court, the parties shall have physical custody of the Child in accordance with the following schedule: A. The Mother shall have primary physical custody of the Child. B. The Father shall have partial physical custody every week on Wednesdays from 4:30 p.m. until 8:30 p.m. and on Sundays from 11:00 a.m. until 5:00 p.m. C. The Father shall provide transportation for exchanges of custody on Wednesdays and he shall pick up the Child at school/daycare. D. The Mother shall ensure that the Father is placed on the authorized pickup list at the Child's daycare. The Mother shall provide transportation for all exchanges of custody on Sundays. } i t 1 t? ?J J i+ ?, ?? BZ ??? (?00Z 9 r 7 ;Ol 3. The parties shall share or alternate having custody of the Child on holidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall run from Christmas Day at 12:00 noon through December 26, at 12:00 noon. In odd-numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. In even-numbered years, the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. B. Thanksgiving: In every year, the Father shall have custody of the Child on Thanksgiving from 11:00 a.m. until 4:00 p.m. and the Mother shall have custody from 4:00 p.m. until bedtime on Thanksgiving Day. C. Easter: The parent who has custody of the Child under the regular custody schedule on Easter morning shall have custody of the Child until 3:00 p.m. and the other parent shall have custody on Easter from 3:00 p.m. until 8:00 p.m. D. Memorial Day/Labor DU: In every year, the Father shall have custody of the Child on Memorial Day and the Mother shall have custody of the Child on Labor Day from 11:00 a.m. until 7:00 p.m. or at such other times as arranged by agreement. E. July Fourth: Each parent shall have the opportunity to have custody of the Child for the Independence Day fireworks each year with the specific days and times to be arranged by agreement. F. Halloween Trick or Treat; Each parent shall have the opportunity to take the Child to Trick or Treat night in his or her community each year. In the event the Trick or Treat night falls on the same evening in both communities, the parties shall alternate taking the Child Trick or Treating in another community each year. G. Mother's Dgy/Father's Dav: In every year, the Father shall have custody of the Child for Father's Day from 11:00 a.m. until 8:00 p.m. and the Mother shall have custody of the Child for Mother's Day. In the event Mother's Day falls on the Father's weekend day of custody under the regular schedule, the Father shall instead have custody of the Child that weekend on Saturday from 11:00 a.m. until 5:00 p.m. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 1. In the event a party's holiday period of custody falls immediately before or following a regular period of custody, the holiday/regular periods of custody shall run continuously without interruption. 4. The parties shall conduct all exchanges of custody in a civil and cooperative manner in order to promote the emotional well-being of the Child. 5. The parties shall make arrangements for the Child to participate in counseling/play therapy with a professional to be selected by agreement. The purpose of the counseling shall be to assess and promote the Child's emotional well-being throughout implementation and anticipated expansion of the partial custody schedule and to provide guidance to the parties relating to the well-being of the Child. The parties shall share any costs of counseling which are not covered by insurance. The Father agrees to pay any costs of the counseling which exceed the Mother's ability to pay her full one-half share. 6. Civil and non-threatening contact between the parties for the purpose of exchanging custody of the Child or communicating with respect to Child related issues shall not be deemed to constitute a violation of the Protection from Abuse Order entered by this Court on March 18, 2009. 7. The parties and counsel shall attend a follow-up custody conciliation conference in the office of the conciliator, Dawn S. Sunday, on Wednesday, July 22, 2009 at 10:30 a.m. for the purpose of reviewing the custodial arrangements. 8. