HomeMy WebLinkAbout05-0573TANNER LAW OFFICES, LLC
1300 Market Street, Suite 6
Lemoyne, PA 17043
Phone (717) 731-8114/ Fax (717) 731-8115
Attorney for Plaintiff
GINA M. DEHAVEN, §
Plaintiff §
V. §
MICHAEL L. SAMPLES, §
Defendant §
The Plaintiff is Gina M. Dehaven, residing at 137A Market Street, New
COMPLAINT FOR CUSTODY
2
3.
4.
5
Cumberland, Cumberland County, Pennsylvania 17070.
The Defendant is Michael L. Samples, residing at 590 Rosstown Road,
Lewisberry, York County, Pennsylvania 17339.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CUSTODY/VISITATION
NO. as-s?3
Plaintiff seeks custody of the following child:
Name
Present Address
Age
Ashlynne Marie Samples 137A Market St. 1
New Cumberland, PA 17070 (D.O.B. 5/29/03)
The child was born out of wedlock
The child is presently in the custody of the Plaintiff, Gina M. Dehaven, who
resides at 137 A Market Street, New Cumberland, PA 17070.
6.
7
8
9
10.
II
During the last five years, the child has resided with the following persons at
the following addresses:
Persons :
Gina M. Dehaven
Address:
137A Market St.
New Cumberland, PA 17070
Dates:
12/30/04-present
Gina M. Dehaven
Michael L. Samples
590 Rosstown Rd.
Lewisberry, PA 17339
5/03 - 12/30/04
The mother of the child is Plaintiff, Gina M. Dehaven, currently residing at
137A Market Street, New Cumberland, PA 17070. She is single.
The father of the child is Defendant, Michael L. Samples, currently residing at
590 Rosstown Road, Lewisberry, PA 17339. He is single.
The relationship of the Plaintiff to the child is that of mother.
The relationship of the Defendant to the child is that of father. The Defendant
currently resides with the following persons:
Name Relationship
Pixie Karge Girlfriend
Plaintiff has not participated as a party in other litigation concerning the
custody of the child in a court of this Commonwealth or any other state.
12. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child and claims to have custody or visitation rights
with respect to the child.
13. Each parent whose parental rights to the child have not been terminated and the
person who has physical custody of the child have been named as parties to this
action.
14. The best interests and permanent welfare of the child will be served by granting
the relief requested. The quality of the child's physical, intellectual, moral and
spiritual environment would be improved by Plaintiff's continuation as primary
caregiver.
WHEREFORE, Plaintiff requests the Court to grant Custody of the Child.
Respectfully submitted,
DATE: a7 05 G"0. /.l?/ylOic
Tabetha A. Tanner, Esquire
Supreme Court I.D. No.: 91979
Attorney for Plaintiff
TANNER LAW OFFICES, LLC
1300 Market Street, Suite 6
Lemoyne, PA 17043
(717) 731-8114
VERIFICATION
I verify that the statements made in this custody complaint are true and correct. I
understand that false statements made herein are made subject to the penalties of 18 Pa.C.S.
§4904 relating to unsworn falsification to authorities.
Date: 001D
J na M. Dehaven
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GINA M. DEHAVEN IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
MICHAEL L. SAMPLES
DEFENDANT
05-573 CIVIL ACTION LAW
. IN CUSTODY
ORDER OF COURT
AND NOW, Friday, February 04, 2005 _, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator,
at DJ Manlove's, 1901 State St., Camp Hill, PA 17011 on Monday, February 21, 2005 at 9:30 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. All children age five or older may also be present at the conference. 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/ Melissa P. Greew, Esq.
Custody Conciliator 1 l
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) 249-3165
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GINA M. DEHAVEN,
Plaintiff
V.
MICHAEL L. SAMPLES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CUSTODYNISITATION
NO. os- L?K
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I served a copy of the Custody Complaint, filed in the
above-captioned matter, upon Michael L. Samples, via first class mail, postage prepaid,
certified, restricted delivery, return receipt requested, addressed as follows:
Mr. Michael L. Samples
590 Rosstown Road
Lewisberry, PA 17339
Date: Jo b S
Respectfully submitted,
Tabetha A. Tanner, Esquire
Supreme Court I.D. No.: 91979
Attorney for Plaintiff
TANNER LAW OFFICES, LLC
1300 Market Street, Suite 6
Lemoyne, PA 17043
(717) 731-8114
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GINA M. DEHAVEN,
Plaintiff
V.
