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HomeMy WebLinkAbout09-5364LAW OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street Harrisburg, PA 17102 Telephone No. (717) 232-9724 Attorney for Plaintiff, Lynelle Wagner LYNELLE WAGNER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. STEPHEN G. FREEMAN Defendant NO. O ??5?3G?C?v I CIVIL ACTION - LAW :CUSTODY COMPLAINT FOR PRIMARY PHYSICAL CUSTODY AND NOW, this day of July, 2009, comes the Plaintiff, Lynelle Wagner, by her attorney, Diane M. Dils, Esquire, and respectfully avers the following: 1. The Plaintiff is Lynelle Wagner, an adult individual currently residing at 1 Pine Hill Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Stephen G. Freeman, an adult individual currently residing at 112 Summit Street, Oberlin, Dauphin County, Pennsylvania 17113. 3. The Plaintiff and Defendant were never married; however, they are the natural parents of two children; namely: Sarah Elizabeth Freeman, born September 1, 2007 and Rylie Mae Freeman, born August 30, 2008. 1 4. The parties lived together until January of 2009, at which time they physically separate. 5. Plaintiff is living at the home of her parents along with the minor children. 6. The Defendant is living with his parents. Currently it is believed that the Defendant, while visiting with the minor children, stays with his neighbors in that the Defendant's home had incurred extensive fire damage and Defendant's parents are currently residing in a trailer in their driveway until a new home is built. 7. The minor children were in the home of the Defendant's parents at the time of the fire. 8. The Defendant never informed the Plaintiff of the fire and the experience that the children went through until three days after the fire occurred. 9. The Plaintiff believes it is in the children's best interest that she be granted primary physical custody with partial custody in the Defendant to be established in a consistent schedule. 10. The minor children have resided in Cumberland County, Pennsylvania for a period of at least six (6) months. 11. The Court of Common Pleas of Cumberland County has jurisdiction in this matter. 2 12. The Plaintiff has not participated as a party or witness in any capacity in other litigation concerning the custody of the minor children in this or any other Court. 13. The Plaintiff has no information of the custody proceedings concerning the children pending in a Court of this Commonwealth or any other state. 14. The 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. WHEREFORE, the Plaintiff, Lynelle Wagner, respectfully prays your Honorable Court to grant her primary physical custody with partial custody set forth in the Defendant. Date bmitted, Diane MYT, Esquire 1400 North Second Street First Floor, Front Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 3 i f VERIFICATION I verify that the statements made in this COMPLAINT FOR PRIMARY P?iYSICAL 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 unsworn falsification to authorities: ! ? f I/LYNELLE WAGNER Date: July 22, 2009 OF I.H,- 14 41 io5. 60 PA ATr4 GG0 330a U* O-O &ZB LYNELLE WAGNER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-5364 CIVIL ACTION LAW STEPHEN G. FREEMAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, August 06, 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 Friday, September 04, 2009 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Esq. -, AA 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-li, - F TH r?' r 2009 AUG -6 ',' c;: Uti -ef LYNELLE WAGNER, Plaintiff VS. STEPHEN G. FREEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2009-5364 IN CUSTODY COURT ORDER AND NOW, this day of October, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: A hearing is scheduled in Court Room No. oZ of the Cumberland County ML dZ b/o Courthouse on the ?J day of 7'ria ,-26 at PSIP A.m. At this hearing, the mother shall be the moving party and shall proceed initially with testimony. Counsel for the parties, or the parties themselves if they do not have legal counsel, shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, the following TEMPORARY Custody Order is entered: A. The mother. Lynelle Wagner, and the father, Stephen G, Freeman, shall have shared legal custody of Sarah Elizabeth Freeman, born September 1, 2007, and Rylie Mae Freeman, born August 30, 2008. B. Physical custody shall be shared equally between the parties on a 50/50 basis. Unless the parties agree to the contrary, the following schedule shall be in place: 51-1 .r 46 i. On the first week, mother shall have custody from Sunday at 5:00 p.m. until Wednesday at 5:00 p.m., father shall have custody from Wednesday at 5:00 p.m. until Friday at 5:00 p.m., and mother shall have custody from Friday at 5:00 p.m. until Sunday at 5:00 p.m, ii. On the following week, the above schedule shall remain in place, subject, however, to the parties flipping the custody schedule so the father will start with custody on Monday through Wednesday, etc. iii. It is noted that father's birthday is on October 11 and the mother shall insure that the father has custody that day to start at approximately noon. BY THE COURT, Judge cc: " iane M. Dils, Esquire Mr. Stephen G. Freeman, Esquire m?3tlt? p 1 ,es LYNELLE WAGNER, Plaintiff vs. STEPHEN G. FREEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-5364 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE 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: Sarah Elizabeth Freeman, born September 1, 2007, and Rylie Mae Freeman, born August 30, 2008. 2. A Conciliation Conference was held on October 8, 2009, with the following individuals in attendance: The mother, Lynelle Wagner, who appeared with her counsel, Diane M. Dils, Esquire, and the father, Stephen G. Freeman, who appeared without counsel. 3. The parties have been separated since approximately January of this year. They have been generally working under a 50150 custody arrangement. Mother now seeks to modify that arrangement and suggests that the children are having problems adjusting with the current schedule. The father suggests the current schedule is fine and wants to keep it in place. The parties were unable to reach an agreement and a hearing is required. 4. The Conciliator recommends an Order in the form as attached which schedules a hearing and also sets forth a custody schedule generally consistent with what the parties have been doing over the past eight months. Date: October J , 2009 Hubert X. Gilr, Esquire Custody Co iliator FIL Fr. ,ter 1 Y THE 2009 OCT 15 PI 1, 12: 00 r MAR O'S10~0 LYNELLE WAGNER : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2009-5364 STEPHEN G. FREEMAN :CIVIL ACTION -LAW Defendant :CUSTODY ORDER OF COURT AND NOW, this soh day of , 2010, upon presentation and consideration of the within Stipulation and Agreement of the parties, it is hereby ORDERED that said Stipulation and Agreement is incorporated herein and made a part of this Court Order. It is further ORDERED that the hearing scheduled for March 3, 2010 is cancelled. BY THE COURT: The Honorable M.L. Ebert, Jr., d: ..'x,`' r [ Distribution: ~ y - X ~ ,.; ~ne M. Dils, Esquire, 1400 North Second St., Harrisburg, PA 17102 }~'t== ~ephen G. Freeman, 112 Summit Street, Oberlin, PA 17112 .~ ~~ O -rt a ~" ~ ~ ~~ rM ~ ~'' 7t> "'t1 ~: > ~ ", ~ { {~~ ~.~ a LYNELLE WAGNER IN THE COURT OF COMMON PLEAS O? (__ --- PLAINTIFF CUMBERLAND COUNTY, PENNSYLV-6=A -- M ? m ?r- V.r- • yy :;01=, V' 2009-5364 CIVIL ACTION LAW --< ° STEPHEN G. FREEMAN =CD r1o C; IN CUSTODY 5 • - s DEFENDANT -- cn ORDER OF COURT AND NOW, Tuesday, March 13, 2012 , 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 Tuesday, April 03, 2012 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Hubert X. Gilroy, Esg.,e Custody Conciliator -r 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 Qopy,.?,i/Pd ? doff • ?Y/?a?Pa?ii? 3/r?//rz LYNELLE WAGNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW STEPHEN G. FREEMAN, NO. 2009-5364 Defendant IN CUSTODY COURT ORDER AND NOW, this ?a day of April, 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No. 2 of the Cumberland County Courthouse on the I_Ttl"Zay of - , 2012, at P& m. At this hearing, the Mother shall be he moving party and shall proceed initially with testimony. Counsel for the parties, or the parties themselves if they do not have an attorney, shall file with the Court and the opposing counsel/party a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called to testify on behalf of each party, and a summary of the anticipated testimony of each witness. This Memorandum shall be filed at least five (5) days prior to the mentioned hearing date. 2. It is noted that Father did not have an attorney at the custody conciliation conference. In the event Father retains counsel prior to the hearing scheduled above and the attorneys for the parties believe another custody conciliation conference may aid in resolving this case prior to the scheduled hearing, counsel for the parties may contact the Custody Conciliator directly to schedule a conciliation conference. 