HomeMy WebLinkAbout09-7373{ N
CALVIN W WILLIAMS, III,
Plaintiffs
V.
ELIZABETH PEREZ,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Q 9" 73 7 3 ct??
CIVIL ACTION - LAW
IN CUSTODY
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND
AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST
TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND
NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE
PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE
MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED
AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY
MONEY CLAIlVIED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR
RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR
PROPERTY OR OTHER RIGHTS IlVIPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE
TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
717-249-3166
CALVIN W WILLIAMS, III, IN THE COURT OF COMMON PLEAS
Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. oq- 737-1 cl?a-
ELIZABETH PEREZ, CIVIL ACTION - LAW
Defendant IN CUSTODY
COMPLAINT FOR CUSTODY
1. The Plaintiff CALVIN W WILLIAMS, III, residing at 149 SOUTH LOCUST
POINT ROAD, MECHANICSBURG, CUMBERLAND COUNTY,
PENNSYLVANIA,17055.
2. The Defendant is ELIZABETH PEREZ, residing at 325 9T" STREET, NEW
CUMBERLAND, CUMBERLAND COUNTY, PENNSYLVANIA, 17070.
3. Plaintiff seeks custody of the following children:
children
LUKE A WILLIAMS
Date of Birth
October 25 2008
The child was born out of wedlock. The child has been in the primary custody of
Defendant.
During the past five years, the child has resided with the following persons and at
the following addresses:
NAME
RESIDENCE DATES
Elizabeth Perez 325 9th Street May 2008 to present
Hector Arrocho New Cumberland, PA 17070
Destiny Arrocho
The mother of the child is Defendant, Elizabeth Perez, single.
4. The relationship of Plaintiff to the child is that of father. Plaintiff currently
resides with two of his daughters, Riley L Williams, DOB 8/30/01 and Magill M Williams,
DOB 6/13/03.
l .
4. The relationship of Plaintiff to the child is that of father. Plaintiff currently resides
with two of his daughters, Riley L Williams, DOB 8/30/01 and Magill M Williams, DOB
6/13/03.
5. The relationship of Defendant to the child is that of mother currently
residing with two of her children, Hector and Destiny Arrocho along with the subject
minor child, Luke A. Williams.
6. Plaintiff has not participated as a party or witness, or in another capacity,
in other litigation concerning the custody of the child in this or another court. Plaintiff
has no information of a custody proceeding concerning the child pending in a court of
this Commonwealth.
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.
7. The best interests and permanent welfare of the child will be served by
granting the relief requested because since the child's birth, Defendant has been denied
uninterrupted periods of custody with his son.
8. Each parent whose parental rights to the child has not been terminated
and the person who has physical custody of the child has been named as parties to this
e 1.
action. All other persons, named below, are known to have or claim a right to custody
or visitation of the child will be given notice of the pendency of this action and the right
to intervene. None.
WHEREFORE, Plaintiff requests the court to grant the relief herein requested.
Respectfully submitted,
MILLER LIPSITT LLC
James A. Miller, Esquire
765 Poplar Church Road
Camp Hill, PA 17011
717) 737-6400
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.
D
ATE. Wednesday, October 21, 2009
CALVIN W WILLIAMS, III, PLAINTIFF
OF THE PAO?TARY
2609 OCT 27 AM 9: 37
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CALVIN W. WILLIAMS, III IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2009-7373 CIVIL ACTION LAW
ELIZABETH PEREZ IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Thursday, October 29, 2009 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, December 01, 2009 at 1:30 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/ Dawn S. Sunday, 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 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
FILED-4, kRCE
OF THE t THCNO ARY
2009OCT 29 PM 3: 28
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PEWi, ?p. ?Y7'SI "ill'1
CALVIN W WILLIAMS, III,
•
•
IN THE COURT OF COMMON PLEAS
Plaintiffs •CUMBERLAND COUNTY, PENNSYLVIIA�, s...
V. NO. 2009-7373 Civil Action LawNa
CIS r -
ELIZABETH PEREZ,
Defendant • IN CUSTODYcp
PETITION TO MODIFY CUSTODY
NOW COMES Petitioner, Calvin W Williams III, by and through his attorneys,'
Miller Lipsitt LLC and James A Miller, Esquire, and respectfully requests that your
Honorable Court modify the existing custody order and for reasons therefor states:
1. Petitioner is Calvin W Williams III (hereinafter "Father").
2. Respondent is Elizabeth Perez (hereinafter "Mother") currently
incarcerated at the Cumberland County Prison, 1101 Claremont Road, Carlisle, PA
17105 and formerly resided at 423 Fourth Street, New Cumberland, PA 17070. Upon
her release on or about September 2, 2014, it is believed and therefore averred that she
will again reside at said address.
