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HomeMy WebLinkAbout04-2075 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. t)l!-- dJ075- ~ : CIVIL ACTION - LAW : CUSTODY JAMIE L. SHORT, vs. MELISSA L. RYAN, Defendant COMPLAINT FOR CUSTODY AND NOW, this /rf'day of May, 2004, comes the Plaintiff, Jamie L. Short, and respectfully requests the following: 1. Your Plaintiff is Jamie L. Short, father of the minor child, who currently resides at 603 Market Street, New Cumberland, Cumberland County, Pennsylvania. 2. The Defendant is Melissa L. Ryan, mother of the minor child, who currently resides at 141 Southside Drive, Newville, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant were previously married and as a result of said marriage, one child was born, namely Courtney Jean Short, born March 24, 2000, in Pennsylvania. 4. There are no custody orders in effect at this time. 5. The Plaintiff, Jamie L. Short, believes it is in the best interest of their daughter, Courtney Jean Short, that equal physical custody be granted to him and the Defendant, Melissa L. Ryan, with the Plaintiff providing care for ~heir daughter for one week, followed by the Defendant providing care for their daughter for the next week, and so on, alternating weeks. 6. The Plaintiff and the Defendant each have homes with suitable arrangements for the minor child to reside with both parents_ 1 7. The minor child has resided at the following addresses over the last five years: 233 West Ridge Street Carlisle, PA 17013 14 Hidden Noll Road Carlisle, PA 17013 411 Geary Avenue New Cumberland, PA 17070 141 Southside Drive Newville, PA 17241 603 Market Street New Cumberland, PA 17070 8. The Court of Common Pleas of Cumberland County has jurisdiction as the Defendant, Plaintiff, and minor child resides in Cumberland County, Pennsylvania. 9. There has been no prior action for custody of the minor child. 10. The best interest and permanent welfare of the child will be served by granting the custody requested because it would establish a stable environment with consistency and familiar family surroundings for Courtney. This would allow each parent to develop a strong relationship with Courtney, as well as have Courtney feel loved and accepted by all of her family members. Equally shared custody would also prevent Courtney from being switched back and forth numerous times a week, and allow her to settle into each of the homes. WHEREFORE, your Plaintiff, Jamie L. Short, respectfully asks your Honorable Court to grant equally shared custody of the child, Courtney Jean Short. 2 Respectfully Submitted, 3 VERI FICA TION I VERIFY THAT THE STATEMENTS MADE IN THIS complaint are true and correct. I understand that false statements herein are made subject to the penalties of 1 B Pa. C.S. S 4904 relating to unsworn falsification to authorities. O~((()(2cb'f Date 4 '" f ~ ~ <(\ (,"; '0 1\ /^' c" ~ V\ ~' \ ~ \ K) ~ l~ ~ l "" C"':;' () 1::':;' -n .../;;'- :;} "- h1 -11 ;::'7': .::n 0 '-- (j ::,,-.. , .. , ;! .' j , , " C) .f r'~ "--- " -:.; JAMIE L. SHORT PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 04-2075 CIVIL ACTION LAW MELISSA L. RYAN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, May 12, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Friday, June 04, 2004 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 defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinll. FOR THE COURT, By: Isl Melissa P. Greevy. Esq. Custody Conciliator mhc The Court of Common Pleas of Cumberland County is requin:d by law to comply with the Americans with Disabilites Act of 1990. For infonnation 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 A ITORNEY 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 ~.~ "7 ~ ~~ Ac7. ElI .~-to ~ -1l /f) .p.v ~.~ A C/. FI-; \iij\]\f/\l)S\!f\Fd I "IC .. -~~:Wl'" I\.J~l'J V,'<'!::'_'f\.l V 82 :i; lid 81 J.!fH ~OOZ },i::!VLOhOHlOdd 3Hl :10 3:)HjO-{J311~ \J Plaintiff JUN 1 4 2004}' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA NO. 04-2075 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY JAMIE L. SHORT, v. MELISSA L. RYAN, Defendant TEMPORARY ORDER OF COURT - AND NOW, this th day of June, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Leaal Custody. Jamie L. Short and Melissa L. Ryan, shall have shared legal custody of the minor child, Courtney Jean Short, born March 24, 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 her health, education and religion. Pursuant to the terms of 23 Pa. C. S. ~5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be requilred to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. phvsical Custody. A. The parties shall continue the present physical custody arrangement which they have been following as illustrated in the calendar document attached hereto as Exhibit "A." B. When Father begins to work third shift in July 2004, assuming he is able to provide Mother with sufficient notice to allow her to make schedule adjustments to her work schedule which is presently been prearranged through the month of July 2004, the schedule will change as follows: (1) Father's alternating weekend time will commence on Fridays at 12:30 p.m. and continue until Sunday at 7:00 p.m. (2) When Father has a day off on a weekday, his custodial period will begin at Noon on the day following his last work day and continue until 7:00 p.m. the following day. Under the present schedule, Father has off on Thursdays on alternatin!