Loading...
HomeMy WebLinkAbout10-2250STEPHEN E. TRASK, Plaintiff V. LINDA M. TRASK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 10 - aa. s-0 V i 1 T'E'?'rrl, N 22 M IN CUSTODY s C? CUSTODY COMPLAINT 5 == Z- R ; C!' AND NOW COMES the above named Plaintiff by his attorney, Gary L. Rothschild, `z fn -A Esquire, and seeks to obtain shared legal and partial physical custody of the minor children, IAN A. TRASK, MEREDITH M. TRASK and DEIRDRE Q. TRASK, from the above named Defendant, and in support thereof avers as follows: 1. Plaintiff is Stephen E. Trask, who currently resides at 236 E. Main Street, Mechanicsburg, Cumberland County, Pennsylvania 17055, having so resided since July, 2009. 2. Defendant is Linda M. Trask, who currently resides at 10 Belvedere Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, having so resided since January, 1998. 3. Plaintiff seeks shared legal and partial physical custody of the following children: Name Present Address Age IAN A. TRASK 10 Belvedere Drive, Mechanicsburg, PA 14 years MEREDITH M. TRASK 10 Belvedere Drive, Mechanicsburg, PA 12 years DEIRDRE Q. TRASK 10 Belvedere Drive, Mechanicsburg, PA 11 years 4. The children were not born out of wedlock. 5. The children are presently in the custody of Linda M. Trask, who currently resides at 10 Belvedere Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 4IgQ.oo Pb ATTI ee 4611 0 azl q t4 6. During the past five years, the children have resided with the following persons and at the following addresses: List of Persons Addresses Dates Stephen E. Trask (father) 10 Belvedere Drive, Mechanicsburg, PA March, 2005 to Linda M. Trask (mother) October 2008 Linda M. Trask (mother) 10 Belvedere Drive, Mechanicsburg, PA October 2008 to present 7. The mother of the children is Linda M. Trask, who currently resides at 10 Belvedere Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. She is married to the Plaintiff (father). 8. The father of the children is Stephen E. Trask, who currently resides at 236 E. Main Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. He is married to the Defendant (mother). Father and mother separated in October 2008 and father filed an action in divorce, at Docket Number 09-8659 (Cumberland County), on December 16, 2009. 9. The relationship of Plaintiff to the children is that of father. The Plaintiff currently resides with his girlfriend Trudy M. Mintz. 10. The relationship of the Defendant to the children is that of mother. The Defendant resides with the minor children. 11. 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. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 13. 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. 14. The best interest and permanent welfare of the children will be served by granting the relief requested because it will enable the children to spend more time with father, thereby benefiting the children, aiding in the development of the children, fostering a positive relationship with father, improving the children's educational growth and allowing father to continue his important role as parent. Father has been involved in the lives of the children since their birth. 15. 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. WHEREFORE, Plaintiff respectfully requests the court to grant shared legal and partial physical custody of the minor children to Plaintiff. Respectfully submitted, Date: 33/?o G/ By: G Rothschild, Esquire Supreme Court I.D. No. 62041 2215 Forest Hills Drive, Suite 35 Northwood Office Center Harrisburg, PA 17112 Telephone: (717) 540-3510 Facsimile: (717) 540-3512 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Custody 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. .? z g , X6 D de tephen E. Trask, Plaintiff ~~ OCR 0 4 2010 STEPHEN E. TRASK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2010-2250 CIVIL ACTION LAW LINDA M. TRASK Defendant IN CUSTODY -~, ~ ~ ~~ ~~ ~ .,, _ .~ ---~ ~. r~s ~a~ ~ ~~ _ - cati = ~~= --~ c~ r ORDER OF COURT ~;~ ~ ~ r~ -~i ~ _~,~ N ~ AND NOW, this day of y ~, 2(~0 , :lion consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated June 7, 2010 is vacated and replaced with this Order. 2. The Father, Stephen E. Trask, and the Mother, Linda M. Trask, shall have shared legal custody of Ian A. Trask, born June 28, 1995, Meredith M. Trask, born June 18, 1997, and Deidre Q. Trask, born December 9, 1998. Major decisions concerning the Children including, but not necessarily limited to, their 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 each Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Children. Neither party shall attempt to alienate the affections of the Children from the other party. Each party shall notify the other of any activity or circumstance concerning the Children 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. §5309, 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. 3. The Mother shall have primary physical custody of the Children. 