MICHAEL L. SAMPLES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-573 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
TEMPORARY ORDER OF COURT
AND NOW, this 10' day of March, 2005, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Legal Custody. The parties, Gina M. DeHaven and Michael L. Samples, shall
have shared legal custody of the minor child, Ashlynne Marie Samples, born May 22, 2003.
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. Pursuant to the terms
of 23 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining
to the child including, but not limited to, medical, dental, religious or school records, the
residence address of the child and of the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
2. Physical Custody. The parties' schedule is arranged on a two (2) week
alternating basis as follows:
A. Week One - Effective February 18, 2005, and alternating weeks
thereafter, Father will have custody from Friday at 2:00 p.m. until Sunday at
4:00 p.m.; from Monday at 8:00 p.m. until Wednesday at 2:00 p.m.; and
Wednesday at 8:00 p.m. until Friday at 2:00 p.m. Mother's periods of custody
during Week One are from Sunday at 4:00 p.m. until Monday at 8:00 p.m. and
Wednesday at 2:00 p.m. until 8:00 p.m.
B. Week Two - Effective February 25, 2005, and alternating weeks
thereafter, Mother will have custody from Friday at 2:00 p.m. until Sunday at
8:00 p.m.; Monday from 2:00 p.m. to 8:00 p.m.; and Wednesday from 2:00
p.m. to 8:00 p.m. Father's periods of custody during Week Two are from
Sunday at 8:00 p.m. until Monday at 2:00 p.m., Monday at 8:00 p.m. to
Wednesday at 2:00 p.m., and Wednesday at 8:00 p.m. until Sunday at 4:00
p.m.
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NO. 05-573 CIVIL TERM
C. During Week Two, in the event that Mother is off on Monday or
Wednesday, Mother's custodial time shall be extended overnight until 2:00
p.m. the next day. In the event that Mother has off of work during Week Two
on Tuesday or Thursday, her custodial period for those days will be from 2:00
P.M. to 8:00 P.M.
D. This schedule was crafted by the parties, with assistance of
counsel, based on Mother working an 11:00 p.m. to 7:00 a.m. shift and Father
working a 6:00 a.m. to 2:00 p.m. shift.
3. Babvsitter Arrangements. In the event that both parties are working, or Mother
is sleeping following an 11:00 p.m. to 7:00 a.m. shift, the Paternal Grandparents will function
as the child's babysitter. The backup babysitter will be Michelle.
4. The Custody Conciliation Conference shall reconvene on April 22, 2005
at 1:00 p.m. before the Custody Conciliator, Melissa Peel Greevy, Esquire, 1901 State
Street, Camp Hill, PA 17011.
BY THE COURT:
J.
Dist: vT?betha A. Tanner, Esquire, 1300 Market Street, Suite 6, Lemoyne, PA 17043
, ¢abeth B. Stone, Esquire, 414 Bridge Street, New Cumberland, PA 17070
J
03
GINA M. DEHAVEN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-573 CIVIL TERM
V.
MICHAEL L. SAMPLES,
CIVIL ACTION - LAW
IN CUSTODY
Defendant
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 THE CUSTODY OF
Ashlynne Marie Samples May 29, 2003
Mother
2. The parties' first Custody Conciliation Conference was held on February 18,
2005 following Mothers filing of a Complaint for Custody on February 1, 2005. Present for
the conference were: the Mother, Gina M. DeHaven, and her counsel, Tabetha A. Tanner,
Esquire; the Father, Michael L. Samples, and his counsel, Elizabeth B. Stone, Esquire.
3. The parties reached an agreement for a Temporary Order which includes a
provision for the parties to return to Custody Conciliation in ap ately two (2) months.
19 /6, 2/0,6
Date
Melissa Peel Greevy, Es e
Custody Conciliator
:245617
RECEIVED JUN 0 7 2005y
GINA M. DEHAVEN,
Plaintiff
V.
MICHAEL L. SAMPLES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-573 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER TO RELINQUISH JURISDICTION
AND NOW, this 6`h day of June, 2005, counsel for the Plaintiff having advised the Conciliator
of the parties' reconciliation and requesting cancellation of the Custody Conciliation Conference
scheduled for April 22, 2005, the Conciliator hereby relinquishes jurisdiction of the above captioned
matter.
FOR THE COURT:
M lissa Peel Greevy, E quire
Custody Conciliator
:252177
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GINA M. DEHAVEN, : IN THE COURT OF COMMON PLEAS
Plaintiff : COUNTY, PENNSYLVANIA
NO. 05-573 C ?;
MICHAEL L. SAMPLES, CIVIL ACTION - CUSTODY
Defendant
PETITION FOR EXPEDITED CONCILIATION CONFERENCE-
co -<
AND NOW comes the Defendant, Gina M. DeHaven, by and through her attorney, Gary
L. Kelley, and respectfully Petitions this Honorable Court as follows:
1. Plaintiff/Petitioner is Gina M. DeHaven who resides at 1593 English Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. Defendant is Michael L. Samples who resides at 590 Rosstown Road, Lewisberry,
Pennsylvania 17339.