~ weeks and Mondays on the week following. ." NO. 04-2075 CIVIL TERM 3. The Custody Conciliation Conference shall reconvene on September 21, 2004 at 1:00 p. m. at the office of the Custody Conciliator, Melissa Peel Greevy, Esquire, 301 Market Street, Lemoyne, PA 17043. It is contemplated at the time the Custody Conciliation Conference reconvenes that the parties; will review the operation of this adjusted schedule which has been made as a result of Fatlner's request for additional time and as a result of his choice to change shifts at his place of .~m ment. // BY THE r~RT: \:::A J. 0lst: Jamie L. Short, 603 Market Street, New Cumberland, PA 17070 Taylor P. Andrews, Esquire, 78 W. Pomfret Street, Carlisle, PA 1701:3 ~ ~ l.' It. .-0'1 9- ;... 0- ;:..r; tuQ ~)6 .d:;L." C')t-- C!;&:i wo.: "'!I.LJ ti:jE !3 .",. "'" ~ \.0 <'v cS ~ ~~Jk - 0: \.0 - ~-"'. ~. ...;0- .~_:.; ~-f "o"c{j-:) ,".-,.i.,.<: ;ii Ii: :s D ."2>- ~ .. CALENDAR. June 2004 Tuesdav 8 22 28 29 Saturday Wednesday 5 2 4 9 16 = Father's time = Mothe~s time 6/4/2004 EKHmIT "All JUN 1 4 2004 ( Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2075 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY JAMIE L. SHORT, v. MELISSA L. RYAN, Defendant 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 clnild who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Courtney G. Short March 24, 2000 Mother 2. A Custody Conciliation Conference was held on June 4, 2004 in response to Father's pro se Complaint for Custody filed on or about Ml~y 11, 2004. The parties have no Custody Order but worked out the arrangements for their daughter without the need of court intervention or written document. Present for the conference were: the Father, Jamie L. Short; the Mother, Melissa L. Ryan, and her counsel, Taylm P. Andrews, Esquire. 3. The parties reached a temporary agreement in the form of an Order as attached. fa /1/0'1 Date I / Melissa eel Greevy, Esquire Custody Conciliator :230227 SEP Z S Z004 :. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERU~ND COUNTY, PENNSYLVANIA NO. 04-2075 CIVIL TERM JAMIE L. SHORT, v. CIVIL ACTION - LAW MELISSA L. RYAN, IN CUSTODY Defendant BAYLEY, J. --- TEMPORARY ORDER OF COURT AND NOW, this }O attached Custody Conciliation follows: day of Summary .2.904, upon consideration of the IS hl~reby ordered and directed as 1. Leqal CustodY. Jamie L. Short and Melissa 1_. Ryan, shall have shared legal custody of the minor child, Courtney Jean Short, born March 24, 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 her health, education and religion. Pursuant to the terms of 23 Pa. C. S. ~5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical CustodY. The parties have agreEld to a shared physical custody schedule which shall commence October 1, 2004. The sc:hedule is a two week alternating schedule which is arranged as follows: A. During Week 1, Mother will have custody on Monday, Tuesday and Wednesday and Father will have custody on Thursday and Friday. Week 1 commences October 4, 2004. B. During Week 2, Father will have custody on Monday, Tuesday and Wednesday and Mother will have custody on Thursday and Friday. Week 2 commences October 11, 2004. C. In addition, the parties will alternat'B weekends. Father's first weekend under the alternating schedule begins O(;tober 2, 2004 at 9:30 a.m. and continues until Monday, October 4, 2004 at 9:30 a.m. Mother's first weekend under the alternating schedule begins October 9, 2004 at 9:30 a.m. and continues until Monday, October 11, 2004 at 9:30 a.m. NO. 04-2075 CIVIL TERM 3. Transoortation. The parent receiving custody is the parent responsible to provide transportation for the child. 4. Holidavs. The following holiday schedule shall take precedence over the regular schedule: A. Thanksaivina. The parties will alternatl3 the Thanksgiving holiday which shall be defined as 9:30 a.m. Thanksgiving day until 8:00 p.m. Thanksgiving day. Mother shall have custody for Thanksgiving day in even- numbered years and Father shall have custody for Thanksgiving day in odd- numbered years. B. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 24th at 9:00 a.m. until December 25th at 1 :00 p.m. Segment 13 shall be from December 25th at 1 :00 p.m. until December 26th at 7:00 p.m. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. In odd- numbered years, Father shall have Segment A and Mother shall have Segment B. C. Easter. The parties will alternate the Easter holiday which shall be identified as that period from Saturday before Easter at 9:30 a.m. until the Monday following Easter at 9:30 a.m. In odd-numbElred years, Father will have custody. In even-numbered years, Mother will have custody. D. Mother's Dav/Father's Dav. Father will have custody for Father's Day and Mother will have custody for Mother's Day. The custodial period for this holiday shall be from 9:30 a.m. until 7:00 p.m. E. Courtney's Birthdav. The parties will split Courtney's birthday with one parent having Courtney from 9:00 a.m. until 3:00 p.m. and the other parent having Courtney from 3:00 p.m. until 9:00 p.m. F. Vacation. Each parent shall be entitled to fourteen (14) days of vacation each year, not more than ten (10) of which may be taken consecutively. The parties shall provide each other with at least a thirty-day notice of their planned vacation time. In the event that the parties have arranged conflicting schedules for vacation, the lParty first providing written notice to the other party shall have choice of the vacation week. Additionally, the vacationing parent shall provide a telephone number and location where they can be reached during the vacation. NO. 04-2075 CIVIL TERM 5. School. The parties have agreed that the child will attend the Big Spring School District, commencing with the 2005/2006 academi,; year. Father's agreement to allow the child to enroll in school in Big Spring School District is contingent upon a continued shared (meaning equal time) physical custody schedule. / ~ ~ 9--30-0'/ ~ BY THE s;oURT: / ~AI Edgar B. Bayley, J. Djs!: Jamie L. Short, 603 Market Street, New Cumbertand, PA 17070 Taylor P. Andrews, Esquire, 78 W. Pomlret Street, Carlisle, PA 17013 - ~!iJ\'V/\l/iS:\!t<jd ). I"AA" ".... '-"~""'n'"' \If\ii Ii../.) t,i '~:1 !i,'":-;'(ti v I Z :j IIr~ os d3S ~oaz Ab'\flONO.YlOOd 3Hl :10 :;,..".U('Ln:n/u ......ll...._~...'-U...J I~ SEP Z 8 Z004f Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2075 CIVIL TERM JAMIE L. SHORT, v. CIVIL ACTION - LAW MELISSA L. RYAN, IN CUSTODY Defendant 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 CURRE:NTL Y IN THE CUSTODY OF Courtney G. Short March 24, 2000 Mother 2. The parties' second Custody Conciliation Conference was held on September 21, 2004 as part of an agreement reached at their conference on June 4,2004. Present for the conference were: the Father, Jamie L. Short; the Mother, Melissa L. Ryan, and her counsel, Taylor P. Andrews, Esquire. The Father participat,ed pro se. 3. attached. The parties reached a temporary agreement in the form of an Order as q/(1-~ toy Date ~s~~. Melissa Peel Greevy, Esquire Custody Conciliator :235996 JAMIE L. SHORT, Plaintiff-Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL 04-2075 : CIVIL ACTION - LA W MELISSA L. RYAN, Defendant-Petitioner : IN CUSTODY DEFENDANT'S PETITION TO CHANGE CUSTODY Petitioner-Defendant, MELISSA L. RYAN, by her attorney, Taylor P. Andrews, Esquire, of Andrews & Johnson respectfully represents: 1) Melissa L. Ryan is a married adult who lives at 141 Southside Drive, Newville, Cumberland County, Pennsylvania 17241 (Penn Township) with her husband, Kevin Ryan, their child, Cameron Ryan (one year of age) and Courtney Jean Short, date of birth March 24, 2000, the subject of this proceeding. 2) Jamie L. Short is a married adult who lives at 603 Market Street, New Cumberland, Cumberland County, Pennsylvania 17070 with his wife, Heather, her son, Ian (age 6) (alternate weeks) and Courtney Jean Short, the subject of this proceeding. 3) All prior pleadings to this docket number are incorporated herein by reference to establish jurisdiction of this Cumberland County Court of this custody action. 4) Petitioner and Respondent are parents of Courtney Jean Short, date of birth March 24,2000 and custody is currently determined by a Temporary Order of Court dated September 30, 2004. [A copy of this existing Order is attached hereto as Exhibit 1.] 5) Petitioner seeks a change in the current custody arrangement from the shared physical custody to an order granting Petitioner primary physical custody subject to partial custody by Respondent. Petitioner seeks this changes for the following reasons: a) Courtney Jean Short has developed a medical condition that requires a consistent diet and a consistent communication about diet. The current shared physical custody has resulted in non-compliance with doctors' directions while Courtney has been in the custody of her father. b) The current shared custody arrangement has stressed Courtney Jean Short and she has developed a disorder requiring greater stability and less conflict in her home. c) While in the custody of her father, Courtney Jean Short has witnessed repeated conflict between her father and stepmother and this has had a negative effect on Courtney. d) Jamie L. Short and his wife, Heather Short, have related to Petitioner, Melissa Ryan, in such a disrespectful way that the current shared custody arrangement has become difficult and stressful for Courtney Jean Short. e) Courtney Jean Short would benefit from increased household stability by remaining in the home of Petitioner for increased periods of time. WHEREFORE, Defendant-Petitioner, Melissa L. Ryan, respectfully requests this Court to modify the existing Order by awarding primary physical custody of Courtney Jean Short to Mother subj ect to partial custody by Father. Respectfully submitted, Tay 78 st Pomfret Street Carlisle, PA 17013 Pa. Supreme Ct.