4. The Father shall have partial physical custody in accordance with the following schedule: A. The Father shall have custody of the Children beginning Wednesday, September 29, 2010 every Wednesday from after school until 8:00 p.m. or until 9:00 p.m. during the summer school break. The Father shall transport the Children to Sylvan Learning Center for their tutoring sessions on Wednesday. As long as Deidre has piano lessons on Wednesdays, the Mother shall pick up Deidre from school and take her to piano lessons and transport her to the Father's residence after her lesson. B. The Father shall transport Ian to and from his tutoring session from 5:00 p.m. until 6:00 p.m. on Thursdays at Sylvan Learning Center. C. In addition, the Father shall have custody of the Children on alternating weekends from Friday at 5:00 p.m. until Sunday at 6:00 p.m. Both parties acknowledge that they will continue to be sensitive to and flexible with the needs and concerns of the Children and that neither party shall use the provisions of this paragraph as the basis for contempt proceedings. 5. Each party shall be entitled to have a vacation period of custody with the Children during the summer school break as arranged by agreement between the parties. The parent having a period of vacation custody shall provide advance notice to the other parent of the address and telephone number where the Children can be contacted. 6. The parties shall communicate directly with each other concerning all custodial issues without the involvement of the Children or third parties. The parties shall not use the Children as messengers or liaisons. The parties shall not discuss issues regarding parental conflicts with the Children. 7. The parties shall cooperate in discussing and coordinating their major disciplinary efforts with the Children and shall also cooperate in enforcing disciplinary measures to promote consistency for the Children's well-being. 8. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 9. 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 E COURT, Edward E. Guido J. cc: ~$ a Sumple-Sullivan, Esquire -Counsel for Mother even Howell, Esquire -Counsel for Father V /o~' ~o/ STEPHEN E. TRASK vs. LINDA M. TRASK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 2010-2250 CIVIL ACTION LAW Defendant IN CUSTODY Prior Judge: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT pC~ 0 4 X010 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Ian A. Trask June 28, 1995 Mother Meredith Trask June 18, 1997 Mother Deidre Trask December 9, 1998 Mother 2. A custody conciliation conference was held on September 28, 2010, with the following individuals in attendance: the Father, Stephen E. Trask, with his counsel, Steven Howell, Esquire, and the Mother, Linda M. Trask, with her counsel, Barbara Sumple-Sullivan, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~/~~~ 02 % ~~~ Date Dawn S. Sunday, Esquire Custody Conciliator STEPHEN E. TRASK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2010-2250 CIVIL ACTION T01 { LINDA M. TRASK, Defendant : IN CUSTODY `<> C--) LR11 =C? PRAECIPE FOR WITHDRAWAL AND ENTRY OF APPEARANCCf To the Prothonotary: Please withdraw the appearance of the undersigned as counsel for the Plaintiff in the above-captioned matter. Date: l Gary LAothschild, Esquire PA Supreme Court I.D. No. 62041 2215 Forest Hills Drive, Suite 35 Northwood Office Center Harrisburg, PA 17112 Tele. (717) 540-3510 Please enter my appearance as counsel for the Plaintiff in the above-captioned matter. Date: ?1 k ?1 p rA supreme Court I.D. No. 62063 619 Bridge Street New Cumberland, PA 17070 Tele. (717) 770-1277 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN E. TRASK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVAN IA c © -q v. NO. 2010-2250 MW = z LINDA M. TRASK, z? CIVIL ACTION - LAW 7,2. rv r7n Defendant °i °c:? 4 C.1)0 rh PETITION FOR SPECIAL RELIEF -' 1. Petitioner is Defendant, Linda M. Trask (hereinafter referred to as "Mother"), an individual residing at 10 Belvedere Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Respondent is Plaintiff, Stephen E. Trask (hereinafter referred to as "Father"), an individual residing at 63 Helam Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Mother and Father are the natural parents of the children named below: NAME ADDRESS DOB Ian A. Trask 10 Belvedere Drive 6/28/1995 Mechanicsburg, PA Meredith M. Trask 10 Belvedere Drive 6/18/1997 Mechanicsburg, PA Deirdre Q. Trask 10 Belvedere Drive 12/9/1998 Mechanicsburg, PA 70.00 PA A71tY elp QW9 1 4. The children are currently in the primary physical custody of Mother. Mother resides with the children at the address referenced above. 5. The Father of the children, currently residing at 63 Helam Drive, Mechanicsburg, PA, is residing with his companion, Trudy Mintz. 6. The parties are currently separated, but not divorced. 7. Mother and Father had previously participated in a custody proceeding in this Court. A copy of the Custody Order dated October 6, 2010, is attached hereto as Exhibit "A" and incorporated herein by reference. 8. Pursuant to mutual agreement of the parties, the parties' son was engaged in counseling with Dr. Bigger of Pinnacle Health prior to the parties' separation in 2008. Since separation and with the express knowledge and consent of both parents, all three children have been patients of Dr. Bigger. Father had participated in the counseling sessions. 9. Prior to separation, Father had little hands on contact with parenting the children. 10. Mother has attempted to facilitate the relationship between the children and Father with the help of the counselor. 11. The children were extremely angry with Father for the circumstances of the separation and 2 for leaving them in the house which was physically deteriorated. 