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Home My WebLink About09-204646 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF JAMES S. BRIDGES, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW PATTI A. BRIDGES, : NO. 2009 - 'yG CIVIL TERM Defendant : IN CUSTODY COMPLAINT FOR CUSTODY NOW comes the plaintiff, James S. Bridges, by his attorney, Nathan C. Wolf, Esquire, and presents the following complaint for custody, representing as follows: 1. The plaintiff is James S. Bridges, an adult individual residing at 331 Oak Flat Road, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Patti A. Bridges, an adult individual residing at 318 Sherman Avenue, Carlisle, Cumberland County, Pennsylvania 17015. 3. Plaintiff seeks equal shared custody of the following child: N= Hayden James Bridges 331 Oak Flax Road Newville, PA 17241 4. Plaintiff and defendant are the natural parents of the child. Age 8 years D.O.B. 8/09/00 5. The parties were divorced by decree issued by this Court dated August 5, 2008 at Docket 2007-6890. 6. The child is presently in the custody of Father and has resided primarily in Father's custody since the parties' separated in 2006. Mother has had periods of partial physical custody of the child since that time. 7. Mother has recently demanded to make significant changes to the current custody schedule, which Father believes is motivated by concerns unrelated to the best interests of the child. 8. Father is willing to work to modify the parties' custody schedule, however, Father believes and therefore avers that the child's best interests and permanent welfare of the child would be best served by maintaining primary physical custody with him. 9. Father is concerned that Mother's recent actions are reflective of her desire to disrupt the status quo, including effecting a change in the child's primary residence and his continued involvement in extra-curricular activities, such that the child's current development and progress would be harmed. 10. The child is currently thriving in school and in his participation in extra-curricular hockey, where the child has close friends and teammates. 11. Father has maintained the marital residence, following the separation of the parties and thus the child has been able to remain in the same school district despite the dissolution of the parties' marriage. 12. 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 any other court. 13. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 14. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 15. Father has been primarily responsible for the child's medical, educational, psychological and recreational needs for the majority of the child's life. 16. The best interests and permanent welfare of the child will be served by granting Father primary physical custody, granting mother periods of partial physical custody, and by granting the parties shared legal custody. WHEREFORE, for the reasons set forth herein, Plaintiff, James S. Bridges, respectfully requests that the Court enter an order granting equal shared legal custody of the child to the parties, granting him primary physical custody of the child, granting mother partial physical custody of the child, along with any additional relief that the Court deems appropriate and just. Respectfully submitted, WOLF & WOLF, Attorney at Law Dated: April -L 2009 E7 an Esquire es Z Street lisle, A 17013 Supreme Court I.D. No. 87380 (717) 2414436 Attorney for Plaintiff VERIFICATION I do hereby verify that the facts set forth in this complaint are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. $4904, relating to unsworn falsification to authorities. March 2009 4aJ es S. Bridges NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF JAMES S. BRIDGES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW PATTI A. BRIDGES, : NO. 2009 - CIVIL TERM Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, have served a true and correct copy of Complaint for Custody upon the following person and in the matter indicated: Patti A. Bridges 318 Sherman Avenue Carlisle, PA 17015 Dated: April, 2009 B Respectfidly submitted, WOLF ,)WOLF, Attorney at Law N5*e, o Esquire 10 Vigh Street C PA 17013 Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Plaintiff aw 4VITMew 2H9 APR -1 Pit 2:12 CWERA-p COLSyy Pat" 411.5.5o PA ATTy eke 61 44.2 P-T* o?a 3 o8'{ f JAMES S. BRIDGES IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-2046 CIVIL ACTION LAW PATTI A. BRIDGES IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, April 07, 2009 , 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 Tuesday, May 05, 2009 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/ 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 OF P? ? ? A?Y 20094PR _8 PM 2. 