3. The parties shall make arrangements to have both children undergo any counseling/therapy as may be determined necessary by Melinda Eash at Sheinvold & Associates. Both parents shall be involved in these counseling sessions as deemed appropriate by the counselor, and the counselor is authorized to discuss the results of these counseling sessions with both parents. Cost of the sessions that are not covered by any available insurance shall be paid 60% by the Mother and 40% by the Father. 4. Pending further Order of this Court, this Court's prior Order of March 5, 2010, shall remain in place. 5. In order to facilitate communication between the parties, both parties shall exchange email addresses and shall communicate with each other on email in connection with matters pertaining to the children. BY THE COURT: M. L. Ebert, Jr., Judge cc: Diane M. Dils, Esquire -? ter? __;oV= Mr. Stephen G. Freeman y .? LYNELLE WAGNER, Plaintiff vs. STEPHEN G. FREEMAN, Defendant Prior Judge: the Honorable M. L. Ebert, Jr., : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2009-5364 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE 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: Sarah Elizabeth Freeman, born September 1, 2007 Rylie Mae Freeman, born August 30, 2008 2. A Conciliation Conference was held on April 3, 2012, with the following individuals in attendance: The mother, Lynelle Wagner, with her counsel, Diane M. Dils, Esquire and the father, Stephen G. Freeman, who appeared without counsel. 3. The Mother has petitioned to modify the existing custody Order which has been in place since 2010. Essentially, the existing arrangement is a 50-50 custody situation. 4. Father resides in Oberlin, Dauphin County, and Mother resides in Enola, Cumberland County. In light of the distance between the parties, it appears that one party will need to have primary custody since the older child will be starting school next September. Additionally, Mother suggests there are a number of reasons why she should have primary custody over the Father. Father disagrees with the Mother's position and is unwilling to agree on Mother's request for primary custody at this time. A hearing is required on that issue. 5. Mother also desires to have the children enrolled in counseling which the parties agreed to do at the conciliation conference. 6. The Conciliator recommends an Order in the form as attached. Date: April , 2012 Z?X Hubert X. Gilr, Esquire Custody Co iliator LYNELLE WAGNER Plaintiff vs. STEPHEN G. FREEMAN Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLV NO. 2009-5364 CIVIL ACTION - LAW :CUSTODY ORDER OF COURT S? AND NOW, this day of 1AI , 2012, after hearing in above matter, it is hereby ORDERED as follows: 1. Lynelle Wagner and Stephen G. Freeman shall share legal custody of children, Sarah Elizabeth Freeman born September 1, 2007 and Rylie T Freeman, born August 30, 2008. The parties agree that major decisi concerning the children's health, welfare, education, religious training upbringing shall be made by the parents jointly, after discussion consultation with each other, with a view towards obtaining and followir harmonious policy to arrive at a decision that is in the children's best inter Each party agrees to keep the other informed of the progress of the childrf education and social adjustments. Each party agrees not to impair the of parties' right to share legal custody of the children. Further, each party agi to give support to one another in the role as parents and to take into accc a 's the consensus of the other parent for the physical and emotional well being lof the children. The parties agree not to either attempt to alienate the affectic A , of the children from the other parent. Each party shall notify the other of activity that could reasonably be expected to be of significant concern to other. The parties agree that the children will be encouraged to contact other parent by telephone and e-mail at all reasonable times. Day to decisions shall be the responsibility of the parent then having phy custody. With regard to any emergency decisions, which must be made, t lie parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereb . However, that parent shall inform the other of the emergency and consult wi h him or her as soon as possible. Each party shall be entitled to complete ai full information from any doctor, dentist, teacher, professional or authori and to have copies of any reports given to either party as a parent. 