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 9. 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. BY THE COURT, cc: 7ebra M. Kerr, Esquire - Counsel for Mother R. Mehaffie, Esquire - Counsel for Fathe q SABRINA GRADY Plaintiff VS. JEFFREY LAMBERT Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 09-1556 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kayden L. Lambert June 26, 2005 Mother 2. A custody conciliation conference was held on April 20, 2009, with the following individuals in attendance: the Mother, Sabrina Grady, with her counsel, John M. Kerr, Esquire, and the Father, Jeffrey Lambert, with his counsel, Debra R. Mehaffie, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ____? ? . ova q Date Dawn S. Sunday, Esquire Custody Conciliator ! • SABRINAYi. GRADY Plaintiff V. JEFFREY Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-1556 CIVIL ACTION - LAW IN CUSTODY PETITION FOR LEAVE TO WITHDRAW AS COUNSEL i NOW comes the Petitioner, Debra R. Mehaffie, Esquire and Scaringi & Scaringi, P.C., who respectfully petitions the Court for leave to withdraw as counsel and in support thereof avers as . Petitioner has informed Mr. Lambert of the rescheduled custody conciliation for 1. The undersigned Petitioner previously entered her appearance as counsel for Defendant Jeffrey Lambert, at his request, and represented him at one (1) custody j conciliation. 2 Petitioner requests permission to withdraw as counsel for Mr. Lambert in the above- captioned action because he has advised the undersigned counsel that he no longer wishes Petitioner to represent him in the above-captioned matter. 3 A custody conference, which was originally scheduled for July 2, 2009 at 10:30 a.m., has been rescheduled for June 11, 2009 at 12:00 p.m. before Dawn Sunday, Esquire. June 11, 2009 and Mr. Lambert has confirmed that he does not wish for Petitioner to represent him at said conference. Additionally, Petitioner has informed plaintiff's counsel that she no longer represents Mr. Lambert. 6. ! Accordingly, the undersigned counsel cannot continue to represent Jeffrey Lambert in accordance with the Rules of Professional Conduct. the undersigned counsel respectfully requests that this Honorable Court order{ and decree the appearance of Debra R. Mehaffie, Esquire, counsel for Jeffrey Lambert is,withdrawn effective immediately. submitted, Date ?,J l/1 U1 r / / t 7ebra R. Mehaffie, Esq e e Court ID#909 1 gi & Scaringi, P.C. inglestown Rd., Suite 106 Harrisburg, PA 17110 717-657-7770 i debra@scaringilaw.com r SABRINA 1'???I. GRADY Plaintiff JEFFREY V. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-1556 CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I, A foregoing P served via I Date: anda L. Emerson, paralegal for Scaringi & Scaringi, P.C., do hereby certify that the tition for Leave to Withdraw as Counsel in the above-captioned action has been duly nited States First Class mail as follows: Jeffrey Lambert 22 Palmer Drive Camp 1E11, Pa 17011 John M. Kerr, Esquire, Law Office of John M. Kerr 5020 Ritter Road, Suite 109 Mechanicsburg, Pa 17055 Dawn S. Sunday, Esquire 39 West Main Street Mechanicsburg, PA 17055 2009 / Amanda L. Emerson, Paralegal Fel - OF THI- 2099 JUG -1 pM " C', SABRINA M. GRADY Plaintiff V. JEFFREY LAMBERT Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-1556 CIVIL ACTION - LAW IN CUSTODY AMENDED PETITION FOR LEAVE TO WITHDRAW AS COUNSEL AND NOW comes the Petitioner, Debra R. Mehaffie, Esquire and Scaringi & Scaringi, P.C., who respectfully files this Amended Petition for Leave to Withdraw as Counsel and in support thereof avers as follows: 1. Petitioner incorporates by reference the averments made in her Petition for Leave to Withdraw as Counsel that was previously filed with this Honorable Court, as though set forth in full. 2. The custody order was entered on April 24, 2009 by the Honorable Kevin A. Hess. A Protection from Abuse Order was also entered by the Honorable Kevin A. Hess on March 18, 2009 to docket number 2009-1486. Beyond these orders, a judge has not ruled upon any other issue in the custody case. Petitioner does not know if a judge has ruled upon any other related matter. 