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HomeMy WebLinkAbout09-6530IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARTON R. CASHMAN, ) Plaintiff ) V. ) JAYME Y. CASHMAN, ) Defendant ) NO. 2009- 6520 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY STIPULATION FOR ENTRY OF AN AGREED ORDER OF CUSTODY AND NOW, this day of August, 2009, Plaintiff, (hereinafter "Father") and Defendant (hereinafter "Mother"), having reached an agreement regarding custody and the best interest and welfare of their minor child, they hereby stipulate and agree as follows: 1) Mother and Father shall have shared legal custody of Bella Julia Cashman, born December 29, 2005. 2) Mother shall have primary physical custody of Bella. 3) Father shall have periods of supervised visitation with Bella in accordance with the following stipulations: a. The visits will take place each Tuesday evening from 5:30 p.m. until 7:00 p.m. beginning on September 1, 2009. b. The visits will take place at the Fredricksen Public Library unless the parties agree to a different location. C. If Father is unable to make a visit, he must notify Mother as early as possible but no later than 3:45 p.m. d. Father shall ensure that his cellular phone has minutes available in case Mother needs to cancel a visit. e. If, by agreement, a visit is canceled, the parties shall reschedule make-up time. f. The parties agree that any discussion of activities that would lengthen the time of the visit or incorporate another activity such as getting something to eat with Bella will be discussed prior to the visit and not within Bella's presence. 4) A follow-up conference is scheduled between the parties and their counsel on December 9, 2009 at 4:00 p.m. at the office of Mother's counsel to discuss the status of the custody situation and determine whether it is appropriate to modify the schedule to increase Father's time for the supervised visits. 5) The parties shall have reasonable telephone contact with Bella. 6) This Stipulation is entered pursuant to an agreement of the parties. The parties may modify the provisions of this Stipulation by mutual consent. In the absence of mutual consent, the terms of this Stipulation shall control. 6adw- 2 " __A§. Barton R. Cashman Jayme Plaintiff Defen Jessica C. D. Holst, Es re Attorney for Plaintiff MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 1)1"-( R becca McClincy Darr, Esquire Attorney for Defendant Howett, Kissinger & Holst 130 Walnut Street, P.O. Box 810 Harrisburg, PA 17108 i I. il1H=??p? Z0?79 S4L:P 29 PN 2: 23 7 /' `' 04,11' lil:e c , 17o/ ( BARTON R. CASHMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09- CIVIL TERM JAYME Y. CASHMAN, Defendant CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Barton R. Cashman, Petitioner, to proceed in forma ap uperis. I, Nicholas M Matash, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Nicholas M Matash, Esquire Geoffrey M Biringer, Esquire Abraham Prozesky, Esquire MidPenn Legal Services 401 East Louther Street Carlisle PA 17013 (717) 243-9400 n RLEL fr, } V !E °; t' `? iAr?Y 2009 SEE 29 P 2: 26 1 1'. ?1 14 ? 'ill 1 i ??}. !f BARTON R. CASHMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09- & S30 CIVIL TERM JAYME Y. CASHMAN, Defendant : CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Barton R. Cashman, (Father). Father resides at 400 South Enola Drive - Apt 1, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Jayme Y. Cashman, (Mother). Mother resides at 49 Circle Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Father seeks periods of supervised visitation of the minor child: Name Present Residence Age Bella Julia Cashman 49 Circle Drive 12.29.05 DOB, 31/a yrs old Camp Hill, PA 17011 Bella was born during the parties' marriage. Bella is presently in the custody of Mother. During her lifetime, Bella has resided with the following persons and at the following addresses: Name Address Date Barton Cashman 4808 Virginia Road birth - summer 2007 Jayme Cashman Mechanicsburg, PA Jayme Cashman 4808 Virginia Road summer 2007 - fall 2008 Mechanicsburg, PA Jayme Cashman 49 Circle Drive fall 2008 - present Camp Hill, PA The parties were divorced on November 27, 2007. 