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HomeMy WebLinkAbout09-2664NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 97380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 24114436 ATTORNEY FOR PLAINTIFF PAUL E. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. NO. 2009 CIVIL ANNE M. WANDELL, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY NOW COMES the plaintiff, Paul Green, by his attorney, Nathan C. Wolf, Esquire, and presents the following complaint for custody, representing as follows: 1. The plaintiff is Paul E. Green, the natural father of the child who is the subject of this action (hereinafter referred to as "Father"), an adult individual residing at 3115 Ritner Highway, Newville, , Cumberland County, Pennsylvania 17241. 2. The defendant is Anne M. Wandell, the natural mother of the child who is the subject of this action (hereinafter referred to as "Mother,"), an adult individual temporarily residing at 288 Redwood Lane, Carlisle, Cumberland County, Pennsylvania 17015. 3. Plaintiff Father seeks primary physical and joint legal custody of the following child: Name . Present Residence Age- Sylvia Grace Green 3115 Ritner Highway 6 days (DOB 4/18/2009) Newville, PA 17241 4. Father and Mother are the natural parents of the child. 5. The child was born out of wedlock 6. The child is presently in the care of Holy Spirit Hospital, Neo-natal Intensive Care Unit having been born following an emergency c-section (cesarean section) procedure on Saturday, April 18, 2009. 7. The parties were never married. 8. Father believes and therefore avers that Mother's behavior during the course of her pregnancy, including the abuse of cigarettes and alcohol was the causal factor of the child having been born approximately 25 days prior to Mother's due date of May 13, 2009. 9. Father was informed by hospital staff that the emergency c-section was necessitated by the significantly decreased level of nutrition and oxygen being provided to the child through Mother's placenta. 10. Father was informed by hospital staff that Mother's substantial use of alcohol and cigarettes during the pregnancy contributed to the damage caused to the placenta. 11. Father repeatedly and strenuously objected to Mother's use of alcohol and cigarettes during the pregnancy and communicated his concerns to Mother in hopes of convincing her to cease her irresponsible and dangerous behavior, which he believed would endanger the welfare of the child. 12. Mother disregarded the pleas of Father and instead removed herself from Father's residence, and is believed to have continued her use of alcohol and cigarettes through the remainder of the pregnancy. 13. Mother's behavior constituted an unacceptable risk to the welfare of the child, which Father was powerless to prevent until the child's birth. 14. Since the birth of the child, Father has visited the child nearly every day in the hospital since her birth, missing only two days when Father was ill and did not want to risk the health of the child. 15. Father has had stable employment in Carlisle working the same job since approximately 2004. 16. Father has had custody of his 16 year old daughter since approximately 2004 and is well- equipped to provide for the child's needs. 17. Father has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 18. Father has no reliable information of any other custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 19. Father 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. 20. The best interests and permanent welfare of the child will be served by granting the relief requested herein because Mother's actions during the pregnancy evidenced a disregard for the best interests and permanent welfare of the child and it is believed that she will continue her course of action, exposing the child to additional risks of harm since her birth. 21. Father submits that because of the fragile condition of the child, having been born at a weight of only approximately 3 pounds, that the child is significantly vulnerable to harm in the event Mother exposes her to any additional risks. 22. Father and Mother have been attempting to reconcile with the understanding that Father is insisting Mother cease her activities which would expose the child to significant risks. 23. Nevertheless, without an Order providing for custody, Father fears Mother will disregard the child's welfare along with his rights to custody, in favor of her risk taking activities. 