12. Dr. Bigger has been instrumental in helping the children meet the challenges arising from Father's separation, adjustment to their new family structures, and attempting to build a relationship with Father and his significant other. 13. The children's progress in accepting these challenges has improved with the help of Dr. Bigger. The counseling had improved the children's ability to deal with the trauma of the way in which Mother and Father separated and the ongoing relationship that Father has with his companion. 14. As the children's relationships grew less contentious with Father, Mother agreed in the last Court Order to an expansion of physical custody periods between the children and Father. 15. The situation with the children has been deteriorating including problems with school grades and relationship issues in Father's home. 16. Father has now unilaterally taken the position that the children will be forbidden from continuing under the care of their therapist, Dr. Bigger, indicating Dr. Bigger is not helping the children. Father terminated the contact between the children and the counselor without any prior notice to Mother or the counselor as to his position on the continuance of counseling. 3 17. Mother requests that the children's treatment with Dr. Bigger be reinstated. 18. The best interest and permanent welfare of the children will be served by granting the relief requested because the relationships between the children and Father and the children and his companion, Trudy Mintz, are deteriorating and need professional intervention. The children are exhibiting stress and anxiety which are being identified in their behaviors including poor school grades and inappropriate and disrespectful social behaviors. The termination of their therapist by Father has taken away an objective forum from the children, making them more combative with Father. 19. The present deterioration of the relationship with Father is magnified by his refusal to allow the children to continue with their medical treatment. Mother believes modifying the custodial time with Father may become necessary if this conflict is not addressed and increased counseling for the children occurs. 20. It is also the position of the child's therapist that it is necessary for the children to continue counseling. There is a beneficial therapeutic relationship established between the children and Dr. Bigger and terminating this relationship without closure is harmful to the children's psychological well-being. WHEREFORE, Mother requests this Honorable Court enter an Order reinstating the 4 children in therapy with Dr. Bigger. Dated: ,S2-,1/z/- Respectfully submitted, 5 Barbara Sumple-Sullivan, Esquire Attorney for Petitioner 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Exhibit.A OCT 0 4 2010 STEPHEN E. TRASK vs. LINDA M. TRASK Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010-2250 IN CUSTODY ORDER OF COURT CIVIL ACTION LAW AND NOW, this day of o G y 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated June 7, 2010 is vacated and replaced with this Order. 2. The Father, Stephen E. Trask, and the Mother, Linda M. Trask, shall have shared legal custody of Ian A. Trask, born June 28, 1995, Meredith M. Trask, born June 18, 1997, and Deidre Q. Trask, born December 9, 1998. Major decisions concerning the Children including, but not necessarily limited to, their 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 each Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Children. Neither party shall attempt to alienate the affections of the Children from the other party. Each party shall notify the other of any activity or circumstance concerning the Children 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. §5309, 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. 3. The Mother shall have primary physical custody of the Children. 4. The Father shall have partial physical custody in accordance with the following schedule: A. The Father shall have custody of the Children beginning Wednesday, September 29, 2010 every Wednesday from after school until 8:00 p.m. or until 9:00 p.m. during the summer school break. The Father shall transport the Children to Sylvan Learning Center for their tutoring sessions on Wednesday. As long as Deidre has piano lessons on Wednesdays, the Mother shall pick up Deidre from school and take her to piano lessons and transport her to the Father's residence after her lesson. B. The Father shall transport Ian to and from his tutoring session from 5:00 p.m. until 6:00 p.m. on Thursdays at Sylvan Learning Center. C. In addition, the Father shall have custody of the Children on alternating weekends from Friday at 5:00 p.m. until Sunday at 6:00 p.m. Both parties acknowledge that they will continue to be sensitive to and flexible with the needs and concerns of the Children and that neither party shall use the provisions of this paragraph as the basis for contempt proceedings. 5. Each party shall be entitled to have a vacation period of custody with the Children during the summer school break as arranged by agreement between the parties. The parent having a period of vacation custody shall provide advance notice to the other parent of the address and telephone number where the Children can be contacted. 