3. The parties are the natural parents of the minor child, Luke A Williams,
DOB 10/25/08.
4. On March 23, 2010, an Order of Court for Custody in the above entitled
action was entered (See attached Exhibit A — March 23, 2010, Order of Court).
5. Since the entry of said Order, circumstances have changed requiring
modification to the custodial periods.
L483 Pd 1717
et97 2 2_
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6. Petitioner historically had been consistently and regularly denied by
Respondent his court ordered custodial periods and any other requested custodial
periods. Moreover, Respondent has been repeatedly incarcerated during her periods of
primary physical custody thereby making Petitioner's custodial periods practically
impossible to exercise at any given time. Respondent is expected to be released from
prison on or about the beginning of September 2014 and Petitioner must maintain his
relationship with his young son.
7. Your Honorable Court has the authority to grant the relief requested
herein.
WHEREFORE, Father respectfully requests your Honorable Court to modify the
current court order to reflect shared legal and physical custody with a week on and
week off schedule.
Respectfully submitted,
Miller Lipsitt LLC
Miller, Esquire
Street
amp Hill, PA 17011
(717) 737-6400
VERIFICATION
verify that the statements made in the attached Petition 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.
DATE:
Calvin W Williams, III
► oAR 2'2 201U
CALVIN W. WILLIAMS, III IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
ELIZABETH PEREZ ,
2009-7373 CIVIL ACTION LAW
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this &2/2.4-- day of , , 2010, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated December 7, 2009 shall continue in effect as modified
by this Order.
2. Paragraph 3 of this Court's prior Order dated December 7, 2009 is deleted and replaced with
the following: The Father shall have partial physical custody of the Child on alternating weekends
from Saturday at 10:00 a.m. through Sunday at 9:30 a.m. The Father may have the option of having
custody of the Child after the Mother takes the Child to church on Sunday as arranged by agreement
between the parties: In addition, the Father shall have custody of the Child on the interim weekends on
Sunday from 1:00 p.m. until 7:00 p.m., beginning Sunday, March 21, 2010.
3. The parent receiving custody of the Child shall be responsible to provide transportation for
the exchange of custody.
4. The parties shall share having custody of the Child on holidays as arranged by agreement.
5. This Order is entered pursuant to an agreement of the parties at 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,
/fr �C,pil�
/K vin A. Hess
cc:: James A. Miller, Esquire — Counsel for Father
Elizabeth Perez - Mother
exhibit A
TRVE:COPV.FROM RECORD
In TestimonyWwhen4 Oars unto set my hand
andihe seal .f Pa.
This Prothonotary
CALVIN W. WILLIAMS, III IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
2009-7373 CIVIL ACTION LAW
ELIZABETH PEREZ
Defendant IN CUSTODY
Prior Judge: Kevin A. Hess
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
Luke A. Williams
DATE OF BIRTH CURRENTLY IN CUSTODY OF
October 25, 2008 Mother
2. A custody conciliation conference was held on March 17, 2010, with the following
individuals in attendance: the Father, Calvin W. Williams, III, with his counsel, James A. Miller,
Esquire, and the Mother, Elizabeth Perez, who is not represented by counsel in this matter.