2. Primary physical custody of Sarah Elizabeth Freeman, born September 2007 and Rylie Mae Freeman, born August 30, 2008 shall be in Lynelle Wagner effective Monday, August 20, 2012. 3. Father, Stephen G. Freeman, shall have partial custody as follows: a. Every other weekend commencing Friday, August 25, 2012 Friday at 4:30 p.m. until Sunday at 7:30 p.m. b. Every Wednesday from 4:30 p.m. until 7:30 p.m. c. At all other times as mutually agreed upon. I, ., 2 i . . 4. The parties shall share the holidays of Easter, Memorial Day, July 4th, Day and Thanksgiving. The parent who has the children on the before the holiday shall retain the children until either 1:00 p.m. or 2:00 p. (the exact time to be mutually agreed upon between the parties) on the day the holiday, at which time, the non-custodial parent shall obtain custody a retain the children for the remainder of the holiday. 5. Christmas shall be divided as follows: Segment A: From December 2 th until December 25th. Segment B: From December 25`h until December 26 h. The exchange time for the Christmas holiday shall be either 1:00 p.m. or 2: p.m., with the exact time to be mutually agreed upon between the parties. In even years, Mother shall have Segment A and Father shall have Segment 13. In odd years, Father shall have Segment A and Mother shall have Segment 13. This schedule simply continues what the parties have done over the last three years. 6. Mother's Day with Mother; Father's Day with Father. 7. The parties shall cooperate with counseling for the children, utilizing Meli Eash, Psychologist at Sheinvold and Associates. The parties shall confer N Ms. Eash to obtain her assistance and recommendations for additional periods of partial custody in Father, including, but not limited to the summer month.,;. The parties agree that they shall cooperate and follow any and a 1 recommendations of Ms. Eash. 3 1 8. Sarah Elizabeth Freeman shall attend the Cumberland Valley School Dis ct commencing the 2012-2013 school year, if Mother resides in said School District. If Mother is unable to secure residency within the Cumberland Valley School District by the commencement of the 2012-2013 school ye r, Sarah Elizabeth Freeman may attend St. Theresa's Catholic School until such time as Mother is able to secure residency in the Cumberland Valley Scho 1 District. 9. Mother and Father shall not use tobacco, alcohol or illegal the substances while the children are in their custody. Mother and Father prevent any other individual from using tobacco, alcohol or illegal chemi substances in the presence of the children to the extent possible. 10. The parties shall refrain making derogatory comments about the other party the presence of the children and to the extent possible, shall prevent thi parties from making such comments in the presence of the children or off harassment or interference with the parties' periods of partial custody. 11.It is the intention of the parties that the children be protected from individuals with poor character (including, but not limited to, individuals involved wi illegal activity, immoral or intemperate behavior or violent propensities). parties shall, to the extent possible, avoid contact with individuals of character. Violation of the provision set forth in this paragraph may considered contempt. 4 e . 12.The parties shall permit and support the children's access to fami?y relationships and events (funerals, reunions, graduations, etc.). Events will accommodated by both parties with routine periods of custody resumi immediately thereafter. Each party shall have the option of proposing time date variations to the other party when special recreational options or otl unexpected opportunities arise. 13.No party shall relocate the children if such relocation will significantly the ability of a non-relocating party to exercise his or her custodial unless (a) every person who has custodial rights to the child/children consen s to the proposed relocation or (b) the court approves the proposed relocatio . The party seeking relocation must follow the procedures required by Pa.C.S. §5337. BY THE COURT: ?AA The Honorable M.L. Ebert, Jr., Distribution: Diane M. Dils, Esquire, 1400 North Second St., Harrisburg, PA 17102 Stephen G. Freeman, 112 Summit Street, Oberlin, PA 17112 3 ?9p; es ka..' I Pd `d?llj _` zoo a. -r 5 LYNELLE WAGNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA f V. : NO.: 2009-5364 C t Z:; -� STEPHEN G. FREEMAN, : CIVIL ACTION-LAW -or Defendant : IN CUSTODY mm--<2> CA CiT r-z -ate c� C:) PETITION FOR CONTEMPT AND MODIFICATION OF EXISTING COIF ORDER < AND NOW, comes the Petitioner, Stephen G. Freeman, by and through his attorney Melanie L. Erb, Esquire and the Dethlefs-Pykosh Law Group, LLC who files this Petition for Contempt and Modification of Existing Custody Order and avers as follows: 1. Petitioner is Stephen G. Freeman, an adult individual currently residing at 112 Summit Street, Oberlin, Dauphin County, Pennsylvania 17113. 