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HomeMy WebLinkAbout04-6101CHRISTOPHER P. BRUNNER, Plaintiff V. ELIZABETH J. BRUNNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. c9l ' 61'2r CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Christopher P. Brunner, an adult individual currently residing at 4121 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Elizabeth J. Brunner, an adult individual currently residing at 4121 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. The parties are the natural parents of one (1) child, namely, Matthew James Brunner, born January 5, 1999. The child was not born out of wedlock. 4. For the past five (5) years, or since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS DATES Christopher P. Brunner and 4121 Nantucket Drive 6/01-Present Elizabeth J. Brunner Mechanicsburg, PA Christopher P. Brunner and 73 Cherry Lane 3/99-6/01 Elizabeth J. Brunner Carlisle, PA Christopher P. Brunner, Elizabeth J. Brunner and JulieAnna DelCollo 3914 Brookridge Drive 3/99-5/99 Mechanicsburg, PA The natural mother of the child is Elizabeth J. Brunner who resides as aforesaid. 5 6. 7 8 She is married to Plaintiff but a divorce complaint was recently filed. The natural father of the child is Christopher P. Brunner who resides as aforesaid. He is married to Defendant but a divorce complaint was recently filed. The relationship of the Plaintiff to the child is that of natural father. The Plaintiff currently resides with the child and Defendant. The relationship of the Defendant to the child is that of natural mother. Defendant currently resides with the child and Plaintiff. Plaintiff has not participated as a parry or witness, or in any other capacity in other litigation, concerning custody of the child. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the child to grant the relief requested because: a) A divorce complaint was recently filed by Plaintiff and, since that time, Defendant has limited Plaintiff's opportunity to have contact with his son. b) At this time, Plaintiff believes it is in his son's best interest that he be awarded primary, physical custody of his son and to establish a custody schedule ensuring his contact with his son. c) Defendant has a learning disability and it is alleged she recently indicated she has suicidal thoughts; d) Defendant has also shown an inability to provide for the financial, physical, or emotional needs of the child including leaving the minor child with a babysitter for substantial periods of time so she can engage in inappropriate behavior; e) A member of Defendant's family contacted undersigned counsel and indicated a belief that, at this time, Plaintiff should be awarded primary physical custody of the minor child; and f) It is believed that Defendant may be having contact with an incarcerated male who may not be allowed to be around young children. 10. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff respectfully requests Your Honorable Court to enter an Order of Court providing him with primary physical and legal custody of the child. Respectfully submitted, Wendy J. F. Grell Esq ' e Attorney for Plaints 3618 N. 6' Street P.O. Box 5292 Harrisburg, PA 17110 (717) 234-6001 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. n 1 DATE: i/ CHRISTOPHER P. BRUNNER, Plaintiff r O 472 ( } "_r U r ' :i' jf t:L lea t "S'?1 CHRISTOPHER P. BRUNNER, Plaintiff V. ELIZABETH J. BRUNNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. O Z/ - 6 /° f CIVIL TERM IN CUSTODY PETITION FOR EMERGENCY RELIEF AND NOW, this (R.?day of December, 2004, comes Plaintiff, Christopher P. Brunner, by and through his attorney, Wendy J. F. Grella, Esquire, and respectfully avers the following: 1. Plaintiff is Christopher P. Brunner, an adult individual currently residing at 4121 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Elizabeth J. Brunner, an adult individual currently residing at 4121 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. The parties are the natural parents of one (1) child, namely, Matthew James Brunner, born January 5, 1999. The child was not born out of wedlock. 4. For the past five (5) years, or since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS DATES Christopher P. Brunner and 4121 Nantucket Drive 6/01-Present Elizabeth J. Brunner Mechanicsburg, PA Christopher P. Brunner and 73 Cherry Lane 3/99-6/01 Elizabeth J. Brunner Carlisle, PA Christopher P. Brunner, Elizabeth J. Brunner and JulieAnna DelCollo 3914 Brookridge Drive 3/99-5/99 Mechanicsburg, PA The natural mother of the child is Elizabeth J. Brunner who resides as aforesaid. 