3. In addition to previously contacting plaintiff's counsel to inform that defendant no longer desires Petitioner to represent him, Petitioner contacted plaintiffs counsel John M. Kerr, Esquire on June 3, 2009 to seek concurrence to Petitioner's withdraw and Attorney Kerr stated that he concurs. WHEREFORE, the undersigned counsel respectfully requests that this Honorable Court order and decree the appearance of Debra R. Mehaffie, Esquire, counsel for Jeffrey Lambert is withdrawn effective immediately. Date V submitted, R. Mclhaffie, Esquire ne Court ID#90951 ;i & Scaringi, P.C. 2000 Linglestown Rd., Suite 106 Harrisburg, PA 17110 717-657-7770 debra(a-)scaringilaw. com SABRINA M. GRADY IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-1556 JEFFREY LAMBERT CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Amanda L. Emerson, paralegal for Scaringi & Scaringi, P.C., do hereby certify that the foregoing Amended Petition for Leave to Withdraw as Counsel in the above-captioned action has been duly served via United States First Class mail as follows: Jeffrey Lambert 22 Palmer Drive Camp Hill, Pa 17011 John M. Kerr, Esquire, Law Office of John M. Kerr 5020 Ritter Road, Suite 109 Mechanicsburg, Pa 17055 Dawn S. Sunday, Esquire 39 West Main Street Mechanicsburg, PA 17055 2009 4anda L. Emerson, Paralegal FILED OF THE P- ? f r?Y 2099 JUN 12 Ah 11 8 i y SABRINA M. GRADY IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-1556 JEFFREY LAMBERT CIVIL ACTION - LAW Defendant IN CUSTODY RULE TO SHOW CAUSE AND NOW THIS Ad-* day of June, 2009, upon consideration of the foregoing Petition for Leave to Withdraw as Counsel, it is hereby ORDERED that a RULE is issued upon Plaintiff and Defendant to show cause why the relief requested should not be granted. Rule returnable within So days of service. DATE Distribution: Debra R. Mehaffie, Esquire, 2000 Linglestown Road, Suite 106, Harrisburg, PA 17110; Phone 717- 657-7770; Fax 717-657-7797; email debra scaringilaw.com John M. Kerr, Esquire, Law Office of John M. Ken, 5020 Ritter Road, Suite 109, Mechanicsburg, Pa 17055 ,,Al'a-wn S. Sunday, Esquire, 39 West Main Street, Mechanicsburg, PA 17055 1 ES' `' i l£cl. `"/ BY THE COURT: OF T( RLED-U?=HCJE L 4, / h1Pi 2009 JUN 16 PM 12: 3 7 pp PEN;, JUN 15 2009 SABRINA GRADY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 09-1556 CIVIL ACTION LAW JEFFREY LAMBERT Defendant IN CUSTODY ORDER OF COURT AND NOW, this /7' day of 41-ns= , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated April 28, 2009 shall continue in effect as modified by this Order. 2. The Father's periods of custody with the Child shall be based at the paternal grandparents' residence with the grandparents present. This provision is not intended to prohibit the Father from taking the Child outside of the grandparents' residence to engage in activities, go to restaurants or parks or to enjoy other outings. 3. In the event the parties make arrangements by mutual agreement for the Father to have an overnight period of custody with the Child, the overnight period of custody shall take place at the paternal grandparents' residence. 4. 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. BY THE COURT, Hess J. cc: ? J hn M. Kerr, Esquire - Counsel for Mother Jeffrey Lambert - Father eon Es ,fit l.cL ? /rZ?vq SABRINA GRADY Plaintiff VS. JEFFREY LAMBERT Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 09-1556 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kayden L. Lambert June 26, 2005 Mother 2. A custody conciliation conference was held on June 11, 2009, with the following individuals in attendance: the Mother, Sabrina Grady, with her counsel, John M. Kerr, Esquire. The Father, Jeffrey Lambert, who is no longer represented by counsel in this matter, did not appear for the conference. The Father had contacted the conciliator's office in the process of rescheduling the follow-up conference. 