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HomeMy WebLinkAbout09-4928DONALD SHAFFER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 6 -V )? CN BILLIE JO BAILEY, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Donald Shaffer, by and through his counsel, Michael J. Whare, Esquire and avers as follows: 1. Plaintiff is Donald Shaffer, who currently resides at 3110 Anthony Highway, Chambersburg, Franklin County, Pennsylvania 17202. 2. Defendant is Billie Jo Bailey, who currently resides at 31 West King Street, Apartment 1, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Plaintiff seeks partial physical custody of Name Primary Residence DOB Justas Bailey 31 West King St, Apt. l 03/28/98 Shippensburg, PA 17257 Payton Bailey 31 West King St, Apt. l 08/09/00 Shippensburg, PA 17257 The children were not born out of wedlock. The children are presently in the custody of Billie Jo Bailey, mother, who resides at 31 West King Street, Apartment 1, Shippensburg, Cumberland County, Pennsylvania 17257. Since birth, the children have resided with the following persons at the following addresses: Name Addresses Dates Mother ? Main Street 2005-2007 Scotland, PA Mother Waynesboro, PA 2007-2008 Mother ? Possum Hollow Rd 2008- January 2009 Shippensburg, PA 17257 Mother 31 West King St., Apt. 1 January 2009- Present Shippensburg, PA 17257 The mother of the children is Billie Jo Bailey, who resides at 31 West King Street, Apartment 1, Shippensburg, Cumberland County, Pennsylvania 17257'. She is not married. The father of the children is Donald Shaffer, who resides at 3110 Anthony Highway, Chambersburg, Franklin County, Pennsylvania 17202. He is not married. 4. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with the following persons: Name Himself Relationship 5. The relationship of the Defendant to the children is that of natural Mother. The Defendant currently resides with the following persons: Name Justas Bailey Payton Bailey Eva Bailey Relationshin Daughter Son Daughter 6. Plaintiff has not participated as a party or witness, or in another.capacity, in other litigation concerning the custody of the children in this or another court. 7. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 8. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 9. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: Name(s) Address Basis of Claim None 10. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) A Court Order of custody and structured visitation is desired so that Plaintiff and child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. b) A Court ordered determination of custody is required to avoid continuing conflict between the parties regarding parental responsibility for custody and support. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant his Complaint for partial physical custody of the children. Respectfully submitted, Date: -7`? I- m 10+? L-. J Michael I Whare squire 3 7 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Plaintiff DONALD SHAFFER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law BILLIE JO BAILEY, Defendant No. IN CUSTODY VERIFICATION 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. ri Donald Shaffer, Plain FILED--O rCE OF THE PPOTHC-INROTARY 2004 JUL 22 AM 10: 58 $ /&6- S() pdG`?y (-K4- / 6 f 3 DONALD SHAFFER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. BILLIE JO BAILEY 2009-4928 CIVIL ACTION LAW IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, - Tuesday, July 28, 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 F-- t loor, Cumberland Count Courthouse, Carlisle on ThursdaySe tember 03, 2009 ..C ._....-_._, ,-.- p at 10:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Qhn.Mangan?r. Es Custody Conciliator The Court of Common Pleas of`Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ?H f' F. J; °?CnY JS ?' 7 `? SEP 0 3 2009 t, DONALD SHAFFER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 09-4928 CIVIL ACTION LAW BILLIE JO BAILEY, IN CUSTODY Defendant ORDER OF COURT AND NOW this 3?& day of September 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Donald Shaffer, and the Mother, Billie Jo Bailey, shall have shared legal custody of Justas Bailey, born 03/28/1998 and Payton Bailey, born 08/09/2000. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their 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 Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children 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 Children subject to Father's physical custody as follows: a. Commencing 09/11/09, Father shall have physical custody of Justas and Payton every other weekend, from Friday until Sunday. Father shall pick up the Children from Mother's residence on Friday at 6:00 pm (or pick the Children up after their activities on Friday) and Mother shall pick the Children up from Father's residence at 4:00 pm on Sunday. b. Father shall have physical custody of the Children at such other times as the parties may mutually agree. 3. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 4. Holidays: The parents shall arrange the holiday schedule as attached unless otherwise mutually agreed upon. 5. Each parent shall have two non-consecutive weeks of vacation with the Children per year. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 6. In the event the custodial parent should take the Children 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. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children'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 Children. 8. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 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 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. 