HomeMy WebLinkAbout00-00260NMMICHAEL SMITH IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
2000-260 CIVIL ACTION LAW
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MICHELLE SMITH r-
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DEFENDAN T -n
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 Tuesday, July 05, 2011 _ 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/ 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
Telephone (717) 249-3166
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Michelle L Sommer, Esquire
Attorng LD. No.: 93034
2 west High Street
Carlisle, Penn ylvania 17013
(717) 249-0900
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MICHAEL SMITH, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PA
V. CASE NO. 00-260 CIVIL TERM
MICHELLE SMITH, n/k/a,
MICHELLE FOLTZ CIVIL ACTION - LAW
Defendant IN CUSTODY
AND NOW this 23rd day of June, 2011, comes the Defendant, Michelle Smith,
now known as, Michelle Foltz, by and through her undersigned counsel, Michelle L.
Sommer, of Abom & Kutulakis, L.L.P., and respectfully sets forth the following
Answer to Plaintiff's Petition for Modification of a Custody Order/Petition for Contempt and
Defendants New Matter and avers the following:
1. Admitted.
2. Admitted in part and Denied in part. It is admitted that the Minor Child has
told the Mother this, on or around, the middle of May, when Father first
made contact with the Minor Child. However; the Minor Child has told
Mother that she did this for "spite" because she was angry with her Mother
and now has no desire to live with her Father. It is specifically denied as the
Minor Child had now indicated that since she has been attending the
Warwick School District her whole life she would like to graduate from there
with her friends.
3. Admitted in part and Denied in part. It is admitted that Father is currently
working full-time for ISA as he indicated at the Domestic Relations
Conference on June 10, 2011. It is specifically denied that Father has a
"stable home" as it is believed and therefore averred that the location of
Father's home is in a very bad location in the City of Harrisburg.
4. Mother is without any specific information, knowledge, or belief to answer
the Defendant's averment.
5. Denied. It is specifically denied that Father and the Minor Child have a
"good Relationship" and that they talk by telephone every day. By way of
further answer, Father's last conversation with the Minor Child occurred on
May 18, 2011. Until recently, Father hasn't seen the Minor Child since she
was five (5) years old.
6. Denied. It is specifically denied that it would be in the best interest of the
Minor Child if Father would be granted Primary Custody since he as not
seen her since she was five (5) years old, nor has he made any attempts to be
part of her life until just recently.
7. Admitted.
DEFENDANT'S ANSWER TO PETITION FOR CONTEMPT
8. The averment within this paragraph is a conclusion of law to which no
responsive pleasing is required.
9. Denied. It is specifically denied that Mother has denied Father his period of
custody provided in the January 19, 2001, Court Order. By way of further
answer, Mother has lived in the same house with the same phone number
since July 2001; it was Father who has decided to not exercised his periods
of custody due to his incarceration, which is no fault of Mother and when
his period of incarceration was completed he made no attempts to contact
Mother to begin his visitation schedule with the Minor Child.
10. Denied. It is specially denied that Father has failed to exercise his requests
for visitation of the Minor Child. In fact as previously stated, Mother has
lived in the same house with the same phone number since July 2001 and he
never attempted to contact her to reinstate his visitation after he was
released from prison.
11. Denied. It is specifically denied that Father did not have Mother's address as
he was provided Mother's address when they appeared for Father's
Contempt Hearings on several occasions before judge Turgeon; therefore,
Father was clearly aware of the Minor Child's address in Lancaster.
12. Denied. It is specifically denied that Mother refused to allow Father to
speak. to the Minor Child. In fact as previously stated, Mother has lived in
the same house with the same phone number since July 2001 and Father was
provided Mother's address and phone number when they appeared for
Father's Contempt Hearings on several occasions before judge Turgeon;
therefore, Father was clearly aware of the Minor Child's address in
Lancaster. By way of further answer, Father has only called Minor Child one
time, during his eleven (11) year absence from her life, on or about
September 2001; at approximately 12:30 a.m. and Father appeared to be
intoxicated so Mother refused to allow Father to speak to her.