2. Respondent is Lynelle Wagner, an adult individual currently residing at 300 South Enola Drive, Enola, Cumberland County, Pennsylvania 17025. 3. The parties are the natural parents of two children, Sarah Elizabeth Freeman, born September 1, 2007 and Rylie Mae Freeman, born August 30, 2008. Attached hereto are marked Exhibit"A" is a copy of an Order of Court dated July 31, 2012. 4. Pursuant to said order, Petitioner/Father is to have periods of partial custody of the minor children every Wednesday from 4:30 p.m.until 7:30 p.m. 5. It is the Fathers belief that Respondent/Mother is out of town on a trip to Hong Kong from April 16, thru April 22, 2013. During that time, Father was denied his period of partial physical custody on Wednesday, April 17, 2013. 6. Further, rather than leaving the minor children with Father, Respondent/Mother left the children in the care of a family member. 3. 0 0 19 Cpl 38�6 7. Additionally, Section 8 of the July 31, 2012 Order states that the minor child, Sarah Elizabeth Freeman, shall attend the Cumberland Valley School District commencing the 2012-2013 school year unless the Mother is unable to secure residency and then she may attend St. Theresa's Catholic School. 8. In fact, minor child, Sarah Elizabeth Freeman, is currently attending St. Catherine Catholic School on Derry Street in Harrisburg, Pennsylvania. 9. Based on Respondents recent decisions regarding the care of the minor children and withholding custody of the minor children from Father during time allotted in the current custody order, it is believed and therefore averred that it is in the children's best interest that the Father be awarded primary physical custody of the minor children. WHEREFORE, Petitioner/Father, Stephen G. Freeman, respectfully request this Honorable Court enter an Order granting him primary physical custody of the minor children, Sarah Elizabeth Freeman and Rylie Mae Freeman. Respectfully Submitted, Date: e L. Erb Att rney ID # 84445 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 (717)975-9446 Attorney for Plaintiff VERIFICATION I, STEPHEN FREEMAN, verify that the statements made in the foregoing Petition for Modification of Existing Custody Order are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904,relating to unsworn falsification to authorities. STEPHEN FREEMAN DATE Melanie L. Erb, Esquire 2132 Market Street Camp Hill, PA 17011 717-975-9446 1Vlerb d,dplalaw.net LYNELLE WAGNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO.: 2009-5364 STEPHEN G. FREEMAN, : CIVIL ACTION—LAW Defendant : IN CUSTODY CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date, a true a correct copy of the foregoin- Order was served by first class mail upon the following: Diane M. Dils, Esquire 1400 North Second Street First Floor, Front Harrisburg, PA 17102 Date: � *aL. LYNELLE WAGNER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-5364 CIVIL ACTION LAW STEPHEN G.FREEMAN z:; -3r IN CUSTODY Z--M DEFENDANT Z::o ORDER OF COURT AND NOW, Wednesday,May 01,2013 upon consideration of the attachep o�Dlaiq'�- 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 Friday,May 24,2013 10:30 AM for a Pre-Hearing Custody Conference. At such conference,an effort will be made to resolve the issues in dispute; or if this cannot be accomplished,to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders,and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X Gilroy, Es L/ Custody Conciliator r 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, -fD Cumberland County Bar Association • 32 South Bedford Street ro?j Carlisle, Pennsylvania 17013 • Telephone (717)249-3166 5 , El& Tq e.1 an,e. EA LYNELLE WAGNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION-LAW C:: STEPHEN G. FREEMAN, NO. 2009-53064 MCC Defendant IN CUSTODY Z-� r— till ORDER C- C) AND NOW, this day of July, 2013, the Conciliator being advised-,-it�parries RL-V-e —i Z- �� reached an agreement and signed a stipulation, the Custody Conciliation scheduled &Rf4uly:12, 2013, has been cancelled and the Conciliator relinquishes jurisdiction. Hubert X. Gilroy,Y.-squire Custody Conciliat r