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Home My WebLink About09-4147SOMER PORRINO, Plaintiff V. STACY HASKINS, Defendant SHAWANA HASKINS Defendant JOHN CHAVIOUS II Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY :NO. 09- 411N7 CIVIL TERM COMPLAINT FOR CUSTODY The Plaintiff, Somer Porrino, by her attorneys, the Family Law Clinic, sets forth the following cause of action in custody. 1. The Plaintiff is Somer Porrino, residing at 405 North Baltimore Avenue, Apartment 1, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 2. The Defendant Stacy Haskins reside at 15049 116th Drive, Jamaica, Queens County, New York 11434. 3. The Defendant Shawana Haskins resides at 708 Decatur Street, Brooklyn, Kings County, New York 11233. 4. The Defendant John Chavious II resides at 1804 Chestnut Street, Harrisburg, Dauphin County, Pennsylvania 17104. 5. Plaintiff seeks primary custody of: Name Present Residence Age Braydan Haskins 708 Decatur Street, Brooklyn, NY 11233 (during the week) 3 15049 116th Drive, Jamaica, New York 11434 (on weekends) The child was born out of wedlock. The child is presently in the custody of Shawana Haskins, who resides at 708 Decatur Street, Brooklyn, New York 11233, and Stacy Haskins, who resides at 15049 116th Drive, Jamaica, New York 11434. During the past five years the child has resided with the following persons at the following addresses: Persons Address Dates Shawana Haskins 708 Decatur Street February 12, 2009 Brooklyn, NY 11233 to Present Stacy Haskins 15049 116th Drive February 12, 2009 Jamaica, New York 11434 to Present Somer Porrino 405 North Baltimore Avenue, Apt #1 December 31, 2008 to Mount Holly Springs, PA 17065 February 12, 2009 261 Plaza Drive, Building #4 Boiling Springs, PA 17007 1213 E Cumberland Road Harrisburg, PA 17103 The mother of the child is Somer Porrino. She is single. The father of the child is John Chavious, II. He is single. October 13, 2006 to December 31, 2008 March 14, 2006 to October 13, 2006 6. The relationship of :Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: Name Michelle Chavious Relationship Child's Paternal Grandmother 7. The relationship of Defendant Stacy Haskins to the child is that of maternal great-aunt. The relationship of Defendant Shawana Haskins to the child is that of maternal cousin. The relationship of Defendant John Chavious II to the child is that of father. Stacy Haskins resides alone during the week and with Braydan Haskins on the weekends. Shawana Haskins resides with the following persons: Name Relationship Stephan Peppers Son Nekeya Haskins Sister Ashley Haskins Sister Miles Haskins Nephew Braydan Haskins Cousin John Chavious II resides with the following persons: Name Relationship Steven Chavious Brother 8. Plaintiff has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. A custody order entered in a dependency proceeding at docket number CP-21 -DP-00000 17-2009 remains in effect as described below. The Dependency Proceeding has been closed by a Court Order signed by the Honorable Judge Ebert, dated February 17, 2009. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth, or any other state. 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. 9. Plaintiff represents that a prior Order of Court was entered in Juvenile Court, Docketed as CP-21-DP-0000017-2009 for custody of the child born March 14, 2006. A copy of which is attached as Exhibit A. 10. The February 17, 2009, Court Order refers to a Family Plan agreement made between Plaintiff and the Defendants. A copy of the private agreement is attached as Exhibit B. 11. Under the existing Order of Court: a. Defendant Stacy Haskins has temporary legal and physical custody of the child. b. Defendant Stacy Haskins must bring child to Pennsylvania every other week for visits with his parents, Plaintiff and Defendant John Chavious II. 12. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff is the child's mother and except for the time the child has been with maternal great-aunt and maternal cousin, has been the child's primary caretaker for most of the child's life; b. Plaintiff can provide the child with a stable home and environment with adequate moral, emotional, and physical surroundings as required to meet the child's needs; c. Plaintiff has corrected the situation that required the child to be placed in the temporary custody of Defendant Stacy Haskins and Defendant Shawana Haskins; d. Plaintiff is willing to accept custody of the child; e. Defendant Stacy Haskins has not complied with the current Court Order requiring her to bring the child to Pennsylvania every other week and has only brought child to Pennsylvania to visit with Plaintiff once since February 17, 2009. 