3. At the conciliation conference the Mother indicated that she had spoken with the Father about the issues to be addressed at the conference and the Father indicated that he was not going to attend and that she should notify him afterward as to the result. The Mother stated that she had asked the Father to have the Child overnight following one of his evening periods of custody as she had to work the second shift. The Mother expressed concern that she was then unable to contact the Father during this overnight period, which was the first for the Child with the Father. The Mother waited at the paternal grandparents' home, where the Father resides, from 6:00 a.m. until 6:45 a.m. on the morning following the overnight to ensure that the Child would get to school. However, the Father had not stayed overnight with the Child at the paternal grandparents and would not disclose where the Child had been. The Mother requested that the Order specifically provide for the Father's periods of custody to be exercised at the paternal grandparents' residence as was the understanding at the prior conciliation conference. The Mother indicated that the Father would like to have every Wednesday overnight. The Mother stated that she advised the Father that she would be willing to address that issue as well at the conciliation conference. 4. Although the Father did not appear for the conference, the Mother indicated that she was willing to consider the possibility of overnight periods of custody for the Child with the Father as arranged by mutual agreement. The Mother further clarified her request that the paternal grandparents be present during the Father's periods of custody when he is not actively engaged in activities outside the home with the Child. 5. Based upon the representations of the Mother and her counsel at the conference and the fact that the Father did not attend the conference, the conciliator recommends an Order in the form as attached. 1 Date T Dawn S. Sunday, Esquire Custody Conciliator OF THE 2009 JUN 17 A 10., 22 SABRINA M. GRADY IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-1556 JEFFREY LAMBERT CIVIL ACTION - LAW Defendant IN CUSTODY MOTION TO MAKE RULE ABSOLUTE AND NOW COMES, Scaringi & Scaringi, P.C. and Debra R. Mehaffie, Esquire who files the following Motion for Rule Absolute: 1. On May 29, 2009, Scaringi & Scaringi filed a Petition to Withdraw as Counsel for Defendant Jeffrey Lambert in this matter. 2. On June 12, 2009, Scaringi & Scaringi filed an Amended Petition to Withdraw as Counsel for Defendant Jeffrey Lambert to bring the original Petition into compliance with the local rule. 3. On or about June 16, 2009, the Honorable Kevin A. Hess issued a Rule to Show Cause upon both parties to show cause why the Petition to Withdraw as Counsel should not be granted. The Rule was returnable 20 days from service. (A copy of the Order is attached hereto as Exhibit "A" and incorporated herein by reference). 4. The Order was served upon Counsel for Plaintiff and Defendant, individually, at his last known address. Counsel for Plaintiff did not oppose Scaringi & Scaringi's request to withdraw as counsel. 5. Mr. Lambert's response to the Petition was due on July 7, 2009. 6. Mr. Lambert has failed to file a response to the Court's Order to Show Cause. WHEREFORE, Scaringi & Scaringi and Debra R. Mehaffie, Esquire, respectfully request that this Court issue an Order authorizing Scaringi & Scaringi and Debra R. Mehaffie, Esquire to withdraw as counsel for Defendant Jeffrey Lambert in the Date -71-1 matter. submitted, Debra R! Mehaffie, Es e Supreme Court ID#90 1 Scaringi & Scaringi, P.C. 2000 Linglestown Rd., Suite 106 Harrisburg, PA 17110 717-657-7770 debra()scaringilaw. com Exhibit "A" SABRINA M. GRADY IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-1556 JEFFREY LAMBERT CIVIL ACTION - LAW Defendant IN CUSTODY RULE TO SHQW CAUSE AND NOW THIS 16~day of June, 2009, upon consideration of the foregoing Petition for Leave to Withdraw as Counsel, it is hereby ORDERED that a RULE is issued upon Plaintiff and Defendant to show cause why the relief requested should not be granted. Rule returnable within -L o days of service. DATE Distribution: Debra R. Mehaffie, Esquire, 2000 Linglestown Road, Suite 106, Harrisburg, PA 17110; Phone 717- 657-7770; Fax 717-657-7797; email debranaLscarin 'law.com John M. Ken, Esquire, Law Office of John M. Kerr, 5020 Ritter Road, Suite 109, Mechanicsburg, Pa 17055 ,.