3. The parties agreed to entry of an Order in the form as attached.
Ai7 (-2-0I U
Date
Dawn S. Sunday, Esquire
Custody Conciliator
Calvin W Williams, III
. IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PA
Vs
Elizabeth Perez
. No. 2009-7373 CIVIL TERM
. CIVIL ACTION - LAW
Defendant IN CUSTODY
CRIMINAL RECORD / ABUSE HISTORY VERIFICATION
1, Calvin W Williams III , hereby swear or affirm, subject to penalties of
law including 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities that:
1. Unless indicated by my checking the box next to a crime below, neither I nor any other
member of my household have been convicted or pled guilty or pled no contest or was
adjudicated delinquent where the record is publicly available pursuant to the Juvenile
Act 42 Pa.C.S. § 6307 to any of the following crimes in Pennsylvania or a substantially
equivalent crime in any other jurisdiction, including pending charges:
Check
all that
apply
Crime
Self Other Date of Sentence
household conviction,
member guilty plea, no
contest plea or
pending charges
18 Pa.C.S. Ch. 25 E E
(relating to criminal
homicide)
18 Pa.C.S. §2702 r--_, E
(relating to aggravated
assault)
18 Pa.C.S. §2706 r
(relating to terroristic
threats)
1-17 18 Pa.C.S. §2709.1
(relating to stalking)
18 Pa.C.S. §2901
(relating to kidnapping),
0
18 Pa.C.S. §2902
(relating to unlawful
restraint)
7.1 18 Pa.C.S. §2903 7,
(relating to false
imprisonment)
18 Pa.C.S. §2910 ET
(relating to luring a
child into a motor
vehicle or structure)
18 Pa.C.S. §3121
(relating to rape)
18 Pa.C.S. §3122.1
relating to statutory
sexual assault)
7_ 18 Pa.C.S. §3123
(relating to involuntary
deviate sexual
intercourse),
EI 18 Pa.C.S. §3124.1 r7.7
(relating to sexual
assault)
JT 18 Pa.C.S. §3125
(relating to aggravated
indecent assaulti
18 Pa.C.S. §3126
(relating to indecent
assault)
,18 Pa.C.S. §3127
(relating to indecent
exposure)
18 Pa.C.S. §3129
(relating to sexual
intercourse with animals)
18 Pa.C.S. §3130 IT
(relating to conduct
relating to sex
offenders)
18 Pa.C.S. §3301
(relating to to arson and
related offenses)
EJ 18 Pa.C.S. §4302 .177
(relating to incestl
18 Pa.C.S. §4303
(relating to concealing
death of child)
18 Pa.C.S. §4304
(relating to endangering
welfare of children)
18 Pa.C.S. §4305 IT
(relating to dealing
in infant children)
fl 18 Pa.C.S._§5902(b) tT
(relating to prostitution
and related offenses)
18 Pa.C.S. §5903
(c) or (d)
(relating to obscene
and other sexual materials
and performances1
18 Pa.C.S. §6301
(relating to corruption
of minors)
18 Pa.C.S. §6312
(relating to sexual
abuse of children'
18 Pa.C.S. §6318
(relating to unlawful
contact with minor"
17.17 18 Pa.C.S. §6320
(relating to sexual
exploitation of children'
23 Pa.C.S. §6114
(relating to contempt for
violation of Protection
order or agreement)
EJ Driving under the
influence of drugs
or alcohol
Manufacture, sale,
delivery, holding,
offering for sale or
possession of any
controlled substance or
other drug or device
2. Unless indicated by my checking the box next to an item below, neither I nor any other
member of my household have a history of violent or abusive conduct including the
following:
Check
all that
apply
Self Other
household
member
17.7 A finding of abuse by a Children & Youth
Agency or similar agency in Pennsylvania
or similar statute in another jurisdiction
17.7. Abusive conduct as defined under the 1.7
Protection from Abuse Act in
Pennsylvania or similar statute in
Date
another jurisdiction
Other: 7
3. Please list any evaluation, counseling or other treatment received following conviction
or finding of abuse:
4. If any conviction above applies to a household member, not a party, state that person's
name, date of birth and relationship to the child :
5. If you are aware that the other party or members of the party's household has or have a
criminal / abuse history, please explain:
I verify that the information above is true and correct to the best of my knowledge
information or belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. § 4904 relating to unsworn falsificatLon to a thorities.
Signature
Calvin W Williams III
Printed Name
CALVIN W. WILLIAMS, III IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
V.
ELIZABETH PEREZ
DEFENDANT
CUMBERLAND COUNTY, PENNSYLVANI4
rrl
(n1-
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: 2009-7373
nr--
2009-7373 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, August 22, 2014
act
ra
, upon consideration of the attached Complaint, it is
hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, September 18, 2014 11:30 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.
You must file with the Court a verification regarding any criminal record or abuse history regarding you and
anyone living in your household on or before the initial in-person contact with the court (including, but not limited to,
a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition.
No party may make a change in the residence of any child which significantly impairs the ability of the other party
to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and
Pa.R.C.P. No. 1915.17 regarding relocation.
FOR THE COURT,
By: /s/ Dawn S. Sunday, Esq. yl t,,//
Custody Conciliator I�
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.
co t£S'a.i
1441,f-1 Stwoclay
'V4.1"Y
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
CALVIN W. WILLIAMS, III IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
ELIZABETH PEREZ
2009-7373
Defendant IN CUSTODY
ORDER OF COURT
CIVIL ACTION L) s rt
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AND NOW, this /Id day of �`�v , 2014, upon consideration
of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated March 23, 2010 is vacated and replaced with this Order.
2. The prior Order of this Court dated December 7, 2009 shall continue in effect as modified
by this Order.