4. Mother resides with the following persons: Name Relationship Bella Cashman Child with Barton Cashman 5. Father presently lives alone. 6. Father has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of Bella in this or another court but there is an existing Marital Settlement Agreement that was incorporated into the Divorce Decree. As part of the Marital Settlement Agreement, there were terms for a custody arrangement but the parties have agreed that this new action will superscede the custody terms in the Marital Settlement Agreement. 7. Father has no information of a current custody proceeding concerning Bella pending in a court of this Commonwealth. 8. Father does not know of a person not a party to the proceedings who has physical custody of Bella or claims to have custody or visitation rights with respect to Bella. 9. The best interest and permanent welfare of Bella will be served by granting the relief requested because it will encourage and nurture the father/daughter relationship and ensure ongoing interaction between Father and Bella in a manner that is agreed to by both parties during time periods in which Father is physically and emotionally capable of focusing on the father/daughter relationship. 10. Every person with rights to custody or having actual physical custody of Bella has been named as parties to this action. WHEREFORE, Father requests this Court to grant him the following relief: 1) Grant the parties shared legal custody of Bella. 2) Grant Mother primary physical custody of Bella. 3) Grant Father periods of supervised visitation with Bella. 4) Any further relief that this Court finds to be just and proper. Td ca Holst, Esquire Penn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 r VERIFICATION The above-named PLAINTIFF, BARTON R. CASHMAN, verifies that the statements made in the above COMPLAINT FOR CUSTODY are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: / 2- 2 on / 0 q LA??- F(- v BARTON R. CASHMAN Olt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARTON R. CASHMAN, ) Plaintiff ) NO. 2009- CIVIL TERM V. ) JAYME Y. CASHMAN, ) CIVIL ACTION - LAW Defendant ) IN CUSTODY ORDER OT.- AND NOW, this ?t day of Atrgt?st, 2009, on consideration of the attached Stipulation, it is hereby ORDERED and DECREED that the terms and conditions of the aforementioned stipulation are hereby entered as an Order of Court. stribution: Je ica C. D. Holst, Esquire, MidPenn Legal Services, 401 E. Louther St., Carlisle, PA 17013 ebecca McClincy Darr, Esquire, Howett, Kissinger & Holst, 130 Walnut Street - P.O. Box 810, Harrisburg, PA 17108 BY THE COURT: FILED-OffIC'E OF THE PR07}- O NARY 2009 OCT -S PM 2: 4 7 P E ?EN S `I L VNNI A Scaringi & Scaringi, P.C. Debra R. Mehaffie, Esquire 2000 Linglestown Road, Suite 106 Harrisburg, Pa 17110 Tele: (717) 657-7770 Fax: (717) 657-7797 debra&scaringi law, com Attorney for Bradley and Susan Cashman BARTON R. CASHMAN, Plaintiff -v- JAYME Y. CASHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2009-6530 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PETITION TO INTERVENE IN CUSTODY ACTION PURSUANT TO 23 Pa. C.S. §5312 AND MODIFY CUSTODY ORDER AND NOW come Petitioners Bradley R. Cashman and Susan K. Cashman, by and through their counsel, Debra R. Mehaffie, Esquire and Scaringi & Scaringi, P.C. and request that this Honorable Court grant them permission to intervene in the above-captioned custody matter and modify the current Custody Order and in support thereof avers as follows: 1. The Petitioners are Bradley R. Cashman and Susan K. Cashman, who reside at 22 Arlington Drive, Carlisle, Pennsylvania. Your Petitioners are the paternal grandparents of Bella Julia Cashman, born December 29, 2005, who is the subject minor child in this custody action. 2. Respondent Barton R. Cashman is the natural father of Bella and he resides at 400 South Enola Drive, Apartment 1, Enola, Pennsylvania. 3. Respondent Jayme Y. Cashman is the natural mother of Bella and she resides at 49 Circle Drive, Camp Hill, Pennsylvania. 4. On or about August 31, 2009 Mother and Father reached an agreement regarding custody of Bella, which was embodied in a Stipulation for Entry of an Agreed Upon Order of Custody. Said Agreement provides in pertinent part that Mother and Father share legal custody, Mother has primary physical custody of the child, and Father has periods of supervised visitation at the Frederickson Public Library, unless the parties agree to a different location. A copy of the Stipulation is attached hereto and marked as Exhibit "A" and incorporated herein by reference. 5. The terms and conditions of the parties' Stipulation were entered as an Order of this Honorable Court on October 5, 2009. A copy of said Order dated October 3, 2009 is attached hereto and marked as Exhibit "B". 6. Petitioners seek to intervene in the above-captioned custody matter pursuant to 23 Pa C.S. §5312, which provides: In all proceedings for dissolution, subsequent to the commencement of the proceedings and continuing thereafter or when parents have been separated for six months or more the court may, upon application f the parent or grandparent of a party, grant reasonable partial custody or visitation rights, or both, to the unmarried child if it finds that visitation rights or partial custody, or both, would be in the best interest of the child and would not interfere with the parent-child relationship. The court shall consider the amount of personal contact between the parents or grandparents of the party and the child prior to the application. 7. Mother and Father separated more than six (6) months prior to Petitioner's request to intervene in this custody matter. 8. Petitioners respectfully request that the current Custody Order be modified to allow Petitioners reasonable partial custody rights to Bella because it will be in her best interest to spend regular periods of time with her grandparents: a.) Bella and her grandparents have a strong and loving bond that should not be broken; b.) Bella enjoys spending time with her grandparents and has expressed a desire to spend regular periods of uninterrupted time with her grandparents; c.) Grandparents can offer a safe and secure environment for Bella to enjoy periods of partial custody; d.) Grandparents seek to encourage a positive relationship between Bella and her parents; e.) Mother has previously threatened to withhold Bella from her grandparents when Petitioners expressed concerns about the amount of money that grandparents provided to Father for Bella's daycare; £) Up until recently, Mother has permitted Bella to spend uninterrupted periods of time with Petitioners, which included overnights; g.) Mother has unilaterally ceased visits with Bella and her grandparents; h.) Petitioners believe that Mother is retaliating against Petitioners because they expressed concerns about the increased costs that they provided to Father for Bella's daycare. Additionally, Mother is angry because Petitioners paid for Father to have legal representation in his support case; i.) Petitioners believe that Mother's actions of depriving Bella of spending quality time with her grandparents is retaliatory in nature and not in Bella's best interests; j.) Father does not object to Petitioners spending quality time with Bella and he supports Petitioners' request for reasonable periods of partial custody; 9. Petitioners submit that it would not interfere in the parent-child relationship for Bella to spend regular periods of time with her grandparents. 