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HomeMy WebLinkAbout04-3328JAMIE LYNN MYERS, MICHAEL ANTHONY WASHINGTON, SR, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04- ..~.~ ~,~ CIVIL TERM : CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Jamie Lynn Myers, hereinafter referred to as the mother. Mother's permanent residence is 409 North Baltimore Street, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 2. The defendant is Michael Anthony Washington, Sr. North Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The mother seeks custody of the minor child: Name Michael Washington, Jr. Defendant resides at 46 West Present Residence Age 409 North Baltimore Street 8/29/2001 DOB Mount Holly Springs, PA 17065 ~3 years old The child, Michael Washington, Jr., was born out of wedlock. The child is presently in the custody of the mother. During the child's lifetime, Michael Washington, Jr. has resided with the following persons and at the following addresses: Date Birth to 9/2003 Name Jamie Lynn Myers Michael Anthony Washington, Sr. Address 206A Lincoln Street Carlisle, PA 17013 Jamie Lynn Myers Jamie Lynn Myers Jermaine Hunt 233 North Bedford Street Carlisle, PA 17013 9/2003 - 11/2003 409 North Baltimore Street 11/2003 - present Mount Holly Springs, PA 17065 The mother is single. The defendant is the father of the child. The defendant is single. 4. The mother currently resides with the following persons: Name Jamie Lynn Myers Jermaine Hunt Michael Washington, Jr. Relationship Self Mother's boyfriend Son with Defendant 5. It is believed that the defendant currently resides with the following persons: Name Michael Anthony Washington, Sr. Stacey Code Corey Corle Relationship Self Defendant's girlfriend Defendant's girlfriend's son 6. The mother 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. 7. The mother has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. The mother 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. 9. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including, but not limited to the following: a) The child has lived with the mother since birth and the mother can provide for the child's emotional, physical, educational, and medical needs including establishing a stable home environment for the child. b) The mother lives with her boyfriend who is willing and able to care for the child and help provide for the child's daily needs. c) The mother is the parent who can best facilitate any interaction between the child and the defendant. d) The defendant has not acted in the best interest of the child in ways including but not limited to the following: i) The defendant has failed to pay his child support obligations and is in arrears. His failure to support the child under a Court Order suggests that he is unable and unwilling to support or care for a child on a full-time basis. ii) The defendant failed to exemise any custodial rights to the child since September 2003, having seen the child on only one occasion for an overnight visit in January 2004. iii) Beginning on June 23, 2004, the defendant began contacting the mother to request visits with the child. These visits have been for about six (6) hours every other day and sometimes under the supervision of the mother in a public area. iv) The defendant does not own furniture or items necessary for overnight visits and he is not able to provide for the daily needs of a young child on a full time basis. v) The defendant has a volatile temper and has become so violent that the mother filed a Protection From Abuse Petition against the defendant and obtained a Temporary Protection From Abuse Order on September 12, 2003. (See attached Exhibit 1). vi) Because of service issues, there has been no hearing on the Protection From Abuse Petition, but the Temporary Protection From Abuse Order remains in effect until March 10, 2005. (See attached Exhibit 2). vii) One incident described in the Protection From Abuse Petition indicates the defendant's violence toward the child. According to the allegations, the defendant slammed the child against a wall and the child suffered physical pain. viii) The child fears the defendant. ix) Although the child has recently spent time with the defendant, the defendant still demonstrates a propensity toward inappropriate physical discipline of the child. x) The defendant's ongoing intimidation of the child indicates his inability to appropriately care for the needs of a child on a full-time basis. 10. Every person with rights to custody or having actual physical custody of the children have been named as parties to this action. WHEREFORE, the mother requests this Court to: a) Grant her primary physical custody of the child. b) Grant the parties shared legal custody of the child. c) Grant the defendant periods of partial custody at times agreed upon by the parties. d) Establish an appropriate custody schedule for the holidays. e) Any additional relief this Court finds just and proper. Respectfi~lly submitted, ; stone Attorney for Plaintiff Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION the and are made subject to the penalties of ~8 to unsworn falsification to authorities. The above-named PLAINTIFF, ]amie Lynn Myers, verifies that statements made in the above Complaint For Custody are true correct. Plaintiff understands that false statements herein Pa. C.S. §4904, relating Date: Jamie Lynn Myers, Plaintiff VS. Michael Anthony Washington, Sr., Defendant : IN THE COURT OF COIvEMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03- CIVIL TERM : : PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important fights. A hearing o,l:t this matter is scheduled on the 17f~day of J'~j~.