13. Denied. It is specifically denied that Mother failed to provide Father with
any information regarding the Minor Child's education or medical services as
he never made such a request. By way of further answer, Father has shared
legal custody of the Minor Child based on the April 4, 2000, Order of Court
and can request educational and medical information on his own through
the Minor Child's school and doctors.
DEFENDANT'S NEW MATTER - PETITION FOR MOnTHCAT ON
AND NOW this 23rd day of June, 2011, comes the Defendant, Michelle Smith,
now known as, Michelle Foltz, by and through her undersigned counsel, Michelle L.
Sommer, of Abom & Kutulakis, L.L.P., and respectfully sets forth the following New
Matter in a Petition for Modification and avers the following:
14. Defendant is Michelle Smith, now known as, Michelle Foltz, who was the
Defendant in the above captioned action between the parties.
15. Plaintiff is Michael Smith, who was the Plaintiff in the above captioned
action between the parties.
16. Petitioner and Respondent are the parents of Brittany Marie Smith, born
September 6, 1995.
17. On April 4, 2000, this Honorable Court entered an Order of Court signed by
judge Edgar B. Bayley based upon a custody conciliation report. (A true and
correct copy of the Order of Court is attached as "Exhibit A'?
a. The Order of Court states that Mother and Father will have Shared
Legal Custody of the Minor Child.
18. On January 19, 2001, this Honorable Court entered an Order of Court
signed by judge Edgar B. Bayley based upon a custody conciliation report.
(A true and correct copy of the Order of Court is attached as "Exhibit B'?.
a. Physical Custody was modified at that time. Mother was given Primary
Physical Custody and Father was to have Partial Physical Custody in
accordance with the following schedule:
i. Every Friday, the Mother shall transport the Child to the Father's
residence at 7:00 a.m. and the Father shall have Custody of the Child
until 1:30 p.m., when the Father shall transport the Child to the
maternal grandparent's residence.
ii. Every Friday, the Father shall pick up the Child at the Mother's
residence between 9:45 and 10:00 p.m. and retain custody of the Child
through Saturday at 1:30 p.m., when the parties shall exchange
custody of the Child at the Capitol City Mall Sears Auto Center.
iii. Every Saturday, the Father shall pick up the Child at the Mother's
residence between 9:45 and 10:00 p.m. and shall retain custody
through Monday at 8:00 p.m. when the Father shall transfer custody
of the Child at the Mother at the Child at the Capitol City Mall Sears
Auto Center.
19. Father appeared out of the blue, on or about May 20, 2011, and Mother
became concerned Father would take Minor Child back to Dauphin County
unexpectedly due to the demands he was making at that time.
20. Mother is not opposed to visitation; however, the existing Physical Custody
Order from January 2001 cannot remain in effect due to the Child's age and
distance between the parties; as well as, the time that has elapsed between
the last visit Father and the Minor Child had prior to his incarceration.
21. It is believed and therefore averred that a new relationship needs to be
introduced gradually so that the parties can establish the Father-Daughter
bond that has been lost over the last eleven (11) years; accordingly, a gradual
schedule needs to be implemented in order to allow that bond to grow.
22. It is believed and therefore averred that Father needs to be patient with this
schedule as the Minor Child is active in several extracurricular activities as
she is active in school sports and he will need to work around her practice
and event schedule through the year.
WHEREFORE, the Defendant/Mother respectfully requests this Honorable
Court to dismiss Plaintiff/Father's Petition for Contempt and direct that the
parties implement a gradual custody schedule that would allow the Minor Child to
be re-introduced to her Father slowly and allow a schedule to be implemented
around the Minor Child's extracurricular activities.
DATE r
Respectfully submitted,
ABOM & KUTULAKIS, L.L.P.
F?-
Michelle L. So r
Supreme Court ID #93034
2 West High Street
Carlisle, Pennsylvania 17013
(717) 249-0900
Attorney for Defendant
VERIFICATION
I, MICHELLE SMITH, now known as, MICHELLE FOLTZ, verify that the
statements made in this Answer to Plaintiffs Petition for Modification and Contempt
and Defendant's New Matter are true and correct to the best of my knowledge,
information, and belief. I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
Date CP Z 1 )Lp
MICHELL FOLTZ
MICHAEL SMITH,
Plaintiff
VS.