53 ?? F Tv, ? i y vii I ?/? T 7n i„ ) 1f l .a ,el ?09? c + KLEINBARD BELL & BRECKER LLP STEVEN J. ENGELMYER, ESQUIRE MELISSA C. PRINCE, ESQUIRE Attorney ID Nos. 42840, 92553 One Liberty Place, 46`h Floor 1650 Market Street Philadelphia, PA 19103 (215) 568-2000 HOWETT KISSINGER & HOLST, P.C. JOHN C. HOWETT JR., ESQUIRE Attorney ID No. 20092 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Attorneys for Defendant Patti A. Bridges JAMES S. BRIDGES V. Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY PATTI A. BRIDGES Defendant. NO. 2009-2046 CIVIL ACTION LAW : IN CUSTODY ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of Defendant Patti A. Bridges in the above- captioned matter. (00302019;v 1 } KLEINBARD BELL & BRECKER LLP &*M? J. 6WI . ri r s STEVEN J. ENGEL M, ESQUIRE Loan) ME SA C. PRINCE, ESQUIRE Dated: April 14, 2009 HOWETT KISSINGER & HOLST, P.C. C. HOWETT, JR., ESQUIRE Date: April 15, 2009 { 00302019;v 11 OF THE F', r, ?.PY 20109 APR 16 ati 11: 2 7 CUV?' : vi??4 MAY 0 6 2009 ? JAMES S. BRIDGES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-2046 CIVIL ACTION - LAW PATTI A. BRIDGES, Defendant : IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this r11 day of A4 t , 2009, upon consideration of the attached Custody Conciliation Re Fort, it is ordered and directed as follows: 1. The Father, James S. Bridges and the Mother, Patti A. Bridges, shall have shared legal custody of Hayden James Bridges, born August 9, 2000. 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 his 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. 2. The parents shall have shared physical custody on the following schedule: A. During the school year, Mother shall have physical custody every Monday and Tuesday overnight from after school to Wednesday morning when school begins. B. During the school year, Father shall have physical custody every Wednesday and Thursday overnight from after school to Friday morning when school begins. CV5 c c_7 c k o aD --JS? o° N C. During the school year, the parties shall alternate weekends, defined as Friday from after school to Monday morning. Mother shall have the first weekend beginning May 8, 2009. D. During the summer, the parties shall go to a week on/week off schedule with Sunday at 5:00 p.m. being the exchange day and time. Father shall have the first week beginning Sunday, June 7, 2009. E. During the summer recess, the non-custodial parent shall have Wednesday overnight from 6:00 p.m. to Thursday when the child will be dropped off at the War College summer camp. 3. Mother shall have physical custody of the child on Mother's Day and Father shall have physical custody of the child on Father's Day. In the event that the party does not have custody on these days under their regular custody schedule, then the parties shall switch a day to accommodate the schedule and shall be afforded a makeup day. 4. In 2009, Mother shall have physical custody of the child on Memorial Day and Father shall have physical custody of the child on July 4tn 5. Each party shall be entitled to two non-consecutive weeks in the summer, provided they give 30-days prior notice and provided that the week coincides with their regularly scheduled week. 6. The parties shall continue to cooperate with counseling for the child. 7. The parties shall cooperate with a custody evaluation to be conducted by Riegler Shienvold and Associates, with costs proportional to the number of individuals in the parties' respective households. Transportation shall be shared such that the receiving party shall transport. 9. The child will attend two summer hockey camps, one in York and one in Hagerstown. The child's hockey equipment shall transfer with the child if there is practice during the custodial parent's custody. Each parent shall take proper care of the equipment. 10. Custody matters shall not be discussed with the child or in the child's presence. 11. Neither party may do or say anything nor permit a third party from doing or saying anything that may estrange the child from the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 12. Neither party is prejudiced by the entry of this temporary shared physical custody arrangement. 13. 