~. ,2003, at ,'~ i~?0/9 .m., in Courtroom No. ;d on the 4th Floor of the Cum~'~-and County Courthouse, 1 Courthous'e Square, Carlisle, Pennsylvania. You MUST obey the Order that is attached untiMt is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. §6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. §2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Conanonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. § 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the heating. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to fred out where you can get legal help. If you cannot find a lawyer, you may have to proceed ~vithout one. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street, Carlisle, Pennsylvania 17013 Telephone Number: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of ~990. For information about accessible facilities and reasonable accomraodations 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. £;x/-t/f&/7 / Jamie Lynn Myers, Plaintiff Michael Anthony Washington Sr., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - LAW PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Michael Anthony Washington Sr. Defendant's Date of Birth is: July 29, 1982 Defendant's Social Security Number is: 179-62-2335 Name(s) of All protected persons, including Plaintiff and minor children: 1. Jamie Lynn Myers AND NOW, on 10th Day of September, 2003 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: PlaintifPs request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. Except for such contact with the minor child/ren as may be permitted under paragraph 4 of this Order, Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintif£s school, business, or place of employment. 3. Except for such contact with the minor ch/ld/ren as may be permitted under paragraph 4 of this Order, Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. Pending the outcome of the final heating in this matter, Plaintiff is awarded temporary custody of the following m/nor child/rem 1. Jamie Lynn Myers Until the final hearing, all contact between Defendant and the child/ren shall be limited to the following: Reasonable periods of partial custody as agreed upon by the parties. The local law enforcement agency in the jurisdiction where the child/ren are located shall ensure that the child/ren are placed in the care and control of the Plaintiff in accordance with the terms of this Order. 5. The following additional relief is granted: -Defendant is prohibited from having any contact with Plaintiff's relatives and Plaintiff's children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ten. -Non-harassing, non-threatening contact between the parties regarding custody and/or visitation shall not be deemed a violation of the order. -Defendant shall not damage or destroy any property owned jointly by the parties or solely by the Plaintiff. A certified copy of this Order shall be provided to the police department where Plaintiffresides and any other agency specified hereafter: PA State Police, Carlisle Barracks Carlisle Police Department 7. The sheriff, police or other law enforcement agencies are chrected to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Heating without prepayment of costs. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 8. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MARCH 10, 2005 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO TI-IE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and~or up to six months in jail. 23 Pa.C.S. §6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. §6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. § §2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintift's residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 4 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriffs office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weapon/s are evidence ora crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest, BY THE COURT_.' ~P~/~,,~ ,2¢z~ Date Distribution to: Legal Services Faxed & Mailed to PSP TRUE COPY FROM RECORD In Testimony whereof, I h~re unto set my hand ang, the seal of said Court at ICerlJsllh Pa. Jamie Lynn Myers, Plaintiff Michael Anthony Washington Sr., Defendant PFAD Number: CS1747477W : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA ; : :No. : : CML ACTION - LAW : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE l. Plaintiffs name is: Jamie Lynn Myers 2. I, (the Plaintiff), am filing this Petition on behalf of: - myself 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. Jamie Lynn Myers 4. Plaintiffs Address is: 233 N. Bedford Street, Carlisle, PA 17013 5. Defendant's Name is: Michael Anthony Washington Sr. 6. Defendant is believed to live at the follow'rog address: 163 West North Street, Carlisle, PA 17013 7. Defendant's Social Security Number is: 179-62-2335 8. Defendant's Date of Birth is: July 29, 1982 9. Defendant's Place of employment is: unemployed 10. 