6. The parties shall communicate directly with each other concerning all custodial issues without the involvement of the Children or third parties. The parties shall not use the Children as messengers or liaisons. The parties shall not discuss issues regarding parental conflicts with the Children. 7. The parties shall cooperate in discussing and coordinating their major disciplinary efforts with the Children and shall also cooperate in enforcing disciplinary measures to promote consistency for the Children's well-being. 8. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 9. 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 , Edward E. Guido J. cc: Barbara Sumple-Sullivan, Esquire - Counsel for Mother Steven Howell, Esquire - Counsel for Father TRUE COPY FROM RECORD In Testimony whereof, I hen unto so my hand and the i of said at sls, Ps. This sy of 20-CC- ry OCT 0 4 2013 STEPHEN E. TRASK Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. LINDA M. TRASK Defendant 2010-2250 CIVIL ACTION LAW IN CUSTODY Prior Judge: Edward E. Guido 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Ian A. Trask June 28, 1995 Mother Meredith Trask June 18, 1997 Mother Deidre Trask December 9, 1998 Mother 2. A custody conciliation conference was held on September 28, 2010, with the following individuals in attendance: the Father, Stephen E. Trask, with his counsel, Steven Howell, Esquire, and the Mother, Linda M. Trask, with her counsel, Barbara S umple- Sullivan, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN E. TRASK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. LINDA M. TRASK, Defendant NO. 2010-2250 CIVIL ACTION - LAW VERIFICATION I, Linda M. Trask, hereby certify that the facts set forth in the foregoing Pleading are true and correct to the best of my knowledge, information and belief I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. DATED: Z L' DAM. TRASK Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN E. TRASK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2010-2250 LINDA M. TRASK, CIVIL ACTION -LAW Defendant CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the Petition for Special Relief, in the above-captioned matter upon the following individual, by United States first-class mail, postage prepaid, addressed as follows: i DATE li' Steven Howell, Esquire 619 Bridge Street New Cumberland, PA 17070 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Attorney for Petitioner STEPHEN E. TRASK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2010-2250 CIVIL ACTION LAW 3 -- M C ::c r r*? 1 LINDA M. TRASK - Z7. r- -VM M IN CUSTODY DEFENDANT ':? ? --;;-; C ORDER OF COURT AND NOW, Wednesday, June 08, 2011 _,upon consideration of the attached Com plaint, 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 Friday, July 01, 2011 _ 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/ Dawn S. Sunda 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 ??J Coe / Telephone (717) 249-3166 //l 2 STEPHEN E. TRASK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA c-z r-..3 `; C= C= vs. 2010-2250 CIVIL ACTION LAW m mm ? ?-- on r- LINDA M. TRASK ?CD ICD Defendant IN CUSTODY <= ORDER OF COURT AND NOW, this IS40 day of txA/y 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated October 6, 2010 shall continue in effect as modified by this Order. 2. On a trial basis pending the follow-up custody conciliation conference scheduled in this Order, the parties shall make arrangements to resume the counseling for the Children with Dr. Bigger on the next available dates. Counseling sessions shall be scheduled on a rotating basis with the appointment for Ian first, Meredith second, Deirdre third and then a fourth appointment which shall be divided into one-half for the Father and one-half for the Mother with Dr. Bigger. The purpose of the split session for each of the parents following the rotation for each Child's counseling session shall be to address the Father's concerns regarding the effectiveness of the counseling, the focus of the counseling sessions with the Children and opportunity for the parents to address issues related to the Children directly with the counselor on a regular basis. The appointment for the parents with Dr. Bigger shall be arranged so that the relationship between each parent with the counselor is identical (i.e. either both parties are patients or neither party is a patient). The Mother shall not have any other counseling relationship with Dr. Bigger or counseling appointment time with Dr. Bigger outside of the half sessions specified in this provision. 3. Each party shall be entitled to transport the Children to an equal number of counseling sessions, as permitted by each party's schedule. 4. The parties and counsel shall attend a follow-up custody conciliation conference in the office of the conciliator, Dawn S. Sunday, on September 27, 2011 at 2:00 p.m. for the purpose of reviewing the concerns raised by both parties at the conciliation conference following the counseling arrangements provided in this Order. 