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody to the child have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant Mother and Father shared legal custody and Mother primary physical custody with the father having periods of partial custody of the child. Date: J(,117 O Respectfully submitted, Amy Hir ' is Certified J?egal Intern i /ZU G MEGA RIESMEYER Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 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 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Somer Porrino Fl'_= SOMER PORRINO, Plaintiff V. STACY HASKINS, Defendant SHAWANA HASKINS Defendant JOHN CHAVIOUS II Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY :NO. 09- q) V CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Somer Porrino, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date Q,611-7 6 Respectfully submitted, Amy Hir is Certifie egalIntern MEG RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 X069 iU14 18 P 112: 133 S "? L SOMER PORRINO IN THE COURT OF COMMON PLEAS O CUMBERLAND COUNTY, PENNSYLVA IA PLAINTIFF V. STACY HASKINS, SHAWANA HASKINS, JOHN CHAVIOUS, II DEFENDANT 2009-4147 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, June 25, 2009 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, July 16, 2009 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the is ues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to ente into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or perman nt order. The court hereby directs the parties to furnish any and all existing Protection from Ab se orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled heari ?2. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. ,jA Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply w th the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accon modations 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 att nd 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 r THE ZCGJ Ct 8" 2 .. , .,L.,, L? .'a as SOMER PORRINO, Plaintiff V. STACY HASKINS, Defendant SHAWANA HASKINS Defendant JOHN CHAVIOUS II Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY :NO. 09-4147 CIVIL TERM CERTIFICATE OF SERVICE I, Amy Hirakis, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Custody Complaint on John Chavious II, residing at 1804 Chestnut Street, Harrisburg, Pennsylvania 17104, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by John Chavious, on the the 20'h day of June, 2009, as evidenced by the attached Amy H' 's Certifie egalIntern Ln m co CL C3 ..n .13 C3 0 0 0 r4 r-1 A cc 0 0 r` I BE N FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 4rm:llloTH6wo ARY 209 JUN 29 AN 9: 30 6£9£-£bZ (LIL) :x83 896Z-£bZ (L I L) £ I OL I Vd `aisiiJUO I334S uid u-poN Sb DINI ID /AVI A'IIwv3 f,au.iouV guisin.TadnS •bsg `.za?iau?sai2l ?ay? unjul103-I agilao si Tili XuzV -r 7//,) O(2 W 2° .aIUQ •10130p pauoijdva-anoqu aul it, lurelduzoo atp of g Iigigxg pur d ligiilxg uar-ur asrald :mououlotd oigL oZ .LNIV'IdWOD OZ S LIgIHXH HDV12V OZ UlDaY Id Y1 UHI TAIO LV I V-60 'ON: AQO.LSflD NI t1c1WI - NOI.LDV IIAIO VIMVA'IASNN3d `A.LNflOD QNWRIggL1 D JO S`dg'Id NOWWOO AO .LXflOD 9H L NI luepua3aQ II SflOIAVHD NHOI' Iutpu0joa SNINSVH VMVI VHS 1uPpualaQ `SNINSVH ADVIS •n d Rind `ONI2RIOd,HF1wOS OF THE PROTPONOTAW 2009 JUN 29 Pty 3: 4 2 .; ?WNTY PENNSYLVANIA Commonwealth of Pennsylvania IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA In The Interest Of: Braedon Haskins, A Minor Date of Birth: 03/14/2006 JUVENILE DIVISION DOCKET NO: CP-21-DP-0000017-2009 FID: 21-FN-00015-2009 MASTER'S RECOMMENDATION FOR DISPOSITION AND NOW, this 12th day of February, 2009, after hearing, the court finds CUSTODY AND CONDITIONS LEGAL CUSTODY - Temporary legal custody is hereby transferred to an Individual Resident or Relative, specifically custody is transferred to maternal great aunt Stacy Z. Haskins. CURRENT PLACEMENT - Child's Safety The child is safe in the current placement setting. Further, the Court hereby finds that to allow this child to remain in the home would be contrary to the child's welfare, and that Reasonable Efforts were made by the County Children and Youth to prevent or eliminate the need for removal of this child from the home. ORDERS/FINDINGS THE COURT FURTHER FINDS: Braedon Haskins, 2, was placed on an emergency basis as a result of his mother's inadequate supervision. The family had a family group decision making meeting and all have agreed that Braedon should be placed in the custody of maternal great aunt Stacy Haskins, who is a foster parent and adoptive parent, and who is empolyed in a group home for autistic children in New York. Braedon will return every other two weeks for visits with his parents. It is recommended that the petition for dependency be dismissed. 