-Va'wn S. Sunday, Esquire, 39 West Main Street, Mechanicsburg, PA 17055 - 14"Ct I IES #-r-.t r e ``6? BY THE COURT: SABRINA M. GRADY IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-1556 JEFFREY LAMBERT CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Amanda L. Emerson, paralegal for Scaringi & Scaringi, P.C., do hereby certify that the foregoing Motion to Make Rule Absolute in the above-captioned action has been duly served via United States First Class mail as follows: John M. Kerr, Esquire, Law Office of John M. Kerr 5020 Ritter Road, Suite 109 Mechanicsburg, Pa 17055 Dawn S. Sunday, Esquire 39 West Main Street Mechanicsburg, PA 17055 Jeffrey Lambert 22 Palmer Drive Camp Hill, Pa 17011 Date: lti C , 2009 ?ucuiua i... 1i111G1JV11, rtllZLiG?'Al CF T{- F n i , rAgr y D JUL 1 3 2009 G SABRINA M. GRADY IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-1556 JEFFREY LAMBERT CIVIL ACTION - LAW Defendant IN CUSTODY RULE ABSOLUTE AND NOW THIS y ` day of 2009, upon consideration of the Petition to Withdraw as Counsel, Rule to Show Cause and Motion to Make Rule Absolute filed on behalf of Scaringi & Scaringi, P.C. and Debra R. Mehaffie, it is hereby ORDERED that said Petition is GRANTED. Scaringi & Scaringi, P.C. and Debra R. Mehaffie, Esquire, are withdrawn as counsel for Defendant Jeffrey Lambert in this matter. BY THE COURT: J. Distribution: ? Debra R. Mehaffie, Esquire, 2000 Linglestown Road, Suite 106, Harrisburg, Pa 17110 ." John M. Kerr, Esquire, 5020 Ritter Road, Suite 109, Mechanicsburg, Pa 17055 ,'- Dawn S. Sunday, Esquire, 39 West Main Street, Mechanicsburg, PA 17055 l/ Jeffrey Lambert, 22 Palmer Drive, Camp Hill, Pa 17011 O-O ('ES ?Yld l L5CL FILrt 2009 Ju' ! 4 P,' 1'? 5 ~• . .~. Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 Attorney for Plaintiff JEFFREY LAMBERT Plaintiff v. SABRINA GRADY Defendant. ~j4 - Z~ i ~ ~~ ~.~ ~~ M~ = ~6 ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. prj - l ~~~o c ~v ~`~ CIVII, ACTION -LAW CUSTODY PETTI'ION FOR MODIFICATION OF CUSTODY AND NOW, comes Plaintiff, Jeffrey Lambert, by and through his counsel, Cindy L. Hribal, Esq., of Carrucoli & Associates, P.C., and avers the following in support of his Petition: 1. Jeffrey Lambert, hereinafter "Father," resides at 2514 Market Street, Apartment 2, Camp Hill, Pennsylvania. 2. Sabrina Grady, hereinafter "Mother," resides at 62 North 10`h Street, Apartment B, Lemoyne, Pennsylvania. 3. The parties are the parents of Kayden Lambert, born June 26, 2005. 4. On Apri128, 2009, an Order of Court was entered, which stipulated that the parties share legal custody with the Mother having primary physical custody. 5. Father requests full primary physical custody. ~ 70. oo P~ any ck ~ I ~l ~ >e~ ~-y6 ~ sd ., Carrucoli & Associates, P.C. 875 Mazket Street Suite 200 Lemoyne, PA 17043 Attorney for Plaintiff WHEREFORE, Father requests this Honorable Court to award him primary physical custody of the minor child. Respectfully submitted, Date: ~ 5 ID 202325 Carrucoli & Associates, P.C. PA Supreme Court ID 202325 875 Market Street Lemoyne, PA 17043 Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 Attorney for Plaintiff JEFFREY LAMBERT Plaintiff v. SABRINA GRADY Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAl~TIA No. CIVII., ACTION -LAW CUSTODY VERIFICATION I, Jeffrey Lambert, verify that the statements made in this Petition to Modify Custody are true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: ~jr `j~ I ~- JE LAMBERT Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 Attorney for Plaintiff JEFFREY LAMBERT Plaintiff v. SABRINA GRADY Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION -LAW CUSTODY CERTIFICATE OF SERVICE I, Cindy L. Hribal, Esq., hereby certify that a true and correct copy of the Petition to Modify Custody was served this date on the below named, by placing same in the United States mail, certified, postage prepaid thereon, addressed as follows: Sabrina Grady 62 North 10~' Street Apartment B Lemoyne, PA 17043 Date: g ' y . Hn ,Esq. Or JEFFREY LAMBERT PLAINTIFF V. SABRINA GRADY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-1556 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, August 20, 2010 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on , Monday, September 20, 2010 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ Dawn S. Sunda 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. A11 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. 