MICHELLE SMITH,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-260 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
FILE COPY
omm W caw
AND NOW, this 0 61 day of A
consideration of the attached Cust 2000, upon
ody Conc liation Report, it is ordered
and directed as follows:
1. The Father, Michael Smith, and the Mother, Michelle Smith, shall
have shared legal custody of Brittany Marie Smith, born September 5, 1995.
Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions
regarding her health, education and religion.
2. The Mother shall have primary physical custody of the Child.
3. The Father shall have partial physical custody of the Child every
week from Sunday at 9:00 a.m. through Monday at 8:00 p.m., beginning April
2, 2000.
4. The parties shall share or alternate having custody of the Child
on holidays as follows:
A. CLEUSTMAS: The Christmas holiday shall be divided into
Segment A, which shall run from Christmas Eve at 12:00 noon
through Christmas Day at 12:00 noon, and Segment B, which
shall run from Christmas Day at 12:00 noon through December 26
at 12:00 noon. The Father shall have custody o.' ' the Child
during Segment A in even numbered years and during Segment B
in odd numbered years. The Mother shall have custody of the
Child during Segment A in odd numbered years and during
Segment B in even numbered years.
B. NEW YEARS: The New Years holiday shall be divided into
Segment A, which shall run from New Years Eve at 12:00 noon
through New Years Day at 12:00 noon, and Segment B, which
shall run from New Years Day at 12:00 noon through January 2
at 12:00 noon. The Father shall have custody of the Child
during Segment A in even numbered years and during Segment B
in odd numbered years. The Mother shall have custody of the
Child during Segment A in odd numbered years and during
Segment B in even numbered years. For purposes of this
paragraph, the entire New Years holiday shall be deemed to
fall within the same year as New Years Eve.
C. FASTER: On Easter Sunday in 20001 the Mother shall have
custody of the Child until 4:00 p.m. and the Father shall have
custody of the Child from 4:00 p.m. on Easter through
termination of his regular period of weekly custody. In
subsequent years, the Mother shall have custody of the Child
on Easter Sunday until 3:00 p.m. and the Father shall have
custody of the Child on Easter beginning at 3:00 p.m. and
continuing through termination of his regular period of weekly
custody.
D. THANKSGIVING: In every year, the Mother shall have custody of
the Child on Thanksgiving Day until 3:00 p.m. and the Father
shall have custody of the Child on Thanksgiving Day from 3:00
p.m. until 8:00 p.m.
E. MEMORIAL DAY: The Father shall have custody of the Child on
Memorial Day in even numbered years from 9:00 a.m. until 8:00
p.m. and the Mother shall have custody of the Child on
Memorial Day in odd numbered years from 9:00 a.m. until 8:00
p.m.
F. IMEPENDENCE DAY (Observed): The Father shall have custody of
the Child on Independence Day in odd numbered years from 9:00
a.m. until after the fireworks and the Mother shall have
custody of the Child in even numbered years from 9:00 a.m.
until after the fireworks.
G. LABOR DAY: The Father shall have custody of the Child every
year on Labor Day until 8:00 p.m.
H. MOT'S DAY/FATHER'S DAY: The Mother shall have custody of
the Child every year on Mother's Day until 1:00 p.m. and, the
Father shall have custody of the Child every year on Father's
Day in accordance with the regular custody schedule.
1. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
J. In the event the Father's period of holiday custody falls
immediately preceding or following his regular period of
custody, the Father's holiday/regular period of custody shall
run continuously.
5. Each party shall be entitled to have custody of the Child for 1
uninterrupted week during each summer school vacation upon providing at
least 30 days advance notice to the other party. The party providing
notice first shall be entitled to preference of his or her selection of
vacation dates.
6. The Father shall be responsible to provide all transportation for
exchanges of custody unless otherwise arranged by the parties.