4 K-4 -rtr EXHIBIT A ,v? rain :: 4 AOPC 3801 REV. 02/12/2009 Such disposition having been determined to be best suited to the protection and physical, mental and moral welfare of the child. RECOMMENDED: rM v ` "r James D. flower Jr. The Recommendation Order is not final it confirmed by the Court below. If objections are raised to the recommendations of the Master, a party may request a hearing before the Court within three (3) days of the date set forth on page 1. ORDER AND NOW, this day of 2 after consideration this court finds the recommendation by the Maste is in the best interest of the child and is hereby adopted and ordered. BY THE COURT: '?? -? ?A' A _ Judge AOPC 3801 REV. 02/1212009 Families First EXHIBIT 8 Family Name: Porrino/ Chavious/ Haskins Date: 2/12/09 Participants: Stacy Z. Haskins, maternal great aunt; John T. Chavious II, father; Wesley S. Chavious, paternal uncle; Shawana Haskins, maternal cousin; Amy Ford, Cumberland County Children and Youth Services Caseworker; Cassie Astrin, Cumberland County Children and Youth Services Casework Intern; Sandy Gibson, Cumberland County Children and Youth Services Casework, Supervisor; Lois Kohler. Cumberland Perry Early Intervention Service Coordinator; Somer Porrino, mother; Maria Shelton, maternal grandmother; via writing- Kristen Campbell, Occupational Therapist; Amy Hempt, Speech Therapist; Hollie Henderson, maternal cousin Coordinator and Co-Facilitator: Eliza A. White Facilitator: Audra Hennessey Observing Family Group Conference and Coordination: Erin Dreisbach, Intern Location: Human Service Building, 16 West High Street Suite 300 Conference Room C, Carlisle PA 17013 Meeting Purpose: For the family to develop a plan to allow Braydon to return to an approved family member/ caretaker. The Families First, Family Group Conference referral was made by Caseworker Ford on 2/5/09. Caseworker Ford stated that she thought the meeting would be beneficial to the family and that Cumberland County Children and Youth Services would consider the plan the family develops. Somer Porrino met to discuss the Family Group Conference process on 2/5/09. Ms. Porrino was able to identify many supports to her and Braydon. The date and time of the meeting was scheduled to accommodate the emergency need for the family group conference prior to the next scheduled hearing, since Braydon was placed into foster care on 2/2/09. The meeting started with introductions and a review of the meeting purpose. The guidelines of the meeting and the meeting format were also reviewed. The family and service providers present identified numerous strengths. Caseworker Amy Ford provided the meeting participants with an overview of the case and what 1(,,d her to requesting a family group decision making meeting; for the family. The meeting participants then identified concerns for the family. 2 Family members and servi?, providet resources available for the family. Caseworker Ford provided the family with the non-negotiables for the plan and the family then worked on developing their family plan. The plan was reviewed and although very well thought out, the coordinator and facilitator assisted getting their words and thoughts on paper that they had already agreed on during their planning session. Caseworker Ford and all other parties, including both mother and father agreed to the plan. Strengths: • Somer loves Braydon • John loves Braydon • Paternal uncle close to Braydon and loves him too • Braydon is Somer's world • Somer is a good mom • Somer is an excellent mother and needs some guidance to help her along • Excellent family/ friend support • Needs both mother and father • Lamont was a good male role model • Strong extended family background • Somer provides to the best of her ability • Somer will take advantage of services that will better her as a parent • Braydon has made some improvement in aggressive behaviors, attention and speech • Braydon is affectionate and thrives on praise • Somer has good intentions regarding Braydon's care • Braydon likes to play, has good eye contact, follows simple direction and imitates words and phrases when modeled • John is a good father • Braydon very active and high energy • Strong paternal side and bonding •? Somer rearranged home and safety proofed home to better meet Braydon's needs Concerns: • Somer reunited with Braydon • Braydon's safety (childproof