5 6. 7 8. She is married to Plaintiff but a divorce complaint was recently filed. The natural father of the child is Christopher P. Brunner who resides as aforesaid. He is married to Defendant but a divorce complaint was recently filed. The relationship of the Plaintiff to the child is that of natural father. The Plaintiff currently resides with the child and Defendant. The relationship of the Defendant to the child is that of natural mother. Defendant currently resides with the child and Plaintiff. Plaintiff has not participated as a parry or witness, or in any other capacity in other litigation, concerning custody of the child. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the child to grant the relief requested because: a) A divorce complaint was recently filed by Plaintiff and, since that time, Defendant has limited Plaintiff s opportunity to have contact with his son. b) At this time, Plaintiff believes it is in his son's best interest that he be awarded primary, physical custody of his son and to establish a custody schedule ensuring his contact with his son. c) Defendant has a learning disability and it is alleged she recently indicated she has suicidal thoughts; d) Defendant has also shown an inability to provide for the financial, physical, or emotional needs of the child including leaving the minor child with a babysitter for substantial periods of time so she can engage in inappropriate behavior; e) A member of Defendant's family contacted undersigned counsel and indicated a belief that, at this time, Plaintiff should be awarded primary physical custody of the minor child; and f) It is believed that Defendant may be having contact with an incarcerated male who may not be allowed to be around young children. 10. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff respectfully requests Your Honorable Court to enter an Order of Court providing him with primary physical and legal custody of the child. Respectfully submitted, Wendy I F. Grell Esq ' e Attorney for Pai 3618 N. 6th Street P.O. Box 5292 Harrisburg, PA 17110 (717) 234-6001 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: CHRISTOPHER P. BRUNNER, Plaintiff A EL LIJ LJ f CZ) N (-) v "J ?o n.. CHRISTOPHER P. BRUNNER, Plaintiff V. ELIZABETH J. BRUNNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 04-6101 CIVIL TERM : IN CUSTODY AFFIDAVIT OF SERVICE ? 2?? 1 AND NOW, this 1--? day of December, 2004, comes Wendy J. F. Grella, Esquire, Attorney for Plaintiff, and states that a true and attested copy of a Complaint for Custody and Petition for Emergency Relief were sent to the Defendant, Elizabeth Brunner, at 4121 Nantucket Drive, Mechanicsburg, Pennsylvania, 17055, by certified mail, return receipt requested. A copy of said receipt is attached hereto indicating that service was made oil December 8, 2004. Sworn and subscribei0ito before this day of 2004. 4 , AOL NOTARY PUBLIC Wendy J. F. ella, e Attorney for 3618 North Sixth Street P.O. Box 5292 Harrisburg, PA 17110 (717) 234-6001 NOTARIAL. SEAL LISA A. RICE, NOTARY PUBLIC CITY OF HARRISBURG, DAUPHIN COUNTY MY COMMISSION EMR63 OCTOBER 10, 2006 Postal i U.S. m v ..o (Domestic Only; No Insurance Coverage Provided) M h N W00 W" nj postage $ O Certified Fee ?O 12 0 112 ?o O Return fieciept Fee $1,15 (Endorsement Required) ?JJ\4r11 Restricted Delivery Fee ??i ?li ?? (Endorsement Required) r-q r-3 s4. $$ Total Postage & Fees C3 ent To , O Apt ------1----- or PO Box No. l l Z \ ? ----------- /?? 1 ----- - =n PS ity, State. ZlR+4 -- -- ------ ?X :rr iur- 20w Se, H, 1- 111100ct,ons ¦ Complete items 1, 2, and 3. Also complete natu XS re item 4 R Restricted Delivery Is desired. X ? Agent ¦ Print your name and address on the reverse Addressee so that we can return the card to you. 113. R Printed Name) C. Date of Delivery ¦ Attach this card to the back of the mailpiece, a Eq or on the front if space permits. Wtv ed Q(M!MF `? ? Yes 1. Article Addressed to: YES, enter del sa tel.. ? No 3. Service Type ? Certified IMall ? Express Mall ? Registered ? Return Receipt for Merchandise ? Insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number - - (Transfer from service 7004 1160 0 005 2378 76 03 /l.X1fx' PS