0 umberland County Bar Association g o2?J'? 8? (? GZ le? 32 South Bedford Street Carlisle Pennsylvania 17013 "t'C7 ? Co?z-rc??0 0 Telephone (717) 249-3166 W $ • ?3- (0 COP MoGteal 46 S"j r W U SEP l Lu I u r? SABRINA GRADY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 'VS. 2009-1556 CIVIL ACTION LAW • ?, C3 -n JEFFREY LAMBERT _ Defendant IN CUSTODY "' ern CD _ ORDER OF COURT AND NOW, this 7-8 ` day of .yA?? 20 10, upon consideration of the attached Custody Conciliation Report, if is ordered and directed as follows: 1. The prior Order of this Court dated April 28, 2009 shall continue in effect as modified by this Order. 2. The parties shall have physical custody of the Child in accordance with the following schedule: A. During alternating weeks, the Father shall have custody of the Child from Friday after school through Tuesday morning before day care and from Wednesday after school through Thursday morning before day care. During the interim weeks, the Father shall have custody from Monday after school through Tuesday morning before day care and Wednesday after school through Thursday morning before day care. B. The Mother shall have custody at all times not otherwise specified for the Father in this provision. C. The Father shall pick up the Child directly from school at the beginning of his periods of custody and the Father may make arrangements for his girlfriend to transport the Child to the Mother's residence before day care at the end of the Father's periods of custody so that the Mother can take the Child to day care. If the Father is personally able to provide transportation in the morning, the Father shall take the Child directly to day care. D. The foregoing custody schedule shall begin with the Father having custody of the Child on Friday, September 24, 2010 for his alternating weekend. 3. The parties and counsel shall attend a follow-up custody conciliation conference in the office of the conciliator, Dawn S. Sunday, on Thursday, November 18, 2010 at 10:30 a.m. for the purpose of reviewing the custodial arrangements following experience with the current custody schedule to further address the Father's request for equally shared custody. 4. 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. BY THE COURT, Kevin A. ess J. cc: '?Cy L. Hribal, Esquire - Counsel for Father Sabrina Grady - Mother cD 1'Es ,-no t lq?C a ?v qua ? V 61 SEf 2 / 2010 SABRINA GRADY vs. JEFFREY LAMBERT Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-1556 CIVIL ACTION LAW IN CUSTODY Prior Judge: Kevin A. Hess CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kayden Lambert June 26, 2005 Mother 2. A custody conciliation conference was held on September 20, 2010, with the following individuals in attendance: the Father, Jeffrey Lambert, with his counsel, Cindy L. Hribal, Esquire, and the Mother, Sabrina Grady, who is not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. 'Q4"&A '=X31 -aa l o Date Dawn S. Sunday, Esquir Custody Conciliator I NOV 19 201U SABRINA GRADY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2009-1556 CIVIL ACTION LAW JEFFREY LAMBERT c-) ,.,, o Defendant IN CUSTODY -? a --j x rrl r - ?. v i rn c.n ORDER OF COURT ° o wo XF3 c w -C) AND NOW, this e ' day of /1OV4, 10 2ib10 ,;?tpon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court dated April 28, 2009 and September, 2010 are vacated and replaced with this Order. 