11. Defendant is an adult. The relationship between the Plaintiff and the Defendant is: Parents of the same children Current or former sexual/intimate partner Persons who five or have lived like spouses 12. The Plaintiff and the Defendant been involved in the following court actions: a. Support 13. Other details of the court action are: Cumberland County Domestic Relations 14. The defendant has been involved in a criminal court action. 15. Plaintiff and Defendant are the parents of the following minor child/rem 16. Michael Anthony Washington Jr. Age:2 Child's address is: 233 North Bedford St., Apt. B, Carlisle, PA 17013 Plaintiff is seeking an Order of child custody as part of this petition. The following is a list of the children and where they have live for the past 5 years: Jamie Lynn Myers For the past 5 years, this child has lived with: 6/01 to mid-August 2003-206A Lincoln St., Carlisle, PA (child lived with both parents) mid-August to present-233 Bedford St., Apt. B, Carlisle, PA (fives with mother) 17, The facts of the most recent incident of abuse are as follows: On about Monday, August 25, 2003 at approximately 8:10PM location: 206 A Lincoln Street, Carlisle, PA During the course of an argument, Defendant grabbed Plaintiff tightly by her upper arms and slammed her into the neighbor's screen door, causing pain, injury and bruising. Defendant menaced Plaintiff by shouting vulgarities at her close up and in her face, causing her to fear further imminent physical harm. Plaintiff called the Carlisle Police. Harassment charges are pending. 18. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren, (including any threats, injuries, or incidents of stalking) are as follows: In or around June 2003, Defendant became angry with the parties' two (2) year old son. Defendant slammed the parties' son into the bedroom wall. When Plaintiff stepped in to protect the child, Defendant struck her across the face, causing Plaintiff to fear for her safety and the safety of their minor child. In or around May 2003, Defendant became angry and grabbed Plaintiff tightly by her upper arm, dragged her from the bathroom to the bedroom and threw her on to the bed. Defendant became further enraged and punched a hole in the bedroom door in close proximity to Plaintiff, causing Plaintiff to fear imminent physical harm. During the course of the parties' relationship, Defendant has abused Plaintiff in ways, including, but not limited to the following: Defendant physically menaced Plaintiff by standing very close to her shouting vulgarities in her face, grabbed her tightly by her upper arms, slammed her into a door, struck her across the face, and dragged her from one room to another, threw her, and punched a door, causing pain, injury, and bruising. 19. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: PA State Police, Carlisle Barracks Carlisle Police Department 20. There is an immediate and present danger of further abuse from the Defendant. 21. FOR THE REASONS SET FORTH ABOVE, ! REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. b. Award Plaintiff temporary custody of the m/nor child/ren and place the following restrictions on contact between Defendant and child/ten: Reasonable periods of partial custody as agreed upon by the parties. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, or in writing, personally or tkrough third persons, including but not limited to any contact at Plaintiffs school, business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiffs children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the m/nor child/ren. e. Order the following additional relief, not listed above: -Non-harassing, non-threatening contact between the parties regarding custody and/or visitation shall not be deemed a violation of the order. -Defendant shal/not damage or destroy any property owned jointly by the parties or solely by the Plaintiff. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendm~t's residence, where Defendant can be served. Respectfully subm/tted, Date: MIDPENN LEGAL SERVICES ,i (,q. Joan Carey~At~orff~y for Plain~'iff Grace ~)'Alo, A~o~ey For Plaintiff 8 I~ Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S.§4904, relating to unswom falsification to authorities. Dated: J~ti ff Jamie Lynn Myers, Plaintiff Michael Anthony Washington, Sr. Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA ; : NO. 03-4468 CIVIL TERM : : PROTECTION FROM ABUSE AND CI~STODY ORDER FOR GENERAL CONTINUANCE AND NOW, this .3~ day of December 2003, upon consideration of the attached Motion for General Continuance, the matter scheduled for hearing on December 22, 2003 at 11:00 a.m. by this Court's Order of September 10, 2003, is hereby continued generally. This Order is entered without prejudice to either party to request a hearing. The Temporm3~ Protection From Abuse Order shall remain in effect through March 10, 2005, or until further Order of Court, whichever comes first. By the Court, ~Ed'gar B. ~3ayley, Judge Jessica Diamondstone, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 Michael Anthony Washington, Sr., Pro Se Defendant Comberland County Sheriff's Department Jamie Lynn Myers, Plaintiff Michael Anthony Washington, Sr. Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-4468 CIViL TERM : : PROTECTION FROM ABUSE AND CUSTODY MOTION FOR GENERAL CONTINUANCE Plaintiff, Jamie Lynn Myers, by and through her attorney, Jessica Diamondstone, of MidPem~ Legal Services, moves the Court for an Order continuing generally the hearing in the above-captioned case on the grounds that: 1. A Temporary Protection From Abuse Order was issued by tiffs Court on September 10, 2003, scheduling a hearing for September 17, 2003 at 2:30 p.m. 2. Since Defendant had not been served with the original documents, subsequent Orders of Court were entered rescheduling the hearing for October 30, 2003 at 8:45 a.m., December 15, 2003, at 2:30 p.m., and December 22, 2003 at 11:00 a.m. 3. The Cumberland County Sheriffs Department has been unable to serve Defendant with certified copies of the Temporary Order and Orders for Continuance. 4. Plaintiff's attorney has made diligent effort to discover the current location and/or address for Defendant, but has been unsuccessful in every attempt to do so. 5. Plaintiff has been advised to call the police, in the event that Defendant accosts her or perpetrates farther abuse upon her, and to have the police effect service with her copy of the Temporary Protection Order/General Continuance, if this should be necessary. 6. Plaintiff desires that the hearing be continued generally pending further Order in this matter. 7. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect through March 10, 2005, or until fi~rther Order of Court, whichever comes first. WHEREFORE, Plaintiff requests that the Court grant this Motion and continue the matter generally and that the Temporary Protection From Abuse Order remain in effect through March 10, 2005, or until further Order of Court, whichever comes first. Respectfully submitted, Jessica,t~amondstone, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 JAMIE LYNN MYERS, MICHAEL ANTHONY WASHINGTON, SR, Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 04- CIVIL TERM : : : CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Jessica Diamondstone, do hereby swear that I served Michael Anthony Washington, Sr. with a Complaint For Custody on July 9, 2004 by certified mail, return receipt, restricted delivery, to the person and address below: Michael Anthony Washington, Sr. 46 West North Street Carlisle, PA 17013 I, Jessica Diamondstone, verify that the statements made in this Affidavit of Service are tree 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. JAMIE LYNN MYERS, MICHAEL ANTHONY WASHINGTON, SR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 04- ~ ~( CIVIL TERM Defendant : CUSTODY PRAECIPE TO PROCEED 1N FORMA PAUPERIS To the Prothonotary: Kindly allow, Jamie Lynn Myers, Plaintiff, to proceed in forma pauperis. I, Jessica Diamondstone, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 JAMIE LYNN MYERS PLAINTIFF MICHAEL ANTHONY WASHINGTON, SR. DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-3328 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, M~uly 19, 2004 _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilro , Es~y~Lq~, the conciliator, at 4th Floor, Cumberland Coun_.ty Cm~rthouse, Carlisle on Frida_y, August 06, 2004 at 9!30 _AM for a Pre-Hearing Custody Conference. At such conference, an eftbrt 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. All children age five or older may also be vresent at the conference. Failure to uprear at the conference may provide grounds for entry ora temporary or permanent order. The court hereby directs the parties to furnish any and ali 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/ ~b-grtJL_GJ~oy, ~q, -- mhc 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. Ail 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. HAVE ANYOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELb;PHONE THE OFFICE SET FOR'iH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELl['. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 JAMIE LYNN MYERS, Plaintiff V MICHAEL ANTHONY WASHINGTON, SR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERL3~ND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 04-3328 : IN CUSTODY COURT ORDER AND NOW, this ~..~. day of {-'~ C-~L, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: The mother, Jamie Lynn Myers, shall enjoy legal and physical custody of Michael Washington, Jr., born August 29, 2001. The father, Michael Washington, Sr., shall enjoy periods of temporary custody with the minor child at such times and under such circumstances as agreed to by the mother. In the event the father desires to modify *~-:~ A_., ....... .. Court to have ' · ~ ~ urucr, [ne Iamer may petition the this case again scheduled vath the Custody Conciliator. CC: ~J~essica Diamondstone t, Mlchael Washington, Sr. 409 North Baltimore Street Mt. Holly Springs, PA 17065 BY THE COURT, oc'r o 4 20o4 JAMIE LYNN MYERS, Plaintiff V MICHAEL ANTHONY WASHINGTON, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERL/LND COUNTY, PENNSYLVANIA CIVIL ACTION ~ LAW NO. 04 - 3328 IN CUSTODY CONCILIATION CONFERENCE SU1V[~Y REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF 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: Michael Washington, Jr., born August 29, 2001. A Conciliation Conference was held on August 19, 2004, with the following individuals in attendance: The mother, Jamie Lynn Myers, with her counsel, Jessica Diamondstone. The father did not appear. The Conciliator recommends an order in the form as attached. DATE il.r,,~y, Esqui~ Custody Concigu~tor /