#: 15641 (717) 243-0123 Attorney for Defendant-Petitioner 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: tdll.elap , , Mt J7JMJQ d f2tal,J Melissa L. Ryan JAMIE L. SHORT, Plaintiff-Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL 04-2075 : CIVIL ACTION - LAW MELISSA L. RYAN, Defendant-Petitioner : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this date, :::J UI'L 11 ' 2006, I mailed a copy of PETITION TO CHANGE CUSTODY to the following person at the following address by U.S. Mail, first class, postage prepaid, to: Jamie L. Short 603 Market Street New Cumberland, P A 17070 I verify that the statements made in the foregoing Certificate of Service 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. ANDREWS & JOHNSON By: Plaintiff SEP 2 B 200V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2075 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY JAMIE L. SHORT, v. MELISSA L. RYAN, Defendant BA YLEY,J. -- TEMPORARY ORDER OF COURT AND NOW, this 30 ~ day of ~1>--"'" , 2004, upon consideration of the attached Custody Conciliation Summary eport, it is hereby ordered and directed as follows: 1. Leaal Custody. Jamie L. Short and Melissa L. Ryan, shall have shared legal custody of the minor child, Courtney Jean Short, bom March 24, 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 her health, education and religion. Pursuant to the terms of 23 Pa. C. S. ~5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Phvsical Custody. The parties have agreed to a shared physical custody schedule which shall commence October 1, 2004. The schedule isa two week alternating schedule which is arranged as follows: A. During Week 1, Mother will have custody on Monday, Tuesday and Wednesday and Father will have custody on Thursday and Friday. Week 1 commences October 4, 2004. B. During Week 2, Father will have custody on Monday, Tuesday and Wednesday and Mother will have custody on Thursday and Friday. Week 2 commences October 11 , 2004. C. In addition, the parties will alternate weekends. Father's first weekend under the alternating schedule begins October 2, 2004 at 9:30 a.m. and continues until Monday, October. 4, 2004 at 9:30 a.m. Mother's first weekend under the alternating schedule begins October 9, 2004 at 9:30 a.m. and continues until Monday, October 11, 2004 at 9:30 a.m. EXHIBIT i / 4 NO. 04-2075 CIVIL TERM 3. Transportation. The parent receiving custody is the parent responsible to provide transportation for the child. 4. Holidays. The following holiday schedule shall take precedence over the regular schedule: A. Thanksaivina. The parties will alternate the Thanksgiving holiday which shall be defined as 9:30 a.m. Thanksgiving day until 8:00 p.m. Thanksgiving day. Mother shall have custody for Thanksgiving day in even- numbered years and Father shall have custody for Thanksgiving day in odd- numbered years. B. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 24th at 9:00 a.m. until December 25th at 1 :00 p.m. Segment B shall be from December 25th at 1 :00 p.m. until December 26th at 7:00 p.m. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. In odd- numbered years, Father shall have Segment A and Mother shall have Segment B. C. Easter. The parties will alternate the Easter holiday which shall be identified as that period from Saturday before Easter at 9:30 a.m. until the Monday following Easter at 9:30 a.m. In odd-numbered years, Father will have custody. In even-numbered years, Mother will have custody. D. Mother's Day/Father's Day. Father will have custody for Father's Day and Mother will have custody for Mother's Day. The custodial period for this holiday shall be from 9:30 a.m. until 7:00 p.m. E. Courtney's Birthday. The parties will split Courtney's birthday with one parent having Courtney from 9:00 a.m. until 3:00 p.m. and the other parent having Courtney from 3:00 p.m. until 9:00 p.m. F. Vacation. Each parent shall be entitled to fourteen (14) days of vacation each year, not more than ten (10) of which may be taken consecutively. The parties shall provide each other with at least a thirty-day notice of their planned vacation time. In the event that the parties have arranged conflicting schedules for vacation, the party first providing written notice to the other party shall have choice of the vacation week. Additionally, the vacationing parent shall provide a telephone number and location where they can be reached during the vacation. . . NO. 04-2075 CIVIL TERM 5. School. The parties have agreed that the child will attend the Big Spring School District, commencing with the 2005/2006 academic year. Father's agreement to allow the child to enroll in school in Big Spring School District is contingent upon a continued shared (meaning equal time) physical custody schedule. BY THE COURT: I~/ ~ 13 .13~ ' , Edg r B. Bayley, J Dist: Jamie L. Short, 603 Market Street, New Cumberland, PA 17070 Taylor P. Andrews, Esquire, 78 W. Pomfret Street, Carlisle,PA 17013 TRUE COPY FROM PleCORU In TIItirnonv Whereof. I her. unto set My haw and lIIe ~ III said ~ Car1IsIe Pa. . ~h~ ~J;~~ ~ - ~~ ~r , . Prothonowv \ .. Plaintiff SEP Z 8 2004 f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2075 CIVIL TERM CIVIL ACTION - LAW JAMIE L. SHORT, Defendant IN CUSTODY v. MELISSA L. RYAN, 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 CourtneyG. Short March 24, 2000 CURRENTL Y IN THE CUSTODY OF Mother 2. The parties' second Custody Conciliation Conference was held on September 21,2004 as part of an agreement reached at their conference on June 4,2004. Present for the conference were: the Father, Jamie l. Short; the Mother, Melissa l. Ryan, and her counsel, Taylor P. Andrews, Esquire. The Father participated pro se. 3. attached. The parties reached a temporary agreement in the form of an Order as 9h-~lof Date Uk ttfJJ,:::2JL B-r.. Melissa Peel Greevy, Esquire Custody