10. Petitioners are requesting an Order of Court that provides for regular periods of partial custody and respectfully suggests the following schedule: a.) November 27, 2009 at 1:00 p.m. until November 29, 2009 at 12:00 p.m. so that Bella can participate as a flower girl, as previously agreed upon, in her uncle's wedding rehearsal and wedding; b.) December 26, 2009 from 10:00 a.m. until December 27, 2009 at 12:00 p.m. so that Bella can attend the Cashman Christmas Celebration. In subsequent years, Bella shall be permitted to enjoy the same schedule with her grandparents so that she can attend this annual celebration; c.) Beginning in December 2009, two (2) consecutive days between Christmas Day and New Year's Day, beginning at 10:00 a.m. on the first day and ending at 7:00 p.m. on the second day, to celebrate Bella's birthday; d.) Beginning January 2010, every Wednesday from immediately after daycare and / or school until 7:00 p.m.; e.) Beginning January 2010, one weekend consisting of Friday immediately after daycare and / or school until Sunday at 7:00 p.m., with the option to extend the weekend to Monday at 7:00 p.m. for Monday holidays; f.) Beginning April 2010, the Saturday immediately prior to Easter from 10:00 a.m. until 7:00 p.m. so that Bella can participate in the Cashman Easter Celebration and / or Egg Hunt; g.) Beginning in 2010, Mother and Grandparents shall alternate Memorial Day, Independence Day (Observed) and Labor Day on an annual basis, beginning with Mother having Memorial Day in 2010. It is respectfully suggested that the period run from 10:00 a.m. until 7:00 p.m.; h.) Beginning in 2010, six (6) consecutive days of uninterrupted time during the summer beginning on Sunday at 7:00 p.m. and continuing until the following Saturday at 7:00 p.m. Grandparents shall provide Mother and Father with written notice of the dates they intend to exercise this provision at least thirty (30) days prior to the period; i.) Beginning in November 2010, Thanksgiving Eve immediately after daycare and /or school until 7:00 p.m. on Thanksgiving Day; and j.) It is respectfully suggested that the parties share transportation, with the party obtaining custody providing transportation. WHEREFORE, Petitioners respectfully requests this Honorable Court to grant them permission to intervene in the above-captioned custody matter, grant Petitioners reasonable periods of partial custody of their granddaughter Bella Julia Cashman and grant any other relief deemed appropriate by this Court. Respectfully submitted: Date: 1) l 0 / i , ,Ve 'K. Mehathe, Esquire I. J0. No. 90951 lJ 00 Linglestown Road, Suite 106 Harrisburg, Pa 17110 Attorney for Petitioners BARTON R. CASHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA -v- : No. 2009-6530 CIVIL TERM JAYME Y. CASHMAN, : CIVIL ACTION - LAW Defendant : IN CUSTODY VERIFICATION We, Bradley R. Cashman and Susan K. Cashman, verify that the statements made in this Petition to Intervene and Modify Custody are true and correct to the best of our knowledge, information and belief. We understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: Date: /0 / C 7 a0© ? ?\'S" "'k? C-? L 4?n Susan K. Cashman BARTON R. CASHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA -v- : No. 2009-6530 CIVIL TERM JAYME Y. CASHMAN, : CIVIL ACTION - LAW Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Amanda L. Emerson, Paralegal, do hereby certify that on this date, I served the forgoing Petition to Intervene and Modify Custody, in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Jessica C.D. Holst, Esquire MidPenn Legal Services 401 East Louther Street Carlisle, Pa 17013 (Counsel for Father) Rebecca McClincy Darr, Esquire Howett, Kissinger & Holst 130 Walnut Street P.O. BOX 810 Harrisburg, Pa 17108 (Counsel for Mother) Dated: October 6, 2009 Amanda L. Emerson, Paralegal Scaringi & Scaringi, P.C. Exhibit "A" )N THE COURT OF COMMON PLEAS OF CUM13ERLAND COUNTY, PENN?YLVXgA, 13ARTON R. CASHMAN, Plaintiff NO. 2009- CIVIL XFRM V. JAYME Y. CASHMAN, ) CIVIL ACTION - LAW Defendant ) IN CUSTODY STIPUL ION ]FOR ENTRY OF AN AGREED ORDER OF CUSTODY AND NOW, this day of August, 2009, Plaintiff, (hereinafter "Father") and Defendant (hereinafter 'Mother'), having reached an agreement regarding custody and the best interest and welfare of their minor child, they hereby stipulate and agree as follows: 1) Mother and Father shall have shared legal custody of Bella Julia Cashman, born December 29, 2005 2) Mother shall have prui nary physical custody of Bella. 3) Father shall have periods of supervised visitation with Bella in accordance with the following stipulations: a. The visits will take place each Tuesday evening from 5:30 p.m. until 7.00 p.m. beginning on September 1, 2009. b. The visits will take place at the Fredricksen Public Library unless the parties agree to a different location. C. If Father is unable to make a visit, he must notify Mother as early as possible but no later than 3:45 p.m. 771 -.7 CfAfA 1S'fAfA-T CRA_ T _TIOUJ 7r,' Mr Cn -TM-OT d. Father shall ensure that his cellular phone has minutes available in case Mother needs to cancel a visit. e. If, by agreement, a visit is canceled, the parties shall reschedule make-up time. f The parties agree that any discussion of activities that would lengthen the time of the visit or incorporate another activity such as getting something to eat with Bella will be discussed prior to the visit and not within Bella's presence. 4) A follow-up conference is scheduled between the parties and their counsel on December 9, 2009 at 4:00 p.m. at the office of Mother's counsel to discuss the status of the custody situation and determine whether it is appropriate to modify the schedule to increase Father's time for the supervised visits. 5) The parties shall have reasonable telephone contact with Bella. 6) This Stipulation is entered pursuant to an agreement of the parties. The parties may modify the provisions of this Stipulation by mutual consent. In the absence of mutual consent, the terms of this Stipulation shall control. Barton R. Cashman plaintiff r3 QiU i IBC Jessica C. D. st, Esgi Attorney for P aintiff MidPenn Legal Services 401 Fast Louther Street Carlisle, P.A. 17013 771-.7 rRVi /f7nPIrT QfiR- T -Gng4 7f= : PIT PPI .-TPI-PIT Attorney for Defendant Howett, Kissinger & Holst 130 'W'alnut Street, P. 0. Box 810 Harrisburg, PA 17108 Exhibit "B" 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARTON R. CASHMAN, Plaintiff V. JAYME Y. CASHMAN, Defendant NO. 2009-_j6_ CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this '3T da of O G y t, 2009, on consideration of the attached Stipulation, it is hereby ORDERED and DECREED that the terms and conditions of the aforementioned stipulation are hereby entered as an Order of Court. Holst, Esquire, MidPenn Legal Services, 401 E. Louther St., Carlisle, PA 17013 cca McClincy Darr, Esquire, Howett, Kissinger & Holst, 130 Walnut Street - P.O: Box 810, Harrisburg, PA 17108 E S' /'rid-t (20 F ?stribution: ? J ica C. D. e BY THE COURT: OF 713 P Fr -?. _ . OTARY ' 14 11 1009 OCT -9 FIN 3: 11 *70. 00 Al't" 1 ev,* 5g35 04 a31`7tq BARTON R. CASHMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-6530 CIVIL ACTION LAW JAYME Y. CASHMAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, October 21, 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, November 12, 2009 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, Es q. 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 OF FILL! J (5 r COf TH ?nF r?q ?r???R f 2009 OC T 21 PM 4. p 1 Cul?j., N apt/ - olf'Cw 4 ?%` /o -ter ©y 2009 ,? BARTON R. CASHMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYl VANIA VS. : CIVIL ACTION - LAW JAYME Y. CASHMAN, NO. 2009-6530 Defendant IN CUSTODY COURT ORDER AND NOW, this l? day of November, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's prior Order of October 3, 2009, is to remain in place subject to the following additional modifications: 1. On every Tuesday, the Father's periods of time with the minor child shall be from Tuesday at 4:30 p.m. until 7:30 p.m. with the understanding that the Paternal Grandparents will be involved in that visitation and the further understanding that the Paternal Grandparents will be the supervisor for that visitation as consistent with the prior Order. In the event the Father is not available on that Tuesday because of work schedule or other circumstances, the parties shall communicate between themselves to reschedule an evening for that week. 2. The Paternal Grandparents shall have custody of the minor child Friday, November 27, 2009, from 3:00 p.m. until Saturday, November 28, 2009, at 9:00 p.m. 3. The Paternal Grandparents shall also have custody on Friday, December 18, 2009, at 4:30 p.m. until that Sunday, December 20, 2009, at 6:00 p.m. 4. The Paternal Grandparents shall also enjoy custody of the minor child on December 26, 2009, from 11:00 a.m. until 7:00 p.m. 5. Starting in January, 2010, the Paternal Grandparents shall have custody for one weekend per month from Friday at 4:30 p.m. until Sunday at 6:00 p.m. on a weekend as agreed upon by the parties. 6. The Mother shall ensure that the Father and Paternal Grandparents are advised with respect to the children's activities such as plays, soccer games, etc., that they may be able to attend to watch their grandchild or his daughter. 7. Legal counsel for the parties shall conduct a telephone conference with the Custody Conciliator on Thursday, March 3, 2010, at 8:00 a.m. At that time and in the event the parties are unable to reach an agreement on a more permanent Order, the Conciliator can schedule another custody conciliation conference or schedule a hearing as may be necessary. In the event there are any major issues between the parties that legal counsel feel the Conciliator can resolve, legal counsel for the parties may contact the Custody Conciliator directly to schedule a telephone conference call in advance of the March 3, 2010, date. 8. The parties may modify the above schedule as they agree. Absent an agreement, the parties shall follow the above schedule subject to any further modification of the schedule by Court Order. Z cc: ana Walter, Esquire 3ebecca bra R. Mehaffie, Esquire McClincy Darr, Esquire c 6ES ?'Nt`dL I!/ l 81cq ??l BY THE COURT, C BARTON R. CASHMAN, Plaintiff VS. JAYME Y. CASHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2009-6530 IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. 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 child who is the subject of this litigation is as follows: Bella Julia Cashman, born December 29, 2005 2. A Conciliation Conference was held on November 12, 2009, with the following individuals in attendance: The mother, Jayme Y. Cashman, who appeared with her counsel, Rebecca McClincy Darr, Esquire, the father, Barton R. Cashman, with his counsel, Shana Walter, Esquire, and the paternal grandparents, Bradley R. Cashman and Susan K. Cashman, with their counsel, Debra R. Mehaffie, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date: November / 3 , 2009 Hubert X. Gilroy, Custody Concilial of n+en r 2009 NOV 18 PM 3: 27 CUMBE, '4u ""BOUNTY PENNSYLVANIA JUN 15 2010 BARYON R. CASHMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW JAYME Y. CASHMAN, NO. 2009-6530 Defendant IN CUSTODY ORDER / ,~4 AND NOW, this [ ~ day of June, 2010, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. Hubert X. Gilroy, Custody Concili~k c7 ~ -; ~, =,, (7yi t A `fit -~. ~ r°' -,~ . "„~ ) y ty-' ~_. ~ '~ 1 ( F --( R ~ ~~ "'.~. BARTON R. CASHMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA -v- : No. 2009-6530 CIVIL TERM JAYME Y. CASHMAN, : CIVIL ACTION - LAW Defendant : IN CUSTODY BRADLEY R. CASHMAN and SUSAN''K. CASHMAN Defendants/ Intervenors PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Mary K. Lemmon, Esquire, as attorney in the above- captioned action for Defendants, Bradley R. Cashman and Susan K. Cashman, per their request. Respectfully submitted, Date: //., 5--16 12, Mary K. Lemmon, 9squire Attorney I.D. No. 70923 Scaringi & Searingi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 (717) 657-7770 a CERTIFICATE OF SERVICE I hereby certify that I served the foregoing Praecipe'to Enter to Plaintiff and Co- Defendant by United States Postal Service, regular mail, postage prepaid, addressed as follows: Jessica Holst, Esquire 401 East Louther Street Carlisle, PA 17013 Donald Kissinger, Esquire 130 Walnut Street Harrisburg, PA 17108 Date: / j!j-U f C) Respectfully submitted, Desiree Brougher, Law Cler Scaringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 (717) 657-7770