3. The parties are the parents of two (2) minor children, Ashlynne Marie Samples,
date of birth, May 29, 2003, and Cassandra Leigh Samples, date of birth January 17, 2006.
4. On March 10, 2005, this Honorable Court entered an Order for Custody after a
Custody Conciliation Conference before the Custody Conciliator Melissa Peel Greevy, Esq. A
true and correct copy of this Order is attached hereto as Exhibit "A."
5. A period of time after the Order was entered, the parties reconciled and began
living together at the Lewisberry address.
6. However, the Order was never modified by either party and remains in full force
and effect.
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7. The Plaintiff, the mother of the children, has not worked and has always provided
for the care and welfare of the children whether the Defendant was at home or work.
8. The children view their mother as a source of love and affection.
9. At least during the past two (2) years, the Defendant has developed an overriding
addiction to alcohol which has adversely affected his relationship with the Plaintiff and the minor
children.
10. On any number of occasions, the Defendant has belittled and denigrated the
Plaintiff in the presence of the minor children. His explosive outbursts and attempts to physically
assault the Plaintiff have placed the minor children in physical jeopardy and fear for their safety.
12. On March 8, 2010, the Defendant's explosive outbursts and violent behavior
culminated with an assault upon the Plaintiff and one of the minor children.
13. The Defendant also ripped the telephone out of the wall of the home and took the
Plaintiffs car keys from her so she could not leave.
14. The Plaintiff called the police and criminal charges are now pending against the
Defendant.
15. As a result, the Plaintiff is now living with her father without the children as the
Defendant would not permit her to leave with the children.
16. The Defendant has withheld the children from the Plaintiff since March 8, 2010.
17. The Plaintiff is concerned for the welfare of the minor children given the
Defendant's work schedule, his erratic behavior, explosive outbursts, and out of control drinking.
I
18. It is in the best interests of the minor children that they be placed in the primary
custody of the Plaintiff.
19. This matter has previously been before the Honorable Kevin A. Hess.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an
emergency order expeditiously scheduling this matter for a Conciliation Conference hearing on
Plaintiffs Petition.
Respectfully submitted,
Gary V. Kelley
ID No. 801 (,f
3117 Chestnut Street
Camp Hill, PA 17011
(717) 612-1484
Attorney for Plaintiff
EXHIBIT A
BAR u ?
GINA M. DEHAVEN, : IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 05-573 CIVIL TERM
V.
MICHAEL L. SAMPLES,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
TEMPORARY ORDER OF COURT
AND NOW, this o' day of March, 2005, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Legal Custody. The parties, Gina M. DeHaven and Michael L. Samples, shall
have shared legal custody of the minor child, Ashlynne Marie Samples, bom May 22, 2003.
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. Pursuant to the terms
of 23 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining
to the child including, but not limited to, medical, dental, religious or school records, the
residence address of the child and of the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
2. Physical Custody. The parties' schedule is arranged on a two (2) week
alternating basis as follows:
A. Week One - Effective February 18, 2005, and altemating weeks
thereafter, Father will have custody from Friday at 2:00 p.m. until Sunday at
4:00 p.m.; from Monday at 8:00 p.m. until Wednesday at 2:00 p.m.; and
Wednesday at 8:00 p.m. until Friday at 2:00 p.m. Mother's periods of custody
during Week One are from Sunday at 4:00 p.m. until Monday at 8:00 p.m. and
Wednesday at 2:00 p.m. until 8:00 p.m.
B. Week Two - Effective February 25, 2005, and alternating weeks
thereafter, Mother will have custody from Friday at 2:00 p.m. until Sunday at
8:00 p.m.; Monday from 2:00 p.m. to 8:00 p.m.; and Wednesday from 2:00
p.m. to 8:00 p.m. Father's periods of custody during Week Two are from
Sunday at 8:00 p.m. until Monday at 2:00 p.m., Monday at 8:00 p.m. to
Wednesday at 2:00 p.m., and Wednesday at 8:00 p.m. until Sunday at 4:00
p.m.
NO. 05-573 CIVIL TERM
C. During Week Two, in the event that Mother is off on Monday or
Wednesday, Mother's custodial time shall be extended overnight until 2:00
p.m. the next day. In the event that Mother has off of work during Week Two
on Tuesday or Thursday, her custodial period for those days will be from 2:00
P.M. to 8:00 P.M.