Conciliator :235996 r: ~ _ t R ~ '6' u.. CIS - ~ ~ g " ,~""p,,,",,,, c;'< ,~- \.....' -T1 :::;:! UJ ii'lJJ r- ;--;-' l~j ~') C) '-.w) j;! :D -< ....r:- 1111 JAMIE L. SHORT PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 04-2075 CIVIL ACTION LAW MELISSA L. RYAN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, June 20, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Friday, August 11, 2006 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort win be made to resolve the issues in dispute; or if this cannot be accomplishcd, to define and narrow the issues to be heard by the court, and to enter into a temporary ordcr. An children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl!:' FOR THE COURT. By: Isl Melissa P. Greery-o Esq, y.r J 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 bet()re the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VE 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 Tejephone (717) 249-3166 ~ ~ $- ~ ~ 9fJ-e-e.? ~ ~ ;p"hI~ ~ 'X'-ee'.? ~-p ~/'~>IJft'~_~ ?c?ce-'} -~-:'~V'!n:J 80.7JIII Z71"l.ronDZ - i,. "(.. ,;;( ',J;. -I ;0 JAMIE L. SHORT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff VS. NO. 04-2075 MELISSA L. RYAN, CIVIL ACTION - LAW Defendant. PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Melissa L. Van Eck, Esquire of Van Eck & Van Eck, P.C., as counsel of record for the Plaintiff in the above-referenced matter. Respectfully submitted, lJate '. '\ \ ,:::Jl1o By: Melissa L. Van Eck, Esquire Attorney ID #85869 P.O. Box 6662 Harrisburg, PA 17H2 717-540-5406 Attorney for Plaintiff ""'h :::! (7'12 1 I~:' C>'\ ~ ..!':.- I Y-:' 7;' ..--~~c:-c'--'--c---:-'--"': Plaintiff SEP 2 8 2006 . ,wr -.--..-. -- -~ ~-:-=:. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2075 CIVIL TERM JAMIE L. SHORT, v. CIVIL ACTION - LAW MELISSA L. RYAN, IN CUSTODY Defendant BAYLEY, P. J. --- TEMPORARY ORDER OF COURT AND NOW, this lOft day of ~$, 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. A hearing is scheduled in ~umber 2 of the Cumberland County Clurthouse, on the ,3-ft day of , " 2006, at /.. '3CJ o'clock .M., at which time testimony will be taken. For the purposes of the hearing, the Mother, , shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of exhibits, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda, lists of exhibits, lists of witnesses and summaries of anticipated testimony of each witness shall be filed at least twenty days prior to the hearing date. 2. Counsel for the parties have stipulated that mental health and medical experts shall be permitted to testify by telephone. Edgar B. Bayley, P.J."- Dist: 4sa Van Eck, Esquire, P.O. Box 6662,7810 Allentown Blvd., Suite B, Harrisburg, PA 17112 ~ylor P. Andrews, Esquire, 78 W. Pomfret Street, Carlisle, PA 17013 ~;.... 0- !- e) o ~~ :5 ~-.:: () , Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2075 CIVIL TERM JAMIE L. SHORT, v. CIVIL ACTION - LAW MELISSA L. RYAN, IN CUSTODY Defendant 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 THE CUSTODY OF Courtney G. Short March 24, 2000 Mother and Father 2. The parties' third Custody Conciliation Conference was held on September 21, 2006. Present for the Conference were: the Father, Jamie L. Short, and his counsel, Melissa Van Eck, Esquire; the Mother, Melissa L. Ryan, and her counsel, Taylor P. Andrews, Esquire. 3. Mother's Position on Custody is as Follows: Mother filed a Petition to Modify Custody on June 19, 2006. Mother is married and resides with her husband and one-year old son in Newville, Pennsylvania. She seeks primary custody of Courtney, who is a student at Big Spring School District. The most recent previous Order in this case was entered September 30, 2004 by Judge Bayley. Mother seeks primary custody because Courtney has developed a medical condition (reflux) which requires a special diet and extensive parental communication. Mother claims that Father has refused to follow directions of the various medical professionals who have been involved with the child. It is thought that the conflict between Father and his new wife, the child and Father's new wife, and between the parties is causing stress for this child which is impacting her medical condition. Mother believes the child needs more stability and to spend more time with her. The child has been participating in counseling with Pamela McDermott at Mazetti and Sullivan. She is also under the care of Dr. Barbara Sumbatian. It has been recommended that the parties receive mobile therapy which would be in-home delivery of mental health care services. While Mother acknowledges that the child has improved since the time of the filing of the Petition, Mother points out that just a few days ago the child was feeling anxious on the day of a custodial exchange, hid her breakfast food and then lied about it to her Mother. ..... NO. 04-2075 CIVIL TERM 4. Father's Position on Custody is as Follows: Father opposes the change to primary physical custody to Mother. Father is married and lives with his wife and, on alternating weeks, his wife's child to a prior relationship. Father sees things as much improved for Courtney and reports that she has been released from the care of the gastroenterologist who had been caring for Courtney. She is no longer in need of medication. Father reports that Courtney