7. In the event the Father is unavailable to provide care during his
periods of custody with the Child, the Father shall contact the Mother to
offer her the opportunity to care for the Child before contacting third
party caregivers.
8. 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,
S
J.
cc: Michael J. Pykosh, Esquire - Counsel for Father
Bryan S. Walk, Esquire - Counsel for Mother
TRUE COPY FRONV.
In Testimony v;h:r, oI, i here unto set my hand
SW the seal of said Courts at Carkl:;, Pa.
' h day of.RP.RIL..,
Prothonota
MICHAEL SMITH, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 00-260 CIVIL TERM
MICHELLE SMITH, CIVIL ACTION - LAW
Defendant IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
1N 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 DATE OF BIRTH CURRENTLY IN CUSIIODY OF
Brittany Marie Smith September 5, 1995 Mother
2. A Custody Conciliation Conference was he'd on March 28, 2000, with
the following individuals in attendance: The Father, Michael Smith, with
his counsel, Michael J. Pykosh, Esquire, and the Mother, Michelle Smith,
with her counsel, Bryan Walk, Esquire.
3. The parties agreed to entry of an order in the form as attached.
fi7
Date Dawn S. Sunday, Esquire
Custody Conciliator
MICHAEL SMITH,
Plaintiff
VS.
MICHELLE SMITH,
Defendant
IN THE OOURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-260 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
ANDr th. G 1 day of ?GL rJ t,t,
consideration of the attached Custody Conciliation Rep rt, it isord
vupon
and directed as follows:
1. The prior Order of this Ccurt dated September 6, 2000 is vacated
and replaced with this Order.
2. The prior Order of this Court dated April 4, 2000 shall continue
in effect with the exception of paragraphs 3 and 61 which are modified by
this Order.
3. Beginning Friday, January 19, 2001, the Father shall have partial
physical custody of the Child in accordance with the following schedule:
A. Every Friday, the Mother shall transport the Child to the
Father's residence at 7:00 a.m. and the Father shall have
custody of the Child until 1:30 p.m., when the Father shall
transport the Child to the maternal grandparent's residence.
B. Every Friday, the Father shall pick up the Child at the
Mother's residence between 9:45 and 10:00 p.m. and retain
custody of the Child through Saturday at 1:30 p.m., when the
parties shall exchange custody of the Child at the Capitol
City Mall Sears Auto Center.
C. Every Saturday, the Father shall pick up the Child at the
Mother's residence between 9:45 p.m. and 10:00 p.m. and shall
retain custody through Monday at 8:00 p.m. when the Father
shall transfer custody of the Child to the Mother at the
Capitol City Mall Sears Auto Center.
4. The parties shall jointly obtain instructions from the Child's
physician regarding treatment of the Child's allergies, including limiting
or prohibiting the Child's contact with animals during periods of custody
with both parties.
EXHIBIT
5. This Oder is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of
this Cyder by mutual consent. In the absence of mutual consent, the terms
of this Order shall control.
BY THE COURT,
.S
Edgar B. ayley, J,
cc: Michael J. Pykosh, Esquire - Counsel for Father
Bryan S. Walk, Esquire - Counsel for Mother
In
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Prothonota
MICHAEL SMITH,
Plaintiff
VS.
MICHELLE SMITH,
Defendant
PRIOR JUDGE: Edgar B. Bayley
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-260 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMERLAND 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:
DATE OF BIRTH CURRENTLY IN CUSMDY OF
Brittany Marie Smith September 5, 1995
Mother/Father
2. A Custody Conciliation Ccnference was held on January 16, 2001,
with the following individuals in attendance: The Father, Michael Smith,
with his counsel, Michael J. Pykosh, Esquire, and the Mother, Michelle
Smith, with her counsel, Bryan S. Walk, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date r f??