Form 5811, ?elxu 2004 Domeetle Ret urn PAcW 1021595.02-M-11 540 -ri 'ci tx? c3 '-? r4Q -gym 7 r +.? ?? v MAR 2 3 2005 CHRISTOPHER P. BRUNNER Plaintiff vs. ELIZABETH J. BRUNNER Defendant IN THE COURT OF COMMON CUMBERLAND COUNTY, PENN 04-6101 CIVIL ACTION LA' IN CUSTODY ORDER AND NOW, this 21st day of March, 2005 , the conciliator, being that the parties have reconciled and no longer require the custody conciliation relinquishes jurisdiction. The Custody Conciliation Conference scheduled for March cancelled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator iAS OF VANIA by counsel hereby 2005 is ?jr= 7 CID 1 V.. N CHRISTOPHER P. BRUNNER, Plaintiff V. ELIZABETH J. BRUNNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-6101 CIVIL TERM IN CUSTODY CUSTODY STIPULATION & AGREEMENT THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between ELIZABETH J. BR UNNER, (hereinafter referred to as "Mother") and CHRISTOPHER P. BRUNNER, (hereinafter referred to as "Father") WHEREAS, the parties are the natural parents of one child, namely MATTHEW JAMES BRUNNER, born January 5, 1999, (hereinafter referred to as "Child"); and WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive stipulation and agreement relative to physical and legal custody of their Child. NOW THEREFORE, in consideration of mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: 1. Mother and Father shall have shared legal custody of the child. 2. Father shall have primary physical custody of the child. 3. Mother shall have periods of partial physical custody of the child at the following times: a.) On alternating weekends from 4:00 p.m. on Friday until Monday evening; b.) At other times as the parties may agree; and c.) Each parent may telephone Matthew once a day when the other parent has custody. 4. Mother agrees to provide transportation and appropriate accommodations, including meals, during her period of partial custody. 5. The Holidays of Thanksgiving, Christmas, Martin Luther King Day, Presidents' Day, Easter Weekend, Memorial Day, Fourth of July and Labor Day shall be shared as the parties may agree. 6. If during Mother's or Father's period of custody a parent is unable to directly care for the child and must make arrangements for a baby-sitter for a period of two (2) hours or more, the non-custodial parent shall have the right of first refusal to provide care for the child and the custodial parent shall make reasonable efforts to contact the non- custodial parent and make the child available for the non-custodial parent to care for the child during this time. In the event the non-custodial parent is unable to care for the child and declines this right of first refusal but the need for a baby-sitter still exists, then the minor child's Paternal Uncle, Andrew Brunner, shall have the right of second refusal to provide care for the child and the custodial parent shall make reasonable efforts to contact Paternal Uncle and make the child available for Paternal Uncle, Andrew Brunner to care for the child during this time. 7. The parties will attempt to accommodate an arrangement where the child shall always be with the Mother during Mother's Day weekend and with Father during Father's Day weekend. In the event this requires an exchange of weekends, the parties will attempt to accommodate each other to see that the child is with the respective parent on their designated Mother's Day weekend or Father's Day weekend. 8. Mother shall be entitled to exercise a one (1) week increment of custody during the child's summer vacation to begin on her regularly scheduled weekend period of custody. Mother shall provide at least sixty (60) days notice of the requested vacation period. Mother must be present with the child the entire one (1) week term of custody. 9. The child should not, UNDER ANY CIRCUMSTANCES, be left alone with any of Mother's friends or paramour(s) unless agreed by both parties. 4 dtSfance e A6 Alln tlie5 Av'w-ore- X? ??t?cr .nor ?a???t?' } -A rst ?f1?ev Pave4l 10.?Mother?hall Pao? move or relocate?withou providing with one hundred G wv?? twenty (120) days notice. 11. The parents shall permit and support their child's access to all family relationships. Special family events such as weddings, family reunions, family gatherings, funerals, graduations, etc. shall be accommodated by both parties, with routine visitations resuming immediately thereafter. Each parent shall have the option at the opposing time, or date variations to the other parent when special recreational options or other unexpected opportunities arise. 