is eating well and doing well in school. Father reports that he and Mother are both participating in Courtney's therapy by taking her to appointments with Pam McDermott. He does not view the May 2006 report of Dr. Sumbatian as reflective of present conditions because he believes that things are much improved now from what they were at the time. Father does not want to agree to mobile therapy until he has an opportunity to speak with Ms. McDermott (on October 3, 2006) and Dr. Sumbatian. If they recommend that the family go forward with the mobile therapy, Father will agree. The appointment for evaluating the mobile therapy need is October 10, 2006. Father resides in New Cumberland and works at Holy Spirit Hospital as a nurse. He works four 12-hour shifts every two weeks. There is about a 45-minute drive between Father's residence and the child's school. 5. Because the parties have not reached an Agreement with regard to Mother's Petition to shift from an equally shared physical custody schedule to a primary physical custody schedule for Mother, the parties are in need of a one-day hearing. Counsel have stipulated that any professional witnesses that may be called shall be permitted to testify by telephone. q/:4~r- Date f-/ Melissa Peel Greevy, E Custody Conciliator :283807 JAMIE L. SHORT, Plaintiff-Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL 04-2075 : CIVIL ACTION - LA W MELISSA L. RYAN, Defendant-Petitioner : IN CUSTODY MOTION FOR CONTINUANCE DefendantJPetitioner, MELISSA L. RYAN, by her counsel, Taylor P. Andrews, Esq., respectfully represents as follows: 1. Petitioner has filed a Complaint to Change Custody of Courtney G. Short, age 6 ~ years, from the current shared custody arrangement to a traditional arrangement with Petitioner mother having primary physical custody. 2. This Court has scheduled a custody hearing for December 13,2006 at 1 :30 p.m., and this Court has noted the Stipulation reached at the Conciliation that mental health and medical experts would be permitted to testify by telephone. (A copy of the temporary Order of Court and Custody Conciliation Summary Report are attached hereto as exhibits) 3. Petitioner's counsel has been unable to assure the availability of the child's psychiatrist, Dr. Barbara Sumbatian, to provide testimony at the scheduled custody hearing. 4. Both parents and the child, Courtney G. Short, expect to become engaged in mobile therapy with a therapist from The Stevens Center with such mobile therapy to commence at each parent's household in December 2006. 5. There will be insufficient time by the scheduled hearing date on December 13,2006 for there to be any reports as to the benefit of the mobile therapy or of observations made by the mobile therapist. 6. For the above referenced reasons Petitioner seeks a continuance of at least 60 days for the scheduled custody hearing in the above captioned case. 7. The counsel for the Respondent-father, Melissa L. Van Eck, Esquire concurs in this request for a continuance. WHEREFORE, Petitioner prays your Honorable Court to continue the custody hearing in the above captioned case currently scheduled for December 13,2006 to a date that is no sooner than February 13,2006. Respectfully submitted, Ta or P. Andrews, Esquire 7 st Pomfret Street Carlisle, PAl 7013 Pa. Supreme Ct.#: 15641 (717) 243-0123 Attorney for Defendant-Petitioner JAMIE L. SHORT, Plaintiff-Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL 04-2075 : CIVIL ACTION - LAW MELISSA L. RYAN, Defendant-Petitioner : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this date, ro ~ L ( , 2006, I mailed a copy of Motion for Continuance to the following person at the following address by U.S. Mail, first class, postage prepaid, to: Melissa VanEck, Esquire 7810 Allentown Blvd. Suite B Harrisburg, PAl 7112 I verify that the statements made in the foregoing Certificate of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. By: Plaintiff rry 0'7 c~"" I 1'.'SE;2 8 2006~' I IN THE COURT OF COM~ON: PLEAS OF ~~ I CUMBERLAND COUNTY, PENNSYLVANIA '0_.-1 NO. 04-2075 CIVIL TERM CIVIL ACTION - LAW JAMIE L. SHORT, v. MELISSA L. RYAN, IN CUSTODY Defendant BAYLEY, P. J.-- TEMPORARY O~ OF COURT . c.. Obe~ AND NOW, this --LO.:l::h- day of ...septelnbel , 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. A hearing is scheduled i~ Courtroorq Number 2 of the Cumberland County GQurthouse, on the .JJ:& day of Oe.e.e. m '() ~, 2006, at .J :30 o'clock L.M., at which time testimony will be taken. For the purposes of the hearing, the Mother, , shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of exhibits, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda, lists of exhibits, lists of witnesses and summaries of anticipated testimony of each witness shall be filed at least twenty days prior to the hearing date. 2. Counsel for the parties have stipulated that mental health and medical experts shall be permitted to testify by telephone. BY THE COURT: Dist: Melissa Van Eck, Esquire, P.O. Box 6662, 7810 Allentown Blvd., Suite B, Harrisburg, PA 17112 Taylor P. Andrews, Esquire, 78 W. Pomfret Street, Carlisle, PA 17013 --._~~ nW::CORD ":t my hand . "., ,;sle, Pa. . /() OJ. ... . . . . .. ........ .._.M' " Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2075 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY JAMIE L. SHORT, v. MELISSA L. RYAN, Defendant 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: DATE OF BIRTH CURRENTLY IN THE CUSTODY OF NAME Courtney G. Short March 24, 2000 Mother and Father 2. The parties' third Custody Conciliation Conference was held on September 21, 2006. Present for the Conference were: the Father, Jamie L. Short, and his counsel, Melissa Van Eck, Esquire; the Mother, Melissa L. Ryan, and her counsel, Taylor P. Andrews, Esquire. 3. Mother's Position on Custody is as Follows: Mother filed a Petition to Modify Custody on June 19, 2006. Mother is married and resides with her husband and one-year old son in Newville, Pennsylvania. She seeks primary custody of Courtney, who is a student at Big Spring School District. The most recent previous Order in this case was entered September 30, 2004 by Judge Bayley. Mother seeks primary custody because Courtney has developed a medical condition (reflux) which requires a special diet and extensive parental communication. Mother claims that Father has refused to follow directions of the various medical professionals who have been involved with the child. It is thought that the conflict between Father and his new wife, the child and Father's new wife, and between the parties is causing stress for this child which is impacting her medical condition. Mother believes the child needs more stability and to spend more time with her. The child has been participating in counseling with Pamela McDermott at Mazetti and Sullivan. She is also under the care of Dr. Barbara Sumbatian. It has been recommended that the parties receive mobile therapy which would be in-home delivery of mental health care services. While Mother acknowledges that the child has improved since the time of the filing of the Petition, Mother points out that just a few days ago the child was feeling anxious on the day of a custodial exchange, hid her breakfast food and then lied about it to her Mother. NO. 04-2075 CIVIL TERM 4. Father's Position on Custodv is as Follows: Father opposes the change to primary physical custody to Mother. Father is married and lives with his wife and, on alternating weeks, his wife's child to a prior relationship. Father sees things as much improved for Courtney and reports that she has been released from the care of the gastroenterologist who had been caring for Courtney. She is no longer in need of medication. Father reports that Courtney is eating well and doing well in school. Father reports that he and Mother are both participating in Courtney's therapy by taking her to appointments with Pam McDermott. He does not view the May 2006 report of Dr. Sumbatian as reflective of present conditions because he believes that things are much improved now from what they were at the time. Father does not want to agree to mobile therapy until he has an opportunity to speak with Ms. McDermott (on October 3, 2006) and Dr. Sumbatian. If they recommend that the family go forward with the mobile therapy, Father will agree. The appointment for evaluating the mobile therapy need is October 10, 2006. Father resides in New Cumberland and works at Holy Spirit Hospital as a nurse. He works four 12-hour shifts every two weeks. There is about a 45-minute drive between Father's residence and the child's school. 5. Because the parties have not reached an Agreement with regard to Mother's Petition to shift from an equally shared physical custody schedule to a primary physical custody schedule for Mother, the parties are in need of a one-day hearing. Counsel have stipulated that any professional witnesses that may be called shall be permitted to testify by telephone. q/;b5/tJ y Date ,.., Melissa Peel Greevy, E Custody Conciliator :283807 ~.~ 5: r-'-' c~.) C::::::) 0""' r'-, 1.....,.' -n ~ ,';1 :;'!'!: '. f"-j '-R C..:> (./1 JAMIE L. SHORT, Plaintiff-Respondent IIlV 11811 f : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL 04-2075 : CIVIL ACTION - LAW MELISSA L. RYAN, Defendant~Petitioner : IN CUSTODY ORDER AND NOW, this ~ay of November 2006 upon consideration of the attached Motion for Continuance, it is hereby ORDERED AND DIRECTED as follows: 1. The hearing currently scheduled in the above captioned case in Courtroom No.2 of the Cumberland County Courthouse on December 13, 2006 at 1 :30 p.m is hereby CONTINUED to the tL/tlaay of J ~~ 2007, at ~:'\51.<- .m., at which time testimony will be taken. For the purpose of the heanng, Mother, MelIssa L. Ryan, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counseVparty a Memorandum setting forth each parties' position on custody, a list of exhibits, a list of witnesses who are expected to testify at the hearing and a summary of the anticipated testimony of each witness. These Memoranda, lists of exhibits, lists of witnesses and summaries of anticipated testimony of each witness shall be filed at least 20 days prior to the hearing date. 2. Counsel for the parties have stipulated that mental health and medical experts shall be permitted to testify by telephone. cc: Taylor P. Andrews, Esq., 78 West Pomfret Street, Carlisle, PA 17013 'j It -)-1 -6 ~ Melissa L. Van Enck, Esquire, 7810 Allentown Blvd., Suite B, Harrisburg, r A 17112 ~ -Ie< fY'IJ-l' W-. yt5 o I :ZI [,,!d 12 li,ON 900l :\("1 ...', JAMIE L. SHORT, P1aintiff- Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL 04-2075 : CIVIL ACTION - LAW MELISSA L. RYAN, Defendant-Petitioner : IN CUSTODY MOTION TO \VITHDRA W CUSTODY COMPLAINT AND CANCEL COURT HEARING Defendant/Petitioner, MELISSA L. RYAN, by her counsel, Taylor P. Andrews, Esq., respectfully represents as follows: 1. Petitioner filed a complaint to change an existing custody order on June 19, 2006. 