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 writing. In the absence of mutual consent in writing, the terms of this Order shall control. BY TH RT, Edward E. Guido J. cc: Barbara Sumple-Sullivan Esquire - Counsel for Mother Steven Howell, Esquire - Counsel for Father STEPHEN E. TRASK vs. LINDA M. TRASK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 2010-2250 CIVIL ACTION LAW Defendant : IN CUSTODY Prior Judge: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: follows: 1. The pertinent information concerning the Children who are the subjects of this litigation is as NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Ian Trask June 28, 1995 Mother Meredith Trask June 18, 1997 Mother Deirdre Trask December 9, 1998 Mother 2. A custody conciliation conference was held on July 1, 2011, with the following individuals in attendance: The Father, Stephen E. Trask, with his counsel, Steven Howell, Esquire, and the Mother, Linda M. Trask, with her counsel, Barbara Sumple-Sullivan, Esquire. 3. The parties agreed to entry of an Order in the form as attached. S moo/ Date Dawn S. Sunday, Esquire Custody Conciliator STEPHEN E.TRASK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA C) rn V =rrI MF 2010-2250 CIVIL ACTION LAW -�'-j 0m Ln cD --+c:) LINDA M.TRASK 7C-I IN CUSTODY C:) DEFENDANT C)(7) ORDER OF COURT AND NOW, Friday,March 15,2013 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,April 18,2013 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. FOR THE COURT, By: /s/ Dawn S. Sunday.Es g.ih- 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 A Telephone (717)249-3166 - 0 sum Pk ,,j ePS I*W,Ito,/ STEPHEN E. TRASK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2010-2250 CIVIL ACTION LAW LINDA M. TRASK Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2013, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court shall continue in effect as modified by this Order. 2. The Father shall have primary physical custody of Meredith. 3. The level and frequency of the contact between the Mother and Meredith shall be as recommended by Dr. Bigger with a specific schedule to be arranged by agreement between the parties. In the event the parties are unable to reach an agreement as to the schedule, counsel for either party may file an additional Petition to return to conciliation. 4. The parties shall make arrangements for the Child to continue in counseling with Dr. Bigger. 5. The Mother shall contact Dr. Bigger to initiate reunification or reconciliation counseling for the Mother and Meredith to open a dialogue and address conflicts which have arisen in the Mother- Daughter relationship. Both parents shall have access to information regarding the progress of this counseling. 6. The parties shall engage in therapeutic family counseling with Vivian Blanc or other professional selected by agreement between the parties. The purpose of the counseling shall be to assist the parties in establishing effective and productive communication and cooperation to enable them to effectively co-parent the Children and address issues which have arisen with regard to the Children. Any costs of the counseling which are not covered by insurance shall be paid 66%by the Father and 34%by the Mother. 7. 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 C , 4t Edward E. Guido J. cc: teven Howell Esquire—Counsel for Father +/Barbara Sumple Sullivan Esquire—Counsel for Mother J 13 a 0 -r..rn rA1� �Z: C� i CD STEPHEN E. TRASK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2010-2250 CIVIL ACTION LAW LINDA M. TRASK Defendant IN CUSTODY Prior Judge: Edward E. Guido 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 Children who are the subjects of this litigation is as follows: NAME AGE CURRENTLY IN CUSTODY OF Ian Trask 17 Mother Meredith Trask 15 Father Deirdre Trask 14 Mother 2. A custody conciliation conference was held on April 18, 2013, with the following individuals in attendance: the Father, Stephen E. Trask, with his counsel, Steven Howell Esquire, and the Mother, Linda M. Trask, with her counsel, Barbara Sumple-Sullivan Esquire. 3. The parties agreed to entry of an Order in the form as attached. c�O�L3 Date Dawn S. Sunday, Esquire Custody Conciliator STEPHEN E. TRASK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA • v. : NO. 2010-2250 • LINDA M. TRASK, : CIVIL ACTION - LAW Defendant : IN CUSTODY STIPULATION This stipulation is made this 1 day of October, 2013. The parties are in agreement to modification of their existing custody order in accordance with this Stipulation and agree as follows: 1) The Order of Court dated April 22, 2013 shall hereby be amended to indicate that Father shall have primary physical custody of son Ian. 2) All terms and conditions contained in the Order dated April 22, 2013 which previously only applied to daughter Meredith shall now be deemed to apply to son Ian also. 3) The parties ratify and confirm the terms of the Order dated April 22, 2013 as expressly modified herein. 4) The parties acknowledged that this Order is entered pursuant to an agreement of the parties. The parties may modify the provisions of this Order by mutual Consent. In the absence of mutual consent, this Order shall control. WITNESS Stephen E. krask c.11.-AdL___ Lin'a M. Trask rr, c v7 tV Zam r , , 3 STEPHEN E. TRASK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2010-2250 • LINDA M. TRASK, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER AND NOW,upon consideration of the Stipulation dated OctobeC, 2013, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the attached Stipulation are adopted as an Order of Court. BY THE s . ' , J. Djstribution: Stephen E.Trask,63 Hellam Drive,Mechanicsburg,PA As.Linda M. Trask,536 Allenview Drive,Mechanicsburg,PA V$5 .).,9Y / `"----E r• 0 � �. ` 1