D. This schedule was crafted by the parties, with assistance of
counsel, based on Mother working an 11:00 p.m. to 7:00 a.m. shift and Father
working a 6:00 a.m. to 2:00 p.m. shift.
3. Babysititer /ffmiemeft. In the event that both parties are working, or Mother
is sleeping following an 11:00 p.m. to 7:00 a.m. shift, the Paternal Grandparents will function
as the child's babysitter. The backup babysitter will be Michelle.
4. The Custody Conciliation Conference shall reconvene on April 22, 2005
at 1:00 p.m. before the Custody Conciliator, Melissa Peel Groovy, Esquire, 1901 State
Street, Camp Hill, PA 17011.
BY THE COURT:
J.
Dist: Woawm A. Tanner. Esquire, 130o Nankai svwt, Suite 6, Lemoyne, PA 17043
mebeth S. SIona, EsgWM, 414 86* Street, New Cumberland, PA 17070
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GINA M. DEHAVEN, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff :
NO. 05-573 CIVIL TERM
V.
CIVIL ACTION - LAW
MICHAEL L. SAMPLES, ;
IN CUSTODY
Defendant
CSISTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-9, 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 THE CUSTODY OF
Ashlynne Marie Samples May 29, 2003
Mother
2. The parties' first Custody Conciliation Conference was held on February 18,
2005 following Mother's filing of a Complaint for Custody on February 1, 2005. Present for
the conference were: the Mother, Gina M. DeHaven, and her counsel, Tabetha A. Tanner,
Esquire; the Father, Michael L. Samples, and his counsel, Elizabeth B. Stone, Esquire.
3. The parties reached an agreement for a Temporary Omer which includes a
provision for the parties to return to Custody Conciliation in a tely two (2) months.
aiP/o6 7.
Date Melissa Peel Greevy, EsgIAfe
Custody Conciliator
:245617
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn
falsification to authorities.
/ ,Jr a
Date: / &q ???-
GINA M. DEHAVEN, : IN THE COURT OF COMMON PLEAS
Plaintiff : COUNTY, PENNSYLVANIA
V. NO. 05-573
MICHAEL L. SAMPLES, CIVIL ACTION - CUSTODY
Defendant
CERTIFICATE OF SERVICE
I, GARY L. KELLEY, Esquire, attorney for Plaintiff in the above-captioned matter, do
hereby certify that I served a true and correct copy of Plaintiffs PETITION FOR EXPEDITED
CONCILIATION CONFERENCE on counsel for Defendant by first class mail, postage prepaid,
on the 12TH day of March, 2010, addressed as follows:
Elizabeth Stone, Esq.
414 Bridge Street, PO Box E
New Cumberland, PA 17070-1927
T. Vt9kj,
GARY L. ELLE , Esquir
I.D. #46801
3117 Chestnut Street
Camp Hill, PA 17011
(717) 612-1484
Attorney for Plaintiff
GINA M. DEHAVEN IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
MICHAEL L. SAMPLES
DEF[:NDANT
2005-573 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, March 16, 2010 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 Monday, April 05, 2010 at 1:30 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
Bv: _/s/ Dawn S. Sunday, Es_q_,.IkA
Custody Conciliator r
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilitcs Act of 1990. For information about accessible facilities and reasonable accommodations
availahle 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 schedules
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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GINA M. DEHAVEN, : IN THE COURT OF COMMON PLEAS
Plaintiff : COUNTY, PENNSYLVANIA
V. NO. 05-573
MICHAEL L. SAMPLES, CIVIL ACTION -CUSTODY
Defendant
PRAECIPE TO DISCONTINUE ACTION
TO THE PROTHONOTARY:
Kindly withdraw and discontinue the Custody Action filed by the Defendant on
or about March 11, 2010.
Respectfully submitted,
Gary L. ell
ID No. 46901
3117 Chestnut Street
Camp Hill, PA 17011
(717) 612-1484
Attorney for Plaintiff
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MAR 3 0 2010
GINA M. DEHAVEN
vs.
MICHAEL L. SAMPLES
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
2005-573
CIVIL ACTION LAW
IN CUSTODY
ORDER
AND NOW, this 23rd day of March, 2010 , the conciliator, being advised by the
Plaintiff Mother that the parties have reconciled and she wishes to withdraw her Petition, hereby
relinquishes jurisdiction. The custody conciliation conference scheduled for April 5, 2010, is
cancelled.
FOR THE COURT,
Dawn S. Sunday, Esquire
Custody Conciliator
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