3. The Mother, Elizabeth Perez, and the Father, Calvin W. Williams III, shall have shared legal
custody of Luke A. Williams, born in 2008. Major decisions concerning the Child including, but not
necessarily limited to, his health, welfare, education, religious training and upbringing shall be made
jointly by the parties after discussion and consultation with a view toward obtaining and following a
harmonious policy in the Child's best interests. Neither party shall impair the other party's rights to
shared legal custody of the Child's. Neither party shall attempt to alienate the affections of the Child
from the other party. Each party shall notify the other of any activity or circumstance concerning the
Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be
the responsibility of the parent then having physical custody. With regard to any emergency decisions
which must be made, the parent having physical custody of the Child at the time of the emergency
shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall
inform the other of the emergency and consult with him or her as soon as possible. In accordance with
23 Pa.C.S.A. §5336, each party shall be entitled to complete and full information from any doctor,
dentist, teacher, professional or authority and to have copies of any reports or information given to
either party as a parent as authorized by statute.
4. The Mother shall continue to have primary physical custody of the Child.
5. Paragraph 3 of this Court's prior order dated December 7, 2009 is deleted and replaced with
the following: The Father shall have partial physical custody of the Child on alternating weekends
from Friday at 5:00 p.m. through Tuesday at 5:00 p.m. beginning Friday, September 26, 2014.
6. The Father shall be responsible to provide transportation for all exchanges of custody unless
otherwise agreed between the parties.
7. The noncustodial parent shall be entitled to have liberal reasonable telephone contact with
the Child.
8. In the event either party anticipates that he or she will be late for an exchange of custody,
that party shall notify the other parent immediately by telephone or text message of the time that he or
she will arrive. Each party shall allow the other parent a 30 minute delay period before making other
arrangements for the Child during the missed period of custody.
9. The Mother shall have custody of the Child every year on Mother's Day and the Father shall
have custody on Father's Day from 9:00 a.m. until 5:00 p.m. The parties shall share having custody of
the Child on the remaining holidays as arranged by agreement.
10. During any period of custody, the parties shall not possess or use illegal controlled
substances or consume alcoholic beverages to the point of intoxication. The parties shall ensure that
other household members and house guests comply with this prohibition.
11. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
12. No party shall be permitted to relocate the residence of the Child which significantly
impairs the ability to exercise custody unless every individual who has custodial rights to the Child
consents to the proposed relocation or the Court approves the proposed relocation. A person proposing
to relocate MUST comply with 23 Pa. C.S. § 5337.
13. The Mother may file a Petition with the Court for the scheduling of an additional custody
conciliation conference if she desires to have a review of the custodial arrangements set forth in this
Order.
14. 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,
cc: Vmes A. Miller Esquire — Counsel for Father
Elizabeth Perez — Mother
� ies ►'�"L1ai��l�
a3py
6`17ti-t- -il6e/(__
CALVIN W. WILLIAMS, III IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
ELIZABETH PEREZ
Defendant
Prior Judge: Kevin A. Hess
2009-7373 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
Luke A. Williams
BIRTH YEAR CURRENTLY IN CUSTODY OF
2008 Mother
2. A custody conciliation conference was held on September 18, 2014, with the following
individuals in attendance: the Father, Calvin W. Williams III, who is represented in this matter by
James A. Miller Esquire, although the Father appeared without counsel. The Mother, Elizabeth Perez,
did not attend the conference although she was properly served with notice.
3. This Court previously entered orders in this matter on December 7, 2009 and March 23,
2010 under which the Mother has primary physical custody and the Father has partial custody on
alternating weekends from Saturday at 10:00 a.m. through Sunday at 9:30 a.m. and on interim Sundays
from 1:00 p.m. through 7:00 p.m.
4. The Father filed this Petiiton for Modification requesting an increase to his periods of partial
custody in light of the changed circumstances. According to the Father, the Mother had been
incarcerated four times in the last 12 months and the Father had custody of the Child for the entire
summer as the Mother was not released until September 2. The Father indicated that they had never
been strictly following the prior Order as the parties have been able to work together in arranging their
schedules on an ongoing basis by agreement. The Mother is unable to drive at this time and therefore
was not able to conduct the exchanges as previously arranged. The Father indicated that the parties
had been working together on a modified custodial schedule and order and the Father believes that the
Mother is in agreement with the arrangements he has proposed.
5. Based upon the representations of the Father at the conciliation conference and the fact that
the Mother did not attend or contact the conciliator to advise of her intention not to appear, the
conciliator recommends an Order in the form as attached. The Mother may file a Petition to review the
custodial arrangements if she believes it would be in the Child's best interests.
5C0e4r-ht/t ( PI .010 I ti
Date
Dawn S. Sunday, Esquire
Custody Conciliator