12. The parties shall keep each other advised in the event of serious illness or medical emergency concerning the child and shall further take any necessary steps to ensure that the health and well-being of the child is protected. During such illness or medical emergency, both parties shall have the right to visit the child as often as he or she desires consistent with the proper medical care of the child. 13. Neither party shall deny, obstruct or interfere with any reasonable requests of the child to make telephone contact with the other parent. 14. Neither parent shall do anything which may estrange the child from the other party, injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love and affection for the other party. 15. Any modification or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing, and only if executed with the same formality as this Stipulation and Agreement. 16. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties" minor child as he has resided for his entire life in Cumberland County, Pennsylvania. 17. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. 18. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. IN WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. WITNESSETH: y©?©L Date ELIZ ETH J. ER ?L/0-09 Date CHRIST PHER P. BRUNNER kk ? 2099 4'-P 25 FF' 2. 3 SEP 2 8 2009 CHRISTOPHER P. BRUNNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW ELIZABETH J. BRUNNER, : NO. 04-6101 CIVIL TERM Defendant IN CUSTODY ORDER OF COURT AND NOW this Z4 ' day of S ?G..lr•? 2009, the attached Custody Stipulation and Agreement is hereby made an Order of Court. BY THE COURT, cc: -'Wendy J. F. Grella, Esquire Attorney for Plaintiff J 6,43'avid Tamanini, Esquire Attorney for Defendant .! C F T X PR0flli ?, 0TA,,,' 2913 MAR 21 AM 11: 4 2 CUMBERLAND COUNT` PENNSYLVANIA CHRISTOPHER P. BRUNNER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,PENNA. V. NO. 04-6101 ELIZABETH J. BRUNNER, CIVIL LAW Defendant CUSTODY PETITION TO MODIFY CUSTODY ORDER 1. Plaintiff is Christopher P. Brunner(hereafter"Father"),who currently resides at 4121 Nantucket Drive,Mechanicsburg,Cumberland County, PA 17050. 2. Defendant is Elizabeth J. Brunner,now known as Elizabeth J. Ritter "Mother"),who currently resides at 1102 Yverdon Drive,Apt. C-8,Camp Hill,PA 17011. 3. The parties are the natural parents of one child,MATTHEW JAMES BRUNNER,born xx/xx/1999(age 14). 4. The parties entered into a Custody Agreement that was made an Order of Court on September 29,2009(copy attached). 5. The parties have not been strictly adhering to the Order,but have come up with agreed-upon alternatives to physical custody. The attached Order gives Father primary physical custody. However,Mother has had primary physical custody for approximately the last two years. 6. The best interest and permanent welfare of the child will be served by entering an Order for shared legal custody,with mother to continue to have primary physical owl SS3 � 4 ayes e2FO T1 custody,which time should include alternating weekends(currently Father has each and every weekend,which prevents Mother from taking vacations,from having daily outings, etc.,even though she does not work on the weekends). WHEREFORE,Mother requests the Court to enter an Order granting shared legal custody and granting her primary physical custody. < DATED: 3-)q")3 &af)m KEPNETH F. L S,ESQUIRE Attorney for Defendant 1101 N. Front St. 1 st Floor Harrisburg,PA 17102 (717)234-3136 Supreme Ct. I.D. #69383 VERIFICATION I hereby verify that the statements made in the foregoing document 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. Section 4904,relating to unworn falsification to authorities. DATED: / I—)3 K ELIZA TH J. BRW4NER n/k/a ELIZABETH J. RITTER • M CERTIFICATE OF SERVICE I certify I have served a true and correct copy of this document to Plaintiffs attorney by mailing same by U.S. Mail,postage prepaid at Harrisburg,PA,addressed to: Wendy J.F. Grella,Esq. 1119 North Front Street Suite 1 Harrisburg,PA 17102 DATED: 3/20/13 �GJ KE TH . LEWIS,ESQUIRE CHRISTOPHER P. BRUNNER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2004-6101 CIVIL ACTION LAW rn [ � xM x> ELIZABETH J.BRUNNER J C:) IN CUSTODY !Z= 7 . DEFENDANT >C- ORDER OF COURT AND NOW, Wednesday,March 27,2013 , 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 25,2013 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.Es q. OW 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 . �&7 l�Ven�q Gre _ �, l a�v r J �s CDC /1 60 Ike Cop -S C91 31.z 7/ice J CHRISTOPHER P. BRUNNER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2004-6101 CIVIL ACTION LAW � r x-,r ELIZABETH J. BRUNNER 7) -Um Defendant IN CUSTODY �!