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. Either party may contact the Custody Conciliator to schedule another conference once the custody evaluation is completed. BY THE COURT, J. cc: athan C. Wolf„ Esquire, Counsel for Father iI - C. Howett, Jr., Esquire, Counsel for Mother Xlissa C. Prince, Esquire, Counsel for Mother J JAMES S. BRIDGES, Plaintiff V. PATTI A. BRIDGES, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-2046 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 Hayden James Bridges August 9, 2000 Father & Mother-counsel dispute whether it is shared or whether Father has primary 2. A Conciliation Conference was held in this matter on May 5, 2009, with the following in attendance: The Father, James S. Bridges, with his counsel, Nathan C. Wolf, and the Mother, Patti A. Bridges, with her counsel, John C. Howett, Jr., Esquire and Melissa C. Prince, Esquire. 3. The parties disputed the physical custody status quo. Father alleged that he had 8 overnights in a two week period while Mother had 6 overnights. Mother alleged that for the past two months, the parties had equal overnights with the child. 4. The parties agreed to an Order in the form as attached. r M. Verney, Esquire Date ac l? z?' Custody Conciliator JU! 19 2010 (~, JAMES S. BRIDG S, : IN THE COURT OF COMMON PLEAS OF Plai tiff :CUMBERLAND COUNTY, PENNSYLVANIA ~'• : N0.2009-2046 CIVIL ACTION -LAW PATTI A. BRIDG S, Defe dent : IN CUSTODY ORDER OF COURT AND NOW, his 19"' day of July, 2010, more than one year having passed and neither party have re uested another Conciliation Conference, the Conciliator hereby relinquishes jurisdict on in this matter. FOR THE COURT, ~2, ~ cqu ine M. Verney, Esquire, Cu dy Conciliator ~ C~ ' '"" ° =n . <;_ '' i;~' ° ~ ~;~ . ,,. - r- -~~~-"g ~ ..._ , ; ~. ~= `- -,~ = ,, ~: _~ ca.> !. r r r• ?. 27 f?HII: ! a M"iQ'ERLAIND COUNTY FENNISYLVANIA MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Email: mcognetti@cognettilaw.com Attorneys for Plaintiff JAMES S. BRIDGES, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO. 2009-2046 PATTI A. BRIDGES, CIVIL ACTION -LAW Defendant IN CUSTODY ASSIGNED JUDGE: J. WESLEY OLER, JR. PETITION FOR CONTEMPT OF CUSTODY ORDER AND MODIFICATION OF CUSTODY ORDER AND NOW, comes Plaintiff, James S. Bridges, by his attorney Maria P. Cognetti, Esquire, who files this Petition for Contempt of Custody and Modification of Custody Order and in support thereof respectfully represents as follows: 1. Petitioner is James S. Bridges, (hereinafter "Father"), Plaintiff in the above- captioned custody action. af?. 0,4tf *70-60 Ck# Z/ 7S7 Of di8 *so 2. Respondent is Patti A. Bridges (hereinafter "Mother"), Defendant in the above- captioned custody action. 3. Father and Mother are the parents of one minor child, Hayden Bridges, who was born on August 9, 2000, and is currently age 10. 4. On May 7, 2009, this Court entered an Order whereby the parties have joint legal and physical custody of Hayden. A. copy of said Order, marked as Exhibit "A," is attached hereto and made a part hereof. 5. Paragraph 1 of the Custody Order states, in relevant part, "[e]ach 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 his health, education and religion.... Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child." 6. Paragraph 2 states, in relevant part, "[d]uring the school year, Father shall have physical custody every Wednesday and Thursday overnight from after school to Friday morning when school begins." 7. Paragraph 10 of the parties' Custody Order states: "[c]ustody matters shall not be discussed with the child or in the child's presence." 8. Furthermore, in Paragraph 11 it states: "[n]either party may do or say anything nor permit a third party from doing or saying anything that may estrange the child from the other parent, or hamper the free and natural development of the child's love and respect for the other parent." 9. Mother had physical custody of Hayden pursuant to the parties' Custody Order from Friday, April 8, until the start of school on Wednesday, April 13`h 10. Mother informed Father on Sunday, April 10`h, that her sister-in-law had passed away suddenly and that she had taken Hayden to Hollidaysburg to be with her family. 11. During their discussions on Sunday, April 10`h, Mother and Father had agreed that Hayden would be back in the area Monday and Tuesday to attend school and to attend hockey tryouts Tuesday evening. 12. Contrary to their agreement, Mother failed to take Hayden to school on Monday, April l lch or Tuesday, April 12`h 13. In the late afternoon of Tuesday, April 12`h, Mother met Father half-way between Hollidaysburg and Newville to exchange custody so that Hayden could attend his hockey tryouts. 14. The viewing for Mother's sister-in-law was Wednesday, April 13`h, from 2:00 p.m. to 4:00 p.m. and 6:00 p.m. to 8:00 p.m. The funeral service was Thursday, April 14", beginning at 10:00 a.m. 15. Father and Mother agreed that Hayden would attend the evening on April 13`h but that he would be returned to Father's custody following the viewing so that he could attend school on Thursday. 