Dawn S. Sunday, Esquire
Custody Conciliator
AND NOW, this 23rd day of June, 2011, I, Michelle L. Sommer, Esquire, of
Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of
the foregoing Answer to Plaintiffs Petition for Modification and Contempt and
Defendant's New Matter, upon the Plaintiff, through his attorney, by depositing, or
causing to be deposited, same in the United States Mail, First-class mail, postage
prepaid addressed to the following:
Sheri D. Coover, Esquire
44 South Hanover Street
Carlisle, PA 17013
Attorney for the Plaintif
Respectfully submitted,
AB0M & KUTULATaS, L.L.P.
i
Michelle L. So er, Esquire
Supreme Court ID #93034
2 West High Street
Carlisle, PA 17013
(717) 249-0900
Attorney for Defendant
3
MICHAEL SMITH IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2000-260 CIVIL ACTION LAW
Ml CHELLE FOLTZ
Defendant IN CUSTODY
C-)
ORDER OF COURT
AND NOW, this S day of GIG L1,S 2011, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated January 19, 2001 is vacated and replaced with this
Order.
2. The Mother, Michelle Foltz, and the Father, Michael Smith, shall have shared legal custody
of Brittany Smith, born September 5, 1995. Major decisions concerning the Child including, but not
necessarily limited to, her 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 interest. Neither party shall impair the other party's rights to
shared legal custody of the Child. 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. §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 of the Child.
4. The Father shall have partial physical custody of the Child in accordance with the following
gradually increasing schedule:
A. The Father shall have custody of the Child on Friday, July 29, 2011 frbm 10:00 a.m.
until 4:00 p.m.
B. The Father shall have custody of the Child every Wednesday `and Thursday,
beginning August 3 and ending on August 18, from 10:00 a.m. until 4:00 p.m.a
C. The Father shall have custody of the Child from August 24, 2011 at 10:00 a.m.
through August 25, 2011 at 4:00 p.m. and from August 31, 2011 at 10:00 a.m. through September 1,
20: 1 at 4:00 p.m.
D. Beginning on September 9, 2011 and continuing thereafter on alternating weekends,
the Father shall have custody of the Child from Friday at 7:30 p.m. through Sunday at 7:00 p.m.
E. The Father may also have additional periods of custody with the Child as arranged
by agreement between the parties.
F. The Father shall provide transportation for all exchanges of custody until the
Father's custodial periods are expanded to alternating weekends. For alternating weekend periods of
custody, the parent receiving custody of the Child shall be responsible to provide transportation for the
exchange of custody.
5. The parties acknowledge that the agreed upon arrangements for alternating weekend periods
of custody are based on the understanding that the Father will generally have off work during his
periods of weekend custody. In the event that the Father is routinely working during periods of
custody, during which the parties shall make arrangements for the Child to be with either the Mother or
the maternal grandparents, on a frequent basis, counsel for either party may contact the conciliator to
schedule a telephone conference to address the issue of the Father's unavailability on his custodial
weekends.
6. The parties shall share having custody of the Child for the Christmas holiday every year,
with the Father having custody from Christmas Eve at 11:00 a.m. through Christmas Day at 11:00 a.m.
and the Mother having custody from Christmas Day at 11:00 a.m. through December 26 at 11:00 a.m.
7. The parties shall share having custody of the Child on the remaining holidays as arranged
by agreement.
8. The parties may have periods of vacation custody with the Child as arranged by agreement
between the parties.
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 T OURT,
J.
cc: Sheri D. Coover, Esquire - Counsel for Father
Michelle L. Sommer, Esquire - Counsel for Mother yes
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I
MICHAEL SMITH IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2000-260 CIVIL ACTION LAW
MICHELLE FOLTZ
Defendant IN CUSTODY
Prior Judge: Edgar B. Bayley
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 DATE OF BIRTH CURRENTLY IN CUSTODY OF
Brittany Smith September 5, 1995 Mother
2. A custody conciliation conference was held on July 26, 2011, with the following individuals
in attendance: the Father, Michael Smith, with his counsel, Sheri D. Coover, Esquire, and the Mother,
Michelle Foltz, with her counsel, Michelle L. Sommer, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
el?
," d - ;off!
Date Dawn S. Sunday, Esquire
Custody Conciliator