> co a--= C < "� c r� ORDER OF COURT 5(= cv --4r, AND NOW, this ` day of Y►1 fit, y 2013, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated September 29, 2009 adopting the parties' Custody Stipulation shall continue in effect as modified by this Order. 2. The parties shall have physical custody of the Child in accordance with the following bi- weekly schedule: A. Week 1: During Week I, the Mother shall have custody of the Child from Tuesday at 8:00 p.m. through Sunday at 6:00 p.m. and the Father shall have custody from Sunday at 6:00 p.m. through the following Tuesday at 8:00 p.m. B. Week II: During Week II, the Mother shall have custody of the Child from Tuesday at 8:00 p.m. through Saturday at 1:00 p.m. and the Father shall have custody from Saturday at 1:00 p.m. through the following Tuesday at 8:00 p.m. C. During the summer school break, the Father's periods of custody shall be extended through Wednesday at 8:00 p.m. each week on the condition that if the Father is working the night shift,the Child shall spend the overnight period with the Mother, the paternal grandmother, or the paternal uncle. The Child shall not spend the overnight period with the Father's girlfriend when the Father is working. D. The alternating biweekly schedule shall begin with the Mother having custody through Sunday at 6:00 p.m. on the weekend of May 4-5, 2013. 3. During the summer school break, the Father shall be entitled to have three nonconsecutive weeks and the Mother shall be entitled to have one week of vacation custody upon providing at least 30 days advance notice to the other parent. The parent providing notice first shall be entitled to his or selection weeks. Both parties shall schedule vacation weeks to include that party's regular weekend period of custody. Periods of vacation custody may be scheduled in smaller periods of less than full weeks as arranged by agreement between the parties. 4. The parties shall share having custody of the Child over the Christmas holiday each year with the Father having custody of the Child from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon and the Mother having custody from Christmas Day at 12:00 noon through December 26 at 12:00 noon. The parties shall share or alternate having custody of the Child on the remaining holidays as arranged by agreement. 5. The parent who is relinquishing custody of the Child for a period of custody shall provide transportation for the exchange. 6. The Mother shall contact the Child's school to make arrangements for Math tutoring if the Child's Math teacher believes it is advisable. The Mother shall advise the Father of two names of available tutors and their charges. The parties shall select the Math tutor by agreement. 7. Paragraph 9 of the Stipulation entered as an Order of this Court on September 29, 2009 is vacated. 8. The Father shall not leave the Child in the care of his girlfriend when the Father is not present without the advance consent of the Mother. 9. 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. 10. 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. 11. 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, t Kevin Hess J. cc: �nneth F. Lewis Esquire—Counsel for Mother Wendy J. F. Grella Esquire—Counsel for Father r.S /72h t l4. s W/3 CHRISTOPHER P. BRUNNER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2004-6101 CIVIL ACTION LAW ELIZABETH J. BRUNNER 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 AGE CURRENTLY IN CUSTODY OF Matthew Brunner 14 Mother/Father 2. A custody conciliation conference was held on April 25, 2013, with the following individuals in attendance: the Mother, Elizabeth J. Ritter(formerly Brunner), with her counsel, Kenneth F. Lewis Esquire, and the Father, Christopher P. Brunner, with his counsel, Wendy J. F. Grella Esquire. 3. The parties agreed to entry of an Order in the form as attached. 9 dQ 1 ?2 Date Dawn S. Sunday, Esquire Custody Conciliator