16. The parties specifically agreed that Hayden would not be attending the funeral service on Thursday. 17. After school on April 13, Father drove Hayden half-way so that Hayden could attend the evening viewing on the premise that Father would again meet half-way after the viewing so that Hayden could go to school the following day. 18. Wednesday evening Father received a text message from Mother (while she was attending the viewing) indicating that Hayden was sick and asking if he could stay until Thursday. 19. When Father did not acquiesce to Mother's request, Mother had Hayden call Father twice to try and get Father to agree to allow him to stay. 20. Father advised Mother that it was inappropriate to have Hayden call him to discuss the issue as it was a parenting decision. 21. While on the phone with Father, Mother informed Father that Hayden was listening to everything that he was saying, and that Hayden was not even sick but that she simply wanted an excuse for him to stay. 22. Mother agreed to have her Aunt and Uncle meet Father half-way Wednesday evening to exchange custody of Hayden. She informed Father that she would call him when they left the viewing. 23. Having not received a call from Mother by 8:30 p.m., Father called to see what was going on and Mother informed him that Hayden would not be returned to his custody until Thursday. 24. As a result of Mother's unilateral actions, the school sent a letter via certified mail, requiring that all future absences be accompanied by a doctor's note or they will be deemed "unlawful". A copy of the letter issued by the school to Father is attached hereto and marked at Exhibit "B." 25. This is not the first time Mother has interfered with Father's custodial rights. 26. On or about January 18, 2011, Mother called Father informing him that she was taking Hayden to the emergency room at Harrisburg Hospital. 27. Father drove to Harrisburg Hospital only to find that Mother and Hayden were not there. 28. Father repeatedly tried to call and text Mother to determine where they went. Mother did not respond. 29. Father drove to Holy Spirit Hospital and Carlisle Hospital before finding Mother and Hayden at Carlisle Hospital. 30. When Mother initially phoned Father regarding the need to take Hayden to the emergency room, she specifically told him she was not taking Hayden to the Carlisle Hospital. 31. In spite of repeated requests to do so, Mother has willfully and deliberately violated this Court's order by failing to comply with Paragraphs 1, 2, 10 and 11. Specifically, a. Mother violated the shared legal custody provisions of the Order by failing to take Hayden to school on Monday, April 11 th, Tuesday, April 12th and Thursday, April 14th, while Hayden was in her care and contrary to the agreement of the parties; thus usurping Husband's shared legal custody rights and unilaterally changing a jointly made decision; b. Mother violated the shared physical custody provisions of the Order by failing to return Hayden to Father on Wednesday evening, April 13th and the majority of the day Thursday, April 14th for his custodial time; c. Mother violated the provisions of paragraphs 10 and 11 by allowing Hayden to become involved in custodial issues that should have remained between the parties; and d. Mother further violated the shared legal custody provisions of the Order by interfering with Husband's ability to take part in medical care and treatment planning for his son. 32. Mother's violations of this Court's Order are willful, deliberate, and without just cause or legal excuse. 33. Mother has, and at all times had, the ability to comply with the Court's Order. 34. Father believes, and therefore avers that given Mother's propensity to not comply with the Court's Order a modification of the custodial arrangement is warranted and her custodial time should be reduced. 35. Father has been put to considerable expense in the preparation and presentation of this Petition because of Mother's failure to comply with the Court's Order. 36. Father believes, and therefore avers, that Mother should be held responsible for his reasonable attorney's fees. 37. Mother's counsel has been sent a copy of this Petition in advance of its filing. 38. WHEREFORE, Father respectfully requests this Honorable Court find: a. Mother in contempt of this Court's Order of May 9, 2009; b. reduce Mother's custodial time; C. award Father reasonable attorney's fees, costs and expenses; and d. any other relief the Court deems equitable and just. Respectfully Submitted: MARIA P. COGNETTI & ANSOCIATES Date: April 26, 2011 By: MARIA PICOGPTI, ESQUIRE Attorney I.D. No. 2 14 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff VERIFICATION I, James S. Bridges, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. 