24. The child is expected to be discharged from the hospital within two weeks of the filing of the instant complaint and Father fears without an expedited conference to establish a custody order Mother will attempt to assume physical custody of the child upon her release from the hospital. 25. Father believes and therefore avers that it is in the child's best interests for him to be awarded primary physical and joint legal custody of the child and requests that such be incorporated into an Order to be issued by this Honorable Court. 26. Father believes that the best interests of the child would be best served by an award of primary physical and joint legal custody to him Plaintiff also believes that the child must continue to have a relationship with Mother, which he will encourage and facilitate with all reasonable efforts, and agrees that Mother should be permitted reasonable visitation and contact with the child. WHEREFORE, Plaintiff Paul E. Green, respectfully requests that this Honorable Court enter an order granting primary physical and joint legal custody of the child to him Plaintiff furthermore requests that this Court enter an Order awarding Defendant, Mother, Anne M. Wandell, rights to legal custody and visitation with the child along with any additional relief that the Court may deem appropriate and just. Respectfully submitted, WOLF & WOLF Dated: April i2 A-, 2009 Nathan C olf, Esquire 10 'gh Street Carlisle, PA 17013 Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Plaintiff VERIFICATION I do hereby verify that the facts set forth in this complaint for custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. ?i'// 2009 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF PAUL E. GREEN, Plaintiff V. ANNE M. WANDELL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009 - CIVIL : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, hereby certify that I have served a true and correct copy of Complaint for Custody upon the following person and in the matter indicated -n OK Aprilfip, 2009 SERVICE BY U.S. MAIL: Anne M. Wandell 288 Redwood Lane Carlisle, PA 17015 WOLF & W LF NAT OLF Atto r Plaintiff l?,, =,FR 2Q f'l 4 1 pot ?/Gs, ?" ,4?ly PAUL E. GREEN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-2664 CIVIL ACTION LAW ANNE M. WANDELL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, May 04, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, June 12, 2009 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ john J. Mangan, jr., Esq. 14 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 F l PD-C" FICE OF THE PPS -- 'ONO?'MY 2009 MAY -4 PM 1.42 44 IWWIW4?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAUL E. GREEN, NO. 09-2664 Plaintiff . CIVIL ACTION - LAW V. IN CUSTODY ANNE M. WANDELL, Defendant . PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of Diane G. Radcliff, Esquire, Supreme Court ID No. 32112, on behalf of the Defendant, Anne M. Wandell. Papers may be served at the address set forth below: Diane G. Radcliff 3448 Trindle Road Camp Hill, PA 17011 Phone: (717) 737-0100 Date: May 6, 2009 (RAIR'").RADCLIFF, ESID'MRt THE poo R4??f j- OF . THo'VOTARY 1009 MAY -g pH lZ: MAY , s zoos ?` C? PAUL E. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 09-2664 CIVIL ACTION LAW ANNE M. WANDELL, IN CUSTODY Defendant ORDER OF COURT AND NOW this %S ?A day of May 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Paul Green, and the Mother, Anne Wandell, shall have shared legal custody of Sylvia Grace Green, born 04/18/2009. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody: Mother shall have primary physical custody of the Child subject to Father's physical custody as follows: a. Father shall have physical custody of Sylvia every Tuesday and Thursday from 4:00 pm until 8:00 pm. Father shall also have physical custody every Sunday from 12:00 pm until 6:00 pm. b. Father has agreed, and shall, provide transportation of Sylvia for his periods of custody. C. Father shall have physical custody of the Child at such other times as the parties may mutually agree. Holidays: The parents shall mutually agree on a holiday schedule. In the alternative, a holiday schedule shall be established at the scheduled status update conference with the assigned conciliator on June 9, 2009 at 8:00 am. 4. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 8 l :?, w c I A 'M 6001 rv ^-'"`:lea! t 6. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 7. Both parties and/or third parties are not permitted to smoke in confined places when the Child is in their custody. 8. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 9. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. A status update with the assigned conciliator is hereby scheduled for June 9, 2009 at 8:00 am at the Court of Common Pleas to ascertain whether increased custodial periods for Father are appropriate. By the Court, J. D'stribution: athan Wolf, Esquire iane Radcliff, Esquire -,-,rohn J. Mangan, Esquire sr??s fr?q PAUL E. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 09-2664 CIVIL ACTION LAW ANNE M. WANDELL, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Sylvia Grace Green 04/18/2009 Primary Mother 2. A Conciliation Conference was held with regard to this matter on May 12, 2009 with the following individuals in attendance: The Mother, Anne Wandell, with her counsel, Diane Radcliff, Esq. The Father, Paul Green, with his counsel, Nathan Wolf, Esq. 3. The parties agreed to the entry of an Order in the form as attached. S L? 1? Date JO V. M gan, Esquire Cu ody onciliator JUN 10 20094 PAUL E. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENIbTSYLVANIA v. No. 09-2664 CIVIL ACTION LAW ANNE M. WANDELL, IN CUSTODY Defendant Prior Judge: M. L. Ebert, Jr., J. ORDER OF COURT AND NOW this ~p-th day of June 2009, upon consideration of the attached' Custody Conciliation Report, it is Ordered and Directed as follows: 1. All prior Orders entered in this matter are hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, Paul Green, and the Mother, Anne Wandell, shall ~iave shared legal custody of Sylvia Grace Green, born 04/18/2009. The parties shall have ~n equal right to make all major non-emergency decisions affecting the Child's general well-bei~ig including, but not limited to, all decisions regarding her health, education and religion. P~Zrsuant 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 br school records, the residence address of the Child and of the other parent. To the exte~t one parent has possession of any such records or information, that parent shall be required to ~hare the same, or copies thereof, with the other parent within such reasonable time as to make) the records and information of reasonable use to the other parent. 3. Physical Custody: The parties shall share physical custody. Mother shall have primary physical custody of the Child subject to Father's partial physical custody, the schedule of which shall be determined by the parties upon mutual agreement. 4. The terms of this Order are entered without prejudice to either party. 5. Holidays: The parents shall mutually agree on a holiday schedule. 6. Neither party may say or do anything nor permit a third party to do or say anyt~ing that may estrange the Child from the other party, or injure the opinion of the Child as tol,the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 7. In the event of a medical emergency, the custodial party shall notify the other lbarty as soon as possible after the emergency is handled. 8. Both parties and/or third parties are not permitted to smoke in confined places .when the Child is in their custody. 9. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 10. The parties are attempting to reconcile. If said reconciliation does not occur on if the parties are unable to reach a final agreement within the next two (2) months of the date of ithis Order, then either party may request the scheduling of another conciliation conference by cpntacting the assigned conciliator directly. 11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, ~~ J. istribution: ~athan Wolf, Esquire ,/Diane Radcliff, Esquire ,/fohn J. Mangan, Esquire e ,~ ,.~.~ ~~ /~ PAUL E. GREEN, Plaintiff v. ANNE M. WANDELL, Defendant Prior Judge: M. L. Ebert, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09-2664 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL' PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently i~the Custody of Sylvia Grace Green 04/18/2009 Pririary Mother 2. A Conciliation Conference was held with regard to this matter on May 12, 2009, an Order issued May 15, 2009 and an agreement has been reached with the following individuals: The Mother, Anne Wandell, with her counsel, Diane Radcliff, Esq. The Father, Paul Green, with his counsel, Nathan Wolf, Esq. 3. The parties agreed to the entry of an Order in the form as attached. ~(~d~~ Date John . M gan, Esquire Cus dy onciliator F~LEO-{~~~=~G~ ~F THE F~~`~~~~"UNARY 2009 JU~i I 0 P 2~ 3 ~~ PAUL E. GREEN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-2664 CIVIL ACTION LAW „-?rTt c. c ? _ r :n r- rv c ANN M. WANDELL I' r-2: IN CUSTODY - DEFENDANT C; CD r_ - ORDER OF COURT AND NOW, Tuesday, July 26, 2011 _ , upon consideration of the attached Co mplain t, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, August 30, 2011 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis 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/ ohn . Mangan, jr- 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 ? /?41fro Carlisle, Pennsylvania 17013 Copj Sul1?? Telephone (717) 249-3166 nn 6vo ?10?q ,Mc???ta? ? ?ny??. ?ondil?y' V co i1ria A4? PAUL E. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 09-2664 CIVIL ACTION LAV 9 r .? `' ANNE M. WANDELL, IN CUSTODY M co M C -,I Defendant o ? c Prior Judge: M. L. EbertJr. J. ORDER OF COURT AND NOW this I0 day of September 2011, upon consideration of the attached Cus tody Conciliation Report, it is Ordered and Directed as follows: 1. All prior Orders entered in this matter are hereby VACATED and replaced with this Order. 2. Legal Custodv: The Father, Paul Green, and the Mother, Anne Wandell, shall have shared legal custody of Sylvia Grace Green, born 04/18/2009. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: The Father shall have primary physical custody of the Child subject to Mother's physical custody as follows: a. Commencing 09/08/11, Mother shall have visitation with Gracie every Thursday from 10 am until 3 pm. Father shall drop off the Child at 10 am at the Capital City Mall and Mother shall drop off Gracie to Father's residence at 3 pm. b. Commencing 09/19/11, Mother shall have visitation/partial custody every Monday from 12 pm until 3 pm and Thursday from 10 am until 3 pm. Father drops off at the Capital City Mall to begin the periods and Mother drops off Gracie at Father's residence at the end. c. Only appropriate licensed drivers shall transport Gracie. Additionally, Mother shall be personally present for each custody exchange. d. The parties are specifically allowed contact with each other for custody exchanges as long as the exchanges are done in a peaceful non-threatening manner. e. Mother may have additional periods of physical custody as the parties may mutually agree. 2- 4. The parties are strongly encouraged to engage in therapeutic family counseling with an appropriate professional. I Holidays: For Thanksgiving, even though Mother already has regular physical custody on Thursday, Mother shall have Thanksgiving from Thursday 9:00 am until 6:00 pm and Father shall have a period of time on Thanksgiving by agreement of the parties. For Christmas 2009, Father shall have physical custody from noon on 12/24 until noon on 12/25 and Mother shall have physical custody from noon on 12/25 until noon on 12/26. 6. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 7. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. Both parties and/or third parties are not permitted to smoke in confined places when the Child is in their custody. 9. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages under any circumstances. Neither party shall consume any alcohol while the Child is in their custody, furthermore, both parties shall not have any alcohol in their blood at the time that parent is to have physical custody of the Child. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 10. A status conference is hereby scheduled for November 16, 2011 at 9 am with the assigned conciliator. 11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, J. Distribution: r ,, ? Nathan Wolf, Esquire n0 ? Michael Palermo, Esquire 0 a,? 1 John J. Mangan, Esquire ?o(c$ ' PAUL E. GREEN, Plaintiff V. ANNE M. WANDELL, Defendant Prior Judge: M. L. Ebert, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 09-2664 CIVIL ACTION LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Sylvia Grace Green 04/18/2009 Primary Father 2. A Conciliation Conference was held with regard to this matter on May 12, 2009, an Order issued May 15, 2009 and an agreement had been reached, an Order was issued June 10, 2009, a Petition for Special Relief was filed, an Order of Court was issued August 4, 2009 granting Father primary custody and a conciliation conference was held September 11, 2009, an Order was issued September 17, 2009, a conciliation conference was held October 5, 2009, a conciliation conference was held October 23, 2009, an Order issued November 13, 2009 and a conference was held September 06, 2011 with the following individuals in attendance: The Mother, Anne Wandell, with her counsel, Michael Palermo, Esq. The Father, Paul Green, with his counsel, Nathan Wolf, Esq. 3. The parties agreed to the entry of an Order in the form as attached. l ??l Date John an, Esquire Custo nciliator