2. Following a conciliation conference on the Petitioner's Complaint a court hearing was scheduled, then rescheduled, and is currently scheduled before the Honorable Edgar B. Bayley for February 14,2007 at 8:45a .m. o'clock. 3. Respondent is represented by Melissa Van Eck, Esquire of P.O. Box 6662, 7810 Allentown Blvd., Suite B, Harrisburg, PA 17112 phone 540-5406. 4. Petitioner has decided to withdraw this complaint seeking modification of an existing order which withdrawal will leave the existing order remaining in place. . .. 5. Respondent's counsel, Melissa Van Eck, Esquire concurs in this Motion. WHEREFORE, Petitioner prays your Honorable Court to grant leave to Petitioner to withdraw this custody complaint and to remove the scheduled hearing from the calendar. Respectfully submitted, ..--- AND ' Tay~r P )AnClrews, Esquire 78 ~Pomfret Street Carlisle, P A 17013 Pa. Supreme Ct.#: 15641 (717) 243-0123 JAMIE L. SHORT, Plaintiff- Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL 04-2075 : CIVIL ACTION - LAW MELISSA 1" RYAN, Defendant- Petitioner : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this date, January 30,2007, I mailed a copy of Motion to Withdraw Custody Complaint and Cancel Court Hearing to the following person at the following address by U.S. Mail, first class, postage prepaid, to: Melissa Van Eck, Esquire 7810 Allentown Blvd., Suite B Harrisburg, P A 17112 I verify that the statements made in the foregoing Certificate of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. ANDREWS & JOHNSON By: or . Andrews, Esquire W. Pomfret Street Carlisle, P A 17013 (717) 243-0123 .. ~ JAN 3] 2001 pi JAMIE L. SHORT, Plaintiff- Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL 04-2075 : CIVIL ACTION - LAW MELISSA L. RYAN, Defendant-Petitioner : IN CUSTODY ORDER AND NOW, this tJrday of ~ 2007 upon consideration of the attached Motion to Withdraw Custody Complaint and Cancel Court Hearing, which expresses the concurrence of the Respondent, the Motion seeking leave to the Petitioner to withdraw her complaint to modify a custody order is granted and the hearing previously scheduled for February 14,2007 at 8:45 a.m. is hereby cancelled. . cc: Taylor P. Andrews, Esq., 78 West Pomfret Street, Carlisle, PA 17013 /&~~ />n.-<~ ~ -d.D? Melissa L. Van Eck, Esquire, 7810 Allentown Blvd., Suite B, Harrisburg, PA t7112 '-11<-. a Lt.. r-. '..J ~"' , + JAMIE L. SHORT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ~-~ P..S v 2004-2075 CNIL ACTION -LAW -~.:~ ~ --~ r~ Uy ~ m ~, ~.= rt7 MELISSA L. RYAN, ~ ~ ca .:L''~'' Defendant IN CUSTODY ,"_. ~' ~ ~ ~' -~ ~_ ...Q .~. -,-, PRIOR JUDGE: Edgar B. Bayley -~'- ~- :~ COURT ORDER - -- ~ ~ AND NOW this J~ d a of November 2012 u on consideration of the attached Y P Custody Conciliation Report, it is ordered and directed that this Court's prior Order of September 30, 2004 (hereinafter referred to as "Order"), shall remain in place .subject to the following modifications: 1. At paragraph 4A of the Order, the schedule shall be changed such that mother shall have custody on Thanksgiving Day in odd numbered years and father shall have custody on Thanksgiving Day in even numbered years. 2. Paragraph 4B of the Order shall be modified such that the exchange of custody shall take place on the Pennsylvania Turnpike at the Bedford Exit at the Sheetz Store. 3. Paragraph 4C of the Order shall be modified such that the weekend for Easter shall run from Friday after school until Monday. 4. Paragraph 4D of the Order shall be modified such that it is understood that Mother's Day and Father's Day provisions will be for the entire weekend from Friday through Monday morning. 5. Paragraph 4E of the Order is deleted. (~ \ 6. In all other respects, all other provisions of the Order shall remain in place. No party shall be permitted to relocate the residence of the child where said relocation will significantly impair 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. Any party proposing to relocate MUST comply with 23 Pa. C.S. § 5337. BY THE COURT, cc: '~P. Richard Wagner, Esquire ~ane Adams, Esquire Thomas A. Plocey Common Pleas Judse Co i ~.s rn.~.~ ~~ ~ r ~ l JAMIE L. SHORT, Plaintiff v MELISSA L. RYAN, Defendant PRIOR JUDGE: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2004-2075 CIVIL ACTION -LAW IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT 1N ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The Conciliator met with legal counsel and the parties at a Custody Conciliation Conference on November 13, 2012. The parties indicated to the Conciliator that they would further discuss the matter and advise the Conciliator via email with r~,pect to .~ some proposed changes. The Conciliator received an email from legal counsel with respect to the proposed changes, and those changes are incorporated into the attached proposed Order. Date: November ~ ! , 2012 ubert X ilroy, Esquire Custo Conciliator