home) Ce) Saner does not have transportation • Lack of a schedule for Somer/ Braydon • Braydon's educational plan • Somer does not have "a lone" time • John's amount of time with Braydon • John's investment in Bradon's life • John's development of the relationship with Braydon • Need to co-parent Braydon • Put aside differences including past between Somer and John • Level of interaction/ supervision of Braydon • Extended family time with Braydon 3 • John's level of understanding of Braydon's developmental delays • Braydon often hungry and sleepy during therapy • Braydon aggressive and no concept of turn taking • Lack of peer involvement/ interactions • Need for change of enviorment, taking a walk, etc... • Little spontaneous speech • Does not point to pictures of common objects/ animals • Self directed- avoids adult direction • Somer's mental health • Somer's medication appear to have an impact on her ability to focus/ interact • Braydon/ Somer's sleep patterns erratic • Negative impact on his behavior/ development • Somer's non compliance in requirements related to Braydon's services/ treatment • Communication between parents regarding Braydon's needs/ services • Somer sleepy or not engaged during Braydon's services, preoccupied/ dealing with crisis • Lack of mom and Braydon play time • Braydon watching excessive tv- not always age appropriate • Lack of food available for Braydon • Lack of strong family/ friends who live nearby • At times Somer blocks/ does not utilize or jeopardizes her family/ friends supports • Dad's criminal history and drug and alcohol concerns • Dad's history of physical/ sexual abuse • Somer's mental health appointments. Braydon can not ride county transportation with her. Resources: • Capital Area Intermediate Unite (not in the home) • Recommendations: Developmental, Speech, Occupational • d Tran A T ' r+arr tingg prc gra: ',--t r nn"- f r t?? paa rrc "ts .,...,..nu.a 1., J l:`L .,.??.. :; G vv..., tiu..s.:.... SSI • Stevens Center- Resource Coordinator • Head Start • County Assistance Office • WIC • Maternal Aunt care for Braydon once a month for 4 days (including transportation) • Twice a year- one week of vacation for Somer with Maternal aunt caring for Braydon • Paternal uncle help as much as can • Drug and alcohol evaluation • Mazzitti and Sullivan • Gaudenzia • Dauphin County Drug and Alcohol Commission • Sex offenders evaluation 4 • TW Ponessa • Aunt Stacy approved Coster care in State of NY, Board of Education, and Mercy I St Non-Negotiables: l All contact between Somer and Braydon will be supervised by people approved by Children and Youth Services until a parent instructor advises another visitation plan. t11 Somer will participate in all mental health treatment. 3 Somer will attend all medical, educational, and mental health appointments for herself and Braydon 4. Joi-in will have only supervised visits with Braydon at the agency until a parenting instructor advises another visitation plan and until all recommended treatment is completed. 5. John will have a drug and alcohol evaluation by 3/12/09 and follow all recommendations of the evaluation, and cooperate with random drug screens. 6. John will have a sexual offenders assessment by 3/12/09 and follow all recommendations of the evaluation. Family Plan: Family Plan Who What B When Aunt Stacy Take Braydon home with her Now Mom Somer Be reunited with Bra don As Soon As Possible Shawana To stay with Bra don Now Dad (John) To spend time with Bra don As Soon As Possible • Braydon will primarly reside at Shawana's home Aunt Sta;.v will be at Shavvgna's hot_ise dur±na the week • Aunt Stacy will be enrolling Braydon in day care • Awit Stacy will have Braydon at her home during the weekends • Aunt Stacy will be responsible for scheduling all Braydon's medical, dental and educational needs after consulting with both parents. • Aunt Stacy will make a referral to the Intermediate Unit service provider for Braydon to receive his much needed services by 2/17/09. • Aunt Stacy will transport Braydon to the Harrisburg/ Carlisle (community visit- parks, McDonald's) area for visits with mom and dad every other Saturday for a I pm visit for 2 hours to start on 2/21/09 at the Carlisle location. Every other visit will occur alternating Carlisle and Harrisburg. • If maternal grandmother can move in with Somer then Braydon will return to Somer's home and maternal grandmother will accept full responsibility of Braydon's care and safety. • Aunt Stacy, Shawana and maternal grandmother will follow through with CYS required clearances. • Somer will attend all scheduled therapy appointments with Mrs. Reeves at the Stevens Center and keep scheduled appointments and Shawana will contact Somer to remind her of the appointments. • John and Sill cooperate with the parenting assessments and all recommen a ions. • John will agree to schedule an appointment for his drug and alcohol evaluation and sexual offenders evaluation by 3/12/09 and follow all recommendations. • John will cooperate with random drug screens by the Agency. • John will work with the caseworker to discuss options for transportation or other resources for the random drug screens. SOMER PORRINO, Plaintiff V. STACY HASKINS, Defendant SHAWANA HASKINS Defendant JOHN CHAVIOUS II Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY :NO. 09-4147 CIVIL TERM CERTIFICATE OF SERVICE I, Amy Hirakis, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Order of Court scheduling the custody conciliation on John Chavious II, residing at 1804 Chestnut Street, Harrisburg, Pennsylvania 17104, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by John Chavious, on the the 1 st day of July, 2009, as evidenced by the attached Breen ca LD -b- ?? m ?O r o F- w U '' a mN, ` E6 G Lb ? 013 W M Ix N L m H1 ? C 2 -.5 'Q Z' U 0 Crj ? Y U romro+-may o! 0 'O E :S w 0 C 0 a '802- W m 1 r E y Z- E V V QC 0 C y C m ! ; Y d l Vw 0 « a d• >. o .c E cYIca0 U ma ?Q o R4 A ? O ? o 1??..?2/C/ J Amy H' *is` Certif * Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 cc) Cr O E 16 Ln ¢ .-O U -? E 0 O C3 C3 Q N rl cO 2 Q 0 r` T 00 Ch U C LL N d LEA'.-:1 o T-!" "vo7s' Y r' 2009 WIJ?_ - 8 FM 2: 3 1 SOMER PORRINO, Plaintiff vs. AUG O fi 2009 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW STACY HASKINS, SHAWNA HASKINS, JOHN CHAVIOUS, II, NO. 2009-4147 Defendant IN CUSTODY COURT ORDER AND NOW, this ~ day of August, 2009, upon consideration of the attached Custody Conciliation Report, this Court's prior Order is reaffirmed with the addition of the following: 1. The mother shall have custody of the minor child from Thursdays through Sundays consistent with the terms as set forth in the July 23, 2009, letter from the Family Law Clinic, a copy of which is attached hereto and marked Exhibit `A'. BY THE COURT, Judge cc: Amy Hirakis, Student Attorney Ms. Stacy Haskins ~~.~~ P- /~ -0 g Ms. Shawana Haskins ~~ !j Mr. John Chavious, II . , SOMER PORRINO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW STACY HASKINS, SHAWNA HASKINS, JOHN CHAVIOUS, II, NO. 2009-4147 Defendant 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. Consistent with the prior Order entered in this case and the correspondence dated July 23, 2009, received by the Conciliator, a copy of which is attached hereto and marked Exhibit `A', the Conciliator recommends an Order in the form as attached. Date: August J , 2009 Hubert X. Gilroy, Esq ' e Custody Conciliator .)`~ ~~ ~r- ~ ~ ~~. ~itt~Y [~~~ f;~G 12 ~'~~'~ ~~ is %: PEN~I~T~TE The Dickinson School of Law Family Law Clink The Dale F. Shugart Community Law Center A service to the community by students 45 North Pitt Street from The Dickinson School of Law of Carlisle, PA 17013 The Pennsylvania State University Office: 717-243-2968 Fax: 717-243-3639 July 23, 2009 Mr. Hubert Gilroy, Esq. 10 East High Street Cazlisle, PA 17013 RE: Porrino v. Haskins, Haskins, &Chavious Dear Mr. Gilroy: At the July 16, 2009, custody conciliation you asked my client, Sourer Porrino, and defendant Stacy Haskins to work out a temporary visitation plan for Sourer and her son Braydan. I have spoken to both Sourer and Ms. Haskins and they have agreed to the following: Sourer will travel by bus to New York on Thursdays and pick up Braydan from Ms. Haskins' home. Sourer will return Braydan to Ms. Haskins' home on Sunday. During these visits Sourer and Braydan will stay at Somer's sister, Jennifer Houston's, home. Ms. Houston resides at 358 Logan Street, Brooklyn, NY 11208. Ms. Houston lives with her sixteen year old son, ltahin Houston. Sourer will not consume alcohol when she has Braydan. Prior to agreeing to this arrangement, Ms. Haskins spoke to Ms. Houston and from this conversation Ms. Haskins was satisfied that Ms. Houston's home was appropriate for Braydan. I request that you enter a temporary order that reflects this agreement. If you have any questions, please feel free to contact me. I am available Monday through Friday, 9:00 AM to 4:30 PM. S' cerely, ff // >7,e~C~ Am irakis Ce fied Legal Intern Cc: Sourer Porrino Stacy Haskins Shawana Haskins John Chavious The Dickinson School of Law of The Pennsylvania State University An Equal Opportunity University EXHIBIT 'A'' T i-i~.f"i_~ -~ ~C~19 ~~.~ ~ ~ „~ ~_~ .- ~~~