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. Dpi tribution: ?1??lichael Whare, Esquire .,4illie Jo Bailey, 31 West King Street, Apartment 1, Shippensburg, PA 17257 _461n J. Mangan, Esquire 114T.Es rKW 4/g/0? HOLIDAYS AND SPECIAL DAYS TIMES EVEN YEARS ODD YEARS Easter Day 1" Half From 9 am until 3 m Father Mother Easter Day 2n Half From 3 m until 9 m Mother Father Memorial Day From 9 am until 9 pm Mother Father Independence Day From 9 am until 9 m Father Mother Labor Day From 9 am until 9 m Mother Father Halloween From one hour before trick or treating to one hour after trick or treating Father Mother Thanksgiving 1St Half From 8 am Thanksgiving Day to 2 m on Thanksgiving Day Father Mother Thanksgiving 2n half From 2 pm on Thanksgiving Day to noon the day after Thanksgiving Day Mother Father Christmas 1St Half From noon on 12/24 to noon on 12/25 Father Mother Christmas 2n Half From noon on 12/25 to noon on 12/26 Mother Father New Year's From 6 pm 12/31 until noon January 1St (with the 12/31 year to control the even/odd determination) Mother Father Mother's Day From 9 am until 9 pm Mother Mother Father's Day I From 9 am until 9 m Father Father DONALD SHAFFER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 09-4928 CIVIL ACTION LAW BILLIE JO BAILEY, 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 Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Justas Bailey 03/28/1998 Primary Mother Payton Bailey 08/09/2000 Primary Mother 2. A Conciliation Conference was held with regard to this matter on September 03, 2009 with the following individuals in attendance: The Mother, Billie Jo Bailey, pro se The Father, Donald Shaffer, with his counsel, Michael Whare, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date John gan, Esquire Cust dy Conciliator Fi B)`e? `Ndc GP IK FIRO RONOTARY 284 SEP -8 AN 6.38 OJMBEJk ;? ?QUNW PD YI.VAW _ FI~.cD.. ~1 ~6~t¢EC~ t~110 DST -? ~,a' 1 ~ ; 00 ,.~,~ rw~~~~el-~~~~D CG~Ji'v ~ DONALD SHAFFER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law No. 09-4928 BILLIE JO BAILEY, . Defendant IN CUSTODY PETITION TO MODIFY CUSTODY AND NOW, comes Donald Shaffer by and through his counsel, Michael J. Whare, Esquire and in support of his Petition to Modify Custody avers as follows: 1. Petitioner is Donald Shaffer, hereinafter referred to as "Father". 2. Respondent is Billie Jo Bailey, hereinafter referred to as "Mother". 3. The parties are the natural parents of Justas Bailey, born March 28, 1998 and Payton Bailey, born August 9, 2000, hereinafter referred as "Children". 4. On September 3, 2009, The Honorable M.L. Ebert, Jr., entered a Custody Order based on an agreement entered into by the parties at the conciliation conference. (Attached as Exhibit A) 5. Since the entry of said Order, there has been a significant change in circumstances in that: a) Mother is currently incarcerated at the Cumberland County Prison. ~~ ~~ ~~ ~~~%~ b) Mother has recently been charged with driving under the influence. c) The Children have been residing with Father for approximately the past month. d) Father avers that he is best able to provide the care, nurture and stability that the Children need for healthy development. 6. Father proposes modifying the Order so that Father has primary physical custody of the Children and Mother has partial custody on alternating weekends. 7. The best interest of the Children will be served by the Court modifying said Order. WHEREFORE, Petitioner respectfully requests this Honorable Court grant his Petition to Modify Custody. Respectfully submitted, Date: ~~ ' 7 1 ~ Michael J. Whare, E uire 37 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Petitioner DONALD SHAFFER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :Civil Action- Law No. 09-4928 BILLIE JO BAILEY, Defendant IN CUSTODY ATTORNEY VERIFICATION I, Michael J. Whare, attorney for Donald Shaffer, verify that the statements made in this Petition are true and correct based upon the information provided to me by Donald Shaffer. 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: ~~ ' 7~~4 Michael J. Whare, E q. . ~ SEP 0 3 2009 ~, DONALD SHAFFER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v No. 09-4928 CIVIL ACTION LAW BILLIE JO BAILEY, IN CUSTODY Defendant ORDER OF COURT AND NOW this ~_ day of September 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Donald Shaffer, and the Mother, Billie Jo Bailey, shall have shared legal custody of Justas Bailey, born-03/28/199$ and Payta~n Bailey, bom 08`'093'~Q00. T`e parties shall have an equal right to make all major non-emergency decisions at~ting the Children's general well being including, but not aimited to, all decisions. regarding their 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 Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other pazent. To the extent one parent has possession of any such records or information, that parent shall be required to shaze 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 pazent. 2. Physical Custody: Mother shall have primary physical custody of the`Children subject to -- Father's physical custody as follows: a. Commencing 09!11/09, Father shall have physical custody of Justas and Payton every other weekend, from Friday until Sunday. Father shall pick up the Children from Mother's residence on Friday at 6:00 pm. (or pick the Children up after their activities on Friday) and Mother shall pick the Children up from Father's residence at 4:00 pm on Sunday. b. Father shall have physical custody of the Children at such other times as the parties may mutually agree. 3. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 4. Holidays: The parents shall arrange the holiday schedule as attached unless otherwise mutually agreed upon. 5. Each parent shall have two non-consecutive weeks of vacation with the Children per year. The requesting pazent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. l v~ II ~~~~V/~ 6. In the event the custodial parent should take the Children out of state, the custodial pazent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which theycan be reached. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children'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 Children. 8. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 9. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consumeJbe under the influence of alcoholic bevea-age's 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. 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, Distribution: Michael Whaze, Esquire ~ ~ ~ Billie Jo Bailey, 31 West King Street, Apartment 1, Shippensburg, PA 17257 John J. Mangan, Esquire m ~i'~~rrttu'~ ~~et~N, ~ ht~e urno sit mir t ~ ~~~~ ~ ~ said a~ Cam, ~ DONALD SHAFFER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law BILLIE JO BAILEY, Defendant No. 09-4928 IN CUSTODY CERTIFICATE OF SERVICE I, Michael J. Whare, Esquire, attorney for Petitioner, do hereby certify that I this day mailed a copy of the within Petition to Modem Custody upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Billie Jo Bailey Cumberland County Prison 1101 Claremont Road Carlisle, PA 17015 Dated: l ° ~ 7- t ~ Michael J. Whare, squire Attorney for Petitioner DONALD SHAFFER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 20094928 CIVIL ACTION LAW BILLIE JO BAILEY DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, _ Tuesday, October 12, 2010 , 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 Wednesday, November 17, 2010 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. Man-an ?Jr., Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFIq SlP FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. --s Cumberland County Bar Association m? ° fir=- ?? A"?a '4'e 44 u 32 South Bedford Street N Carlisle, Pennsylvania 17013 :--= =Q Telephone (717) 249-3166 C? -? ?, ,AW, 11 2D11 DONALD SHAFFER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNS-YLV.NI V. No. 09-4928 CIVIL ACTION L BILLIE JO BAILEY, IN CUSTODY Defendant ?. M Prior Judge: M. L. Ebert, Jr., J. r.F ORDER OF COURT AND NOW this 13 day of January 2011, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. All previous Orders entered in this matter are hereby replaced with the instant Order. 2. Legal Custody: The Father, Donald Shaffer, and the Mother, Billie Jo Bailey, shall have shared legal custody of Justas Bailey, born 03/28/1998 and Payton Bailey, born 08/09/2000. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their 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 Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children 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: Father shall have primary physical custody of the Children subject to Mother's physical custody as the parties may agree. Father has agreed to, and shall, allow maternal grandmother to have alternating weekends with the Children. 4. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 5. Holidays: The parents shall arrange the holiday schedule as attached unless otherwise mutually agreed upon. 6. Each parent shall have two non-consecutive weeks of vacation with the Children per year. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 7. In the event the custodial parent should take the Children 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 parry to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children'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 Children. 9. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 10. 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 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. 11. This Order is entered without prejudice to the parties, specifically Mother. In the event that either party is not content with the instant Order, that party may file a Petition to Modify with Cumberland County Court of Common Pleas and another conciliation shall be scheduled. 12. 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. Distribution: ''Michael Whare, Esquire V Billie Jo Bailey, 31 West King Street, Apartment 1, Shippensburg, PA 17257 &/ John J. Mangan, Esquire III* L,& LW CAP By the Court, HOLIDAYS AND SPECIAL DAYS TIMES EVEN YEARS ODD YEARS Easter Day 1St Half From 9 am until 3 m Father Mother Easter Da 2° Half From 3 m until 9 m Mother Father Memorial Day From 9 am until 9 pm Mother Father Independence Day From 9 am until 9 m Father Mother Labor Day From 9 am until 9 m Mother Father Halloween From one hour before trick or treating to one hour after trick or treating Father Mother Thanksgiving 1St Half From 8 am Thanksgiving Day to 2 m on Thanksgiving Da Father Mother Thanksgiving 2° half From 2 pm on Thanksgiving Day to noon the day after Thanksgiving Day Mother Father Christmas 1St Half From noon on 12/24 to noon on 12/25 Father Mother Christmas 2n Half From noon on 12/25 to noon on 12/26 Mother Father New Year's From 6 pm 12/31 until noon January 1St (with the 12/31 year to control the even/odd determination) Mother Father Mother's Day I From 9 am until 9 m Mother Mother Father's Day From 9 am until 9 m Father Father DONALD SHAFFER, Plaintiff V. BILLIE JO BAILEY, Defendant Prior Judge: M. L. Ebert, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09-4928 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: The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Justas Bailey 03/28/1998 Primary Mother Payton Bailey 08/09/2000 Primary Mother 2. A Conciliation Conference was held with regard to this matter on September 03, 2009, an Order issued September 03, 2009 and a conference was held December 01, 2010 with the following individuals in attendance: The Mother, Billie Jo Bailey, pro se The Father, Donald Shaffer, with his counsel, Michael Whare, Esq. 3. The undersigned recommends the entry of an Order in the form as attached. 1/f/ la ':?? Date John J. M g , Esquire Custody o iliator