2. The Mother, Sabrina Grady, and the Father, Jeffrey Lambert, shall have shared legal custody of Kayden Lambert, born June 26, 2005. Major decisions concerning the Child including, but not necessarily limited to, his health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 3. The parties shall have physical custody of the Child in accordance with the following schedule: A. The Father shall have custody of the Child on alternating weekends from Friday after school through Sunday at 7:00 p.m. and every week on Monday after school through Tuesday morning at 9:00 a.m. and from Wednesday after school through Thursday morning at 9:00 a.m. B. The Mother shall have custody at all times not otherwise specified for the Father in this provision. C. The Father shall pick up the Child directly from school at the beginning of his periods of custody and the Father may make arrangements for his girlfriend to transport the Child to the Mother's residence in the morning at the end of the Father's periods of custody. 4. The parties shall share having custody of the Child on holidays as arranged by agreement. 5. Each party shall be entitled to have vacation periods of custody with the Child with the specific dates and times to be arranged by agreement. 6. 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. BY THE COURT, Kevin A/Hess J. cc: Aa na Grady - Mother effrey Lambert - Father ?pleb' m7t14d? I th C? ho SABRINA GRADY vs. JEFFREY LAMBERT Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-1556 CIVIL ACTION LAW IN CUSTODY Prior Judge: Kevin A. Hess CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kayden Lambert June 26, 2005 Mother/Father 2. A custody conciliation conference was held on November 18, 2010, with the following individuals in attendance: the Mother, Sabrina Grady, and the Father, Jeffrey Lambert. Neither party is currently represented by counsel. 3. The parties agreed to entry of an Order in the form as attached. A n4:n ? L E, o/ o Date -? Dawn S. Sunday, Esquire Custody Conciliator COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW SABRINA M. GRADY, Plaintiff CD V. No.2009-1556 Z; rnco C- C- M Mr- = JEFFREY L. LAMBERT 0 , Defendant Petition for Modification 7, I. Petitioner is Plaintiff,SABRINA M. GRADY,who currently resides at 62 N. I OTh Street,Apt B,Lemoyne,Cumberland County,PA 17043. 2. Respondent is Defendant,JEFFREY L. LAMBERT, who currently resides at 22 Palmer Drive, Camp Hill, Cumberland County,PA 17011. 3. Petitioner and Respondent are the natural parents of the following child: Name Age KAYDEN L. LAMBERT 7 years 4. A custody order was entered on August 20, 20 10, in the Cumberland County Court of Common Pleas. A copy of the custody order is attached. 5. Petitioner seeks to modify the custody order because: My work schedule and I believe two days in a row instead of going back and forth during the week is in the best interest of our son. Bringing Kayden home earlier on Sunday's allows Kayden more time to adjust to being back home before starting the school week. 6. Petitioner believes the custody order should be changed as follows: With his father Tuesday and Wednesday nights-picked up directly from school or at 3:30 pin during summer hours. He is to be dropped off directly at school following Jeffrey's week day visits instead of bringing him home in the morning. And we should split every other weekend with Jeffrey bringing him home at 4pm instead of 7pm,allowing Kayden more time to adjust to being back home and giving him time to prepare for school the next day. . 's 43 -oo v/ �*v Petition for Modification Page 3 of 5 WHEREFORE, Petitioner respectfully requests that this Court modify the Order as requested. Date: �0 -- SABRINA M. GRAD aintiff Verification I, SABRINA M. GRADY,Plaintiff,verify that the facts stated in the foregoing Petition are true and correct to the best of my knowledge,information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. '4904 relating to unsworn falsification to authorities. Date:—L I � ��� 3 SABRINA M. GRAD , laintiff Petition for Modification Page 4 of 5 V COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION �3 rte : SABRINA M. GRADY, ) ,� Plaintiff V. ) No. 2009-1556rn `M ' JEFFREY L. LAMBERT, Defendant ) ° ca a c3 Certificate Of Service ' 1, SABRINA M. GRADY,Plaintiff in the above matter,hereby certify that on u�Q.. 3—03 ,I mailed a true and correct copy of the Petition for Modification, by certified mail,return receipt requested,restricted delivery, and another copy of the same document by first class mail,postage prepaid,to: JEFFREY L. LAMBERT 22 