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: S. Br iges 4sS(- I r;70, ??rp , MAY 0 6 20094 JAMES S. BRIDGES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-2046 CIVIL ACTION - LAW PATTI A. BRIDGES, . Defendant : IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this % day of , 2009, upon consideration of the attached Custody Conciliation R ort, it is ordered and directed as follows: 1. The Father, James S. Bridges and the Mother, Patti A. Bridges, shall have shared legal custody of Hayden James Bridges, born August 9, 2000. 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 his 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. 2. The parents shall have shared physical custody on the following schedule: A. During the school year, Mother shall have physical custody every Monday and Tuesday overnight from after school to Wednesday morning when school begins. B. During the school year, Father shall have physical custody every Wednesday and Thursday overnight from after school to Friday morning when school begins. C. During the school year, the parties shall alternate weekends, defined as Friday from after school to Monday morning. Mother shall have the first weekend beginning May 8, 2009. D. During the summer, the parties shall go to a week on/week off schedule with Sunday at 5:00 p.m. being the exchange day and time. Father shall have the first week beginning Sunday, June 7, 2009. E. During the summer recess, the non-custodial parent shall have Wednesday overnight from 6:00 p.m. to Thursday when the child will be dropped off at the War College summer camp. 3. Mother shall have physical custody of the child on Mother's Day and Father shall have physical custody of the child on Father's Day. In the event that the party does not have custody on these days under their regular custody schedule, then the parties shall switch a day to accommodate the schedule and shall be afforded a makeup day. 4. In 2009, Mother shall have physical custody of the child on Memorial Day and Father shall have physical custody of the child on July 4`h 5. Each party shall be entitled to two non-consecutive weeks in the summer, provided they give 30-days prior notice and provided that the week coincides with their regularly scheduled week. 6. The parties shall continue to cooperate with counseling for the child. 7. The parties shall cooperate with a custody evaluation to be conducted by Riegler Shienvold and Associates, with costs proportional to the number of individuals in the parties' respective households. 8. Transportation shall be shared such that the receiving_ _party shall transport. 9. The child will attend two summer hockey camps, one in York and one in Hagerstown. The child's hockey equipment shall transfer with the child if there is practice during the custodial parent's custody. Each parent shall take proper care of the equipment. 10. Custody matters shall not be discussed with the child or in the child's presence. 11. Neither party may do or say anything nor permit a third party from doing or saying anything that may estrange the child from the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 12. Neither party is prejudiced by the entry of this temporary shared physical custody arrangement. 13. 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. Either party may contact the Custody Conciliator to schedule another conference once the custody evaluation is completed. BY THE COURT, .5 J. cc: Nathan C. Wolf„ Esquire, Counsel for Father John C. Howett, Jr., Esquire, Counsel for Mother Melissa C. Prince, Esquire, Counsel for Mother 4??If :::}; r III ? se' my ?rx kf0efc?s JAMES S. BRIDGES, Plaintiff V. PATTI A. BRIDGES, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-2046 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 Hayden James Bridges August 9, 2000 Father & Mother-counsel dispute whether it is shared or whether Father has primary 2. A Conciliation Conference was held in this matter on May 5, 2009, with the following in attendance: The Father, James S. Bridges, with his counsel, Nathan C. Wolf, and the Mother, Patti A. Bridges, with her counsel, John C. Howett, Jr., Esquire and Melissa C. Prince, Esquire. 3. The parties disputed the physical custody status quo. Father alleged that he had 8 overnights in a two week period while Mother had 6 overnights. Mother alleged that for the past two months, the parties had equal overnights with the child. 4. The parties agreed to an Order in the form as attached. Date ac line M. Verney, Esquire Custody Conciliator , 6y#" F /,1 0 0 " Oak Flat Elementary School Office of the Principal 334 Centerville Road Newville, PA 17241 Medical Requirement April 13, 2011 Mr James Bridges 331 Oak Flat Road Newville, PA 17241 Re: Hayden Bridges Dear Mr Bridges: In our previous communication, we expressed our concern about the attendance of Hayden. This medical requirement letter is issued because your child has accumulated 17 absences and 1 tardy/tardies to date. This is considered excessive. Therefore, the following regulations are now in effect regarding your student: 1. Any future absences or tardiness which occurs will be classified as unexcused/unlawful unless the family doctor certifies the absence or tardiness with a written excuse. Unlawful is applied to students enrolled in first grade and through the age of sixteen. Unexcused is applied to kindergarten students and students seventeen years of age and older. 2. After three (3) unexcused/unlawful absences, you, the parent or guardian, are in jeopardy of receiving a fine imposed according to Pennsylvania's Compulsory School Attendance Law. Please avoid this procedure by sending your student to school regularly or obtaining a doctor's excuse for future absences. Thank you for your cooperation . If you have any helpful comments or questions regarding this requirement, please feel free to call me at 776-2045. Respectfully, O? . ??/- zte,? Mrs. Stacey Kimble b.2r1 o+- S4-,,,co1 e4o+s Principal cc: Mrs. Winesickle, Home/School Visitor VERIFICATION I, James S. Bridges, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. 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: S . Ar? AJam s S. Bridges CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, hereby certify that I served a true and correct copy of the foregoing Petition for Contempt of Custody Order at the address indicated below: John C. Howett, Jr., Esquire HOWETT KISSINGER & HOIST, PC P.O. Box 810 Harrisburg, PA 17108 Service by: Personal service via hand delivery X Service by First Class, United States Mail, postage pre-paid, mailed at Camp Hill, Pennsylvania, addressed as indicated above Overnight delivery Facsimile service Certified/Registered Mail Date: April 26, 2011 By: MARIA P. COGNETTI & ASSOCIATES MARIA P. CO( Attorney I.D. No 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff JAMES S. BRIDGES IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-2046 CIVIL ACTION LAW PATTI A. BRIDGES IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, May 06, 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, June 10, 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 uelrne M. Verne Esq., AIN Custody Conciliator fil 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 r-, HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFK2SE ' FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. rn 1 -, " Cumberland County Bar Association ~* ;y r- 32 South Bedford Street ` a Carlisle, Pennsylvania 17013 r_-D - , ? ; Telephone (717) 249-3166 Z C) MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Email: mcognetti@cognettilaw.com !t r - Attorneys for Plaintiff JAMES S. BRIDGES : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 2009-2046 PATTI A. BRIDGES, CIVIL ACTION -LAW Defendant IN CUSTODY PRAECIPE TO WITHDRAW PETITION TO THE PROTHONOTARY: Kindly withdraw on behalf of Plaintiff, James S. Bridges, the Petition for Contempt of Custody Order and Modification of Custody Order filed with your Court on April 27, 2011. Respectfully submitted, MARIA P. COGNETTI & ASSOCIATES Date: June 1, 2012 By. MARIA 6?o. ETTI, ES QUIRE Attorney 7914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, hereby certify that I served a true and correct copy of the foregoing Praecipe to Withdraw Petition at the address indicated below: John C. Howett, Jr., Esquire HOWETT KISSINGER & HOLST, PC P.O. Box 810 Harrisburg PA 17108 Service by: Personal service via hand delivery X Service by First Class, United States Mail, postage pre-paid, mailed at Camp Hill, Pennsylvania, addressed as indicated above overnight delivery Facsimile service Certified/Registered Mail Date: June 1, 2012 By: MARIA P. COGNETTI & ASSOCIATES MARIA'. COPYETTI, ESQUIRE Attorney I.D. N&127914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff JAMES S. BRIDGES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-2046 CIVIL ACTION - LAW ,. PATTI A. BRIDGES Defendant -w IN CUSTODY 4:A ORDER OF COURT AND NOW, this 5th day of June, 2012, having not been contacted by the parties for more than 90 days to schedule a Conciliation Conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, acq line M. Verney, Esquire, Custo Conciliator