Palmer Drive Camp Hill, PA 17011 I certify that(check ALL of the following which are true): Certified mail: [X] The green and white sender's receipt is attached. (ATTACH receipt.) [ ] The green recipient's receipt is attached; JEFFREY L. LAMBERT signed the certified mail receipt on (ATTACH receipt.) [ ] The certified mail was returned to me unsigned,with the notation that the certified mail was: [ ] refused [ ] unclaimed [ ] other notation: [ ] Neither the certified mail envelope nor the certified mail receipt was returned to me. Regular mail: [ ] The regular mail has not been returned to me. [ j The regular mail was returned to me,with the notation: Certificate of Service Page 1 of 3 I verify that the information in the Certificate of Service is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904,relating to unsworn falsification to authorities. Date: c - (Signature)SAB M. GRADY STAPLE OR TAPE THE CERTIFIED MAIL RECEIPTS BELOW: CERTIFIED U.S. Postal ServiceTM RECEIPTi only; I ru C0 nagwmlnq�' C3 TT 46 t)i�t} I3 Postage $ cc ru Certified Fee C3 Return Receipt Fee ;�,? ?�I I e O C3 (Endorsement Required) Restricted Delivery Feet "iltl (Endorsement Required) f C3 E� ; rq ,2 C3 Total Postage&Fees $ r� Sent To ru ,'-q ------------•-•---------------- Street,Apt.No.; C3 or PO Box No. r - ZI--P-•--+4------------------------ -PS Form City,State, :00 August 2006 See Reverse for Instructions GREEN RECEIPT WITH JEFFREY L.LAMBERT'S SIGNATURE Certificate of Service Page 2 of 3 SABRINA M. GRADY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA • V. ern c-- ,-:,^' 2009-1556 CIVIL ACTION LAW fir,; • JEFFREY L. LAMBERT -t ,}, IN CUSTODY a DEFENDANT -L o :T) ORDER OF COURT AND NOW, Thursday,June 27,2013 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday,Esq. , the conciliator, at 39 West Main Street,Mechanicsburg,PA 17055 on Monday,July 22,2013 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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! Dawn S. Sunday,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 9 Telephone (717)249-3166 bec t- asne 007/0 r P tor X21 /3 SABRINA M. GRADY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2009-1556 CIVIL ACTION LAW JEFFREY L. LAMBERT Defendant IN CUSTODY C-0 CD cz, J ORDER OF COURT QD <zT' AND NOW, this lo Q 3 day of a�h ,:-4o'n:" consideration of the attached Custody Conciliation Report, it is ordered and directed as-f6116�s: 1. The prior Order of this Court dated August 20, 2010 shall continue in effect as modified by this Order. 2. The parties shall have physical custody of the Child in accordance with the following schedule: A. The parties shall alternate having custody of the Child on weekends from Friday after school, or at 3:30 p.m. if there is no school, through Monday at the time school begins, or 9:30 a.m. if there is no school. B. The Father shall have custody of the Child each week from Tuesday after school, or at 3:30 p.m. if there is no school, through Thursday morning at the time school begins, or 9:30 a.m. if there is no school. C. The Mother shall have custody of the Child during the week at all times not otherwise specified for the Father in this provision. 3. No party shall be permitted to relocate the residence of the Child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the Child consents to the proposed relocation or the Court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C.S. § 5337. 4. 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. BY THE COURT, Kevin . Hess J. cc: Sabrina M. Grady—Mother vJeffrey L. Lambert—Father v �3 30 0 SABRINA M. GRADY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2009-1556 CIVIL ACTION LAW JEFFREY L. LAMBERT Defendant IN CUSTODY Prior Judge: Kevin A. Hess CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8,the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME AGE CURRENTLY IN CUSTODY OF Kayden L. Lambert 8 Mother/Father 2. A custody conciliation conference was held on July 22, 2013,with the following individuals in attendance: the Mother, Sabrina M. Grady, and the Father, Jeffrey L. Lambert. Neither party is represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator