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HomeMy WebLinkAbout00-07027NMD MARIA F. TARAMELLI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA C-, ►.s vs. : NO. 00 - 7027 CIVIL -0 W zV JOSEPH S. DICKINSON, : CIVIL ACTION - LAW (or- r\,) Defendant : IN CHILD CUSTODY � 2 Q Prior Judicial assignment: Kevin A. Hess, Judge �? Prior Conciliator: Dawn Sunday, Esquire �' FATHER'S PETITION FOR MODIFICATION OF CHILD CUSTODY AND NOW, comes Defendant, Joseph S. Dickinson, by and through his counsel, Linda A. Clotfelter, who files this Petition to for Modification of Child Custody and in support thereof respectfully states the following: 1. Petitioner is Joseph S. Dickinson, (hereinafter "Father"), an adult individual who resides at 855 Club House Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. Father's Criminal Record Abuse History Verification is being filed concurrently with this Petition. 2. Respondent is Maria F. Taramelli, (hereinafter "Mother"), an adult individual who resides at 413 Cocklin Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The parties are the natural parents of one child, namely, Mallory G. Taramelli- Dickinson (hereinafter the "Child") born in February 14, 2000, now age Fourteen (14) years. 4. The parties share legal and physical custody of the Child (using a 2-2-3 schedule) per the Order of Court dated August 2, 2005, that was entered after a hearing. The Order also stated that the Order of March 10, 2004, shall remain in full force and effect. True and correct copies of the Orders are attached hereto collectively as Exhibit "A" and are incorporated herein. er3,00 � j 5. The August 2, 2005 Order authorized Mother to enroll the Child in St. Joseph's School in Mechanicsburg for the 2005-2006 school year and if she failed to do so it authorized Father to enroll her in the Cumberland Valley School District. 6. The Child will begin high school in the fall, however, the parties are unable to agree upon the high school the Child will attend. 7. After visiting both the Cumberland Valley High School and Trinity High school, the Child has stated that she wishes to attend Cumberland Valley High School. 8. The Child has some interests, such as JROTC that are not offered at Trinity High School. 9. Father seeks an Order of Court authorizing him to enroll the Child in the Cumberland Valley School District. 10. Father also believes that the best interest and permanent welfare of the Child will be served by granting Father primary custody for the following reasons: a. Weekday periods of custody at Father's home would better facilitate the Child's attendance at school due to bus schedules and availability and both parents' work schedules and availability. Simply put, Father, who works in Mechanicsburg, is more available to meet emergency and other issues that arise at school, than Mother who works in Hershey. b. Although the child has performed well at school with a shared custody schedule, it is likely that high school academics and activities will be more challenging and will require more structure in the child's home life for her to succeed. c. The Child has expressed to Father a strong preference to change the custody schedule increasing her time with her Father. WHEREFORE, Father respectfully requests that this Court enter an Order authorizing Father to enroll the Child in Cumberland Valley School District; granting the parties shared legal custody; primary physical custody to Father; partial physical custody to Mother; and such other relief as this Court deems just and proper. Date: Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER nda A. Clotfelter, Esquire ttorney ID No. 72963 4076 Market Street, Suite 100 Camp Hill, PA 17011 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Petitioner MARIA F. TARAMELLI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00 — 7027 CIVIL JOSEPH S. DICKINSON, : CIVIL ACTION — LAW Defendant : IN CHILD CUSTODY VERIFICATION I, JOSEPH S. DICKINSON, verify that the statements 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. § 4904, relating to unsworn falsification to authorities. Date: � 161. — P L( JI. DICKINSON Petitioner MARIA F. TARAMELLI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : 00-7027 CIVIL : CIVIL ACTION - LAW JOSEPH S. DICKINSON, Defendant : IN CUSTODY ORDER AND NOW, this 2 day of August, 2005, after hearing, the petition of the defendant for modification of the custody order is GRANTED to the extent that: 1. On the week following his non-custodial weekend, the father shall exercise custody of the child, Mallory Taramelli-Dickinson, born February 14, 2000, from Monday at 4:30 p.m. or after work, whichever is earlier, until Wednesday morning. at 8:00 a.m. or the beginning of the child's school day. 2. For the purpose of the existing order, a vacation week will be defined as a period of seven days beginning and ending on a Monday: Moreover, neither party shall exercise vacation rights in such a manner as to require the child to miss school without the other parent's written consent. 3. Mother's Day and Father's Day shall now be treated as holidays. i he mother shall have custody of Mallory on Mother's Day and the father shall have custody of Mallory on Father's Day. It is further directed that the mother is authorized to enroll Mallory at the St. Joseph's School in Mechanicsburg for the school year 2005-2006. Should she fail to do so, the father is authorized to enroll the child in the Cumberland Valley School District. To the extent that same is not inconsistent with the order entered this date, our order of March 10, 2004, shall remain in full force and effect. BY THE COURT, J. Paul Helvy, Esquire For the Plaintiff Theresa Barrett Male, Esquire For the Defendant :rim Kevin Hess, J. 'TRUE COV( tn TeT,tirnony whereo;, and t3 satof said RECORD .11) set -my hand rliste, Pa, MARIA F. TARAMELLI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. JOSEPH S. DICKINSON, Defendant : IN CUSTODY ORDER AND NOW, this / 0'4 day of March, 2004, following hearing, the custody order of July 25, 2002, is modified to provide that: 1. Legal Custody. Maria F. Taramelli (Mother) and Joseph S. Dickinson (Father) shall share legal custody of Mallory Dickinson, born 2/14/00. 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 affecting her health, education and religion. Pursuant to the terms of 23 Pa.C.S.A. 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 that 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. Both parents shall be entitled to full participation in all education and medical/treatment planning meetings and evaluations regarding the child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational records, attendance records or report cards. Additionally, each parent shall be : 00-7027 CIVIL : CIVIL ACTION - LAW entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, child's parties, musical presentations, back -to -school night, and the like. 2. Physical Custody. Physical custody of the minor child shall be as follows: a. Primary Custody. Mother shall have primary physical custody of the minor child. b. Partial Custody. Father shall exercise periods of partial custody on alternating weekends from Friday at 4:30 p.m. until Monday at 8:00 a.m. The alternating weekend schedule shall continue as heretofore. Father shall also exercise periods of partial custody during the week following his custodial weekend on Wednesday evening from 4:30 p.m. or after work, whichever is earlier, until Friday morning at 8:00 a.m. or the beginning of the child's school day. On the week following his non-custodial period, father shall exercise a period of partial custody from Monday at 4:30 p.m. or after work, whichever is earlier, until Tuesday evening at 7:30 p.m. 3. Vacation. During each calendar year, each parent shall be entitled to two (2) non- consecutive weeks of uninterrupted custody, to be taken over that parent's regularly scheduled weekend. A week is seven (7) days beginning and ending on a Friday. If the parties cannot agree, then the beginning and ending times shall be 3:30 p.m. Each parent shall notify the other by e-mail thirty (30) days in advance of the dates for that parent's vacation periods. Neither parent will take vacation during the last week of school, the last week before school starts, or during the other parent's holiday periods. The parent first notifying the other will have the choice of dates. 4. Holidays. The parties shall share holidays as follows: Even -Numbered Years Odd -Numbered Years Easter Father Mother Memorial Day M F July Fourth F M Labor Day M F Thanksgiving F M Christmas Schedule A M F Christmas Schedule B F M New Year's M F a. All holidays begin at 3:30 p.m. on the day before the holiday and end at 9:00 a.m. on the morning after the holiday. b. Christmas Schedule A begins on Christmas Eve at 12:00 noon and ends on Christmas Day at 12:00 noon. Cbrislinas Schedule B begins on Christmas Day at 12:00 noon and ends on December 26th at 12:00 noon. 5. Holidays take precedence over the other provisions of this order. 6. The party securing custody shall provide the transportation. This means that the parties may designate any responsible adult to assist them with transportation, and both parties shall have the right to notify the child's day care providers and schools of this designation. BY THE COURT, J. Paul Helvy, Esquire For the Plaintiff Theresa Barrett Male, Esquire For the Defendant :rlm TRUE COPY FROM RECORD In Testimony wher of, 1 here unto set my hand and Alla seal of sai Court a Carlisle, Pa. Th -f 10 MARIA F. TARAMELLI, Plaintiff vs. JOSEPH S. DICKINSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00 — 7027 CIVIL : CIVIL ACTION — LAW : IN CHILD CUSTODY CRIMINAL RECORD / ABUSE HISTORY VERIFICATION as I, JOSEPH S. DICKINSON, hereby swear or affirm, subject to penalties of law including 18 Pa.C.S. § 4904 relating to unsworn falsification, to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act, 42 Pa.C.S. §6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check all that apply Crime ❑ 18 Pa.C.S. Ch. 25 (relating to criminal homicide) 18 Pa.C.S. §2702 (relating to aggravated assault) 0 18 Pa.C.S. §2706 (relating to terroristic threats) Self Other household member Date of Sentence conviction, guilty plea, no contest plea or pending charges 0 O 18 Pa.C.S. §2709.1 (relating to stalking) O 18 Pa.C.S. §2901 (relating to kidnapping) O 18 Pa.C.S. §2902 (relating to unlawful restraint) 18 Pa.C.S. §2903 (relating to false imprisonment) Lil 18 Pa.C.S. §2910 (relating to luring a child into a motor vehicle or structure) O 18 Pa.C.S. §3121 (relating to rape) O 18 Pa.C.S. §3122.1 (relating to statutory sexual assault) 18 Pa.C.S. §3123 (relating to involuntary deviate sexual intercourse) 18 Pa.C.S. §3124.1 (relating to sexual assault) 18 Pa.C.S. §3125 (relating to aggravated indecent assault) O 18 Pa.C.S. §3126 (relating to indecent assault) O 18 Pa.C.S. §3127 (relating to indecent exposure) O 0 O 0 O 0 O 0 O 0 O 0 O 0 O 0 O 0 O 18 Pa.C.S. §3129 (relating to sexual intercourse with animal) O 18 Pa.C.S. §3130 (relating to conduct relating to sex offenders) O 18 Pa.C.S. §3301 (relating to arson and related offenses) 18 Pa.C.S. §4302 (relating to incest) O 18 Pa.C.S. §4303 (relating to concealing death of child) O 18 Pa.C.S. §4304 (relating to endangering welfare of children) O 18 Pa.C.S. §4305 (relating to dealing in infant children) O 18 Pa.C.S. §5902(b) (relating to prostitution and related offenses) O 18 Pa.C.S. §5903(c) or (d) (relating to obscene and other sexual materials and performances) O 18 Pa.C.S. §6301 (relating to corruption of minors) O 18 Pa.C.S. §6312 (relating to sexual abuse of children) O 18 Pa.C.S. §6318 (relating to unlawful contact with minor) O 0 O 0 O 0 O 0 O 0 O 0 O 0 O 0 O 0 LI 18 Pa.C.S. §6320 (relating to sexual exploitation of children) LI 23 Pa.C.S. § 6114 (relating to 0 contempt for violation of protection order or agreement) Driving under the influence of drugs or alcohol Manufacture, sale, delivery, holding, offering for sale or possession of any controlled substance or other drug or device 0 0 O 0 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other Date all that household apply member O A finding of abuse by a Children & Youth 0 0 Agency or similar agency in Pennsylvania or similar statute in another jurisdiction O Abusive conduct as defined under the Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction O Other: 0 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child. 5. If you are aware that the other party or members of the other parry's household has or have a criminal/abuse history, please explain: I verify that the information above is true and correct to the best of my knowledge, information or 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. JOGS. DICKINSON MARIA F. TARAMELLI IN THE COURT OF COMMON PLEAS OF PLAINTIFF V. JOSEPH S. DICKINSON DEFENDANT CUMBERLAND COUNTY, PENNSYLVANIA 2000-7027 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 22, 2014 , 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 Tuesday, June 10, 2014 10:00 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court (including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT, By: /s/ Dawn S. Sunday, Esq. op. Custody Conciliator t' 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. 1'es9s LL �,. eca441_ A4.� j. ikt y ► 2 s eLi.x/;), Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 t-, N t� MARIA F. TARAMELLI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00 — 7027 CIVIL JOSEPH S. DICKINSON, : CIVIL ACTION — LAW Defendant : IN CHILD CUSTODY CRIMINAL RECORD / ABUSE HISTORY VERIFICATION T'r; xx C") :: I, MARIA F. TARAMELLI, hereby swear or affirm, subject to penalties of law including 18 Pa.C.S. § 4904 relating to unsworn falsification, to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act, 42 Pa.C.S. §6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check all that apply Crime ❑ 18 Pa.C.S. Ch. 25 (relating to criminal homicide) ❑ 18 Pa.C.S. §2702 (relating to aggravated assault) ❑ 18 Pa.C.S. §2706 (relating to terroristic threats) Self Other Date of Sentence household conviction, member guilty plea, no contest plea or pending charges O 18 Pa.C.S. §2709.1 (relating to stalking) 18 Pa.C.S. §2901 (relating to kidnapping) 18 Pa.C.S. §2902 (relating to unlawful restraint) 18 Pa.C.S. §2903 (relating to false imprisonment) O 18 Pa.C.S. §2910 (relating to luring a child into a motor vehicle or structure) O 18 Pa.C.S. §3121 (relating to rape) O 18 Pa.C.S. §3122.1 (relating to statutory sexual assault) O 18 Pa.C.S. §3123 (relating to involuntary deviate sexual intercourse) O 18 Pa.C.S. §3124.1 (relating to sexual assault) 18 Pa.C.S. §3125 (relating to aggravated indecent assault) 18 Pa.C.S. §3126 (relating to indecent assault) O 0 O 0 O 0 18 Pa.C.S. §3127 (relating to 0 indecent exposure) O 18 Pa.C.S. §3129 (relating to 0 0 sexual intercourse with animal) 18 Pa.C.S. §3130 (relating to 0 0 conduct relating to sex offenders) O 18 Pa.C.S. §3301 (relating to 0 arson and related offenses) 18 Pa.C.S. §4302 (relating to incest) O 18 Pa.C.S. §4303 (relating to concealing death of child) O 18 Pa.C.S. §4304 (relating to endangering welfare of children) 18 Pa.C.S. §4305 (relating to dealing in infant children) O 18 Pa.C.S. §5902(b) (relating to prostitution and related offenses) O 18 Pa.C.S. §5903(c) or (d) (relating to obscene and other sexual materials and performances) O 18 Pa.C.S. §6301 (relating to corruption of minors) O 18 Pa.C.S. §6312 (relating to sexual abuse of children) 18 Pa.C.S. §6318 (relating to unlawful contact with minor) 0 O 0 O 0 O 0 O 0 U 18 Pa.C.S. §6320 (relating to sexual exploitation of children) ❑ 23 Pa.C.S. § 6114 (relating to contempt for violation of protection order or agreement) O Driving under the influence of drugs or alcohol 0 Manufacture, sale, delivery, holding, offering for sale or possession of any controlled substance or other drug or device O 0 O 0 O ❑ 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other Date all that household apply member ❑ A finding of abuse by a Children & Youth 0 0 Agency or similar agency in Pennsylvania or similar statute in another jurisdiction O Abusive conduct as defined under the Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction O Other: 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child. 5. If you are aware that the other party or members of the other party's household has or have a criminal/abuse history, please explain: I verify that the information above is true and correct to the best of my knowledge, information or 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. 0)4 6,14,41 Lte-44. MARIA F. TARAMELLI MARIA F. TARAMELLI IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2000-7027 CIVIL ACTION LAVA U Zr r-rluj = . JOSEPH S. DICKINSON r-yl (*- F . Defendant IN CUSTODY < co r ORDER OF COURT AND NOW, this g day of 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. Within one week of the date of the custody conciliation conference, the parties shall make arrangements for the parties and the Child to engage in therapeutic family counseling with a professional to be selected by agreement. The parties shall select the counselor and contact the counselor's office within one week following the conciliation conference to schedule the initial sessions. The purpose of the counseling shall be to address the school enrollment and custodial schedule issues in a cooperative manner conducive to the Child's best interests and emotional well- being. 2. On or before July 7, 2014, counsel for either party may contact the conciliator to request the scheduling of a hearing in the event the counseling process is not successful in resolving the outstanding issues. 3. Pending further Order of Court or agreement of the parties, the parties shall continue to share having legal and physical custody of the Child in accordance with the prior Orders of this Court dated August 2, 2005 and March 10, 2004. 4. Pending further Oder of Court or agreement of the parties, the Father shall be entitled to enroll the Child in the Cumberland Valley School District for cheerleading. The Mother shall make arrangements to transport the Child to cheerleading practices at Cumberland Valley which fall during the Mother's custodial time. 5. The Father shall have custody of the Child for vacation from August 8, 2014 through August 17, 2014, from Monday through Sunday but shall not have vacation custody for two consecutive weeks. 6. 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. 7. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, , X-/Z4 Kevin ess J. cc: Zj�Paul Helvy Esquire—Counsel for Mother ,/Linda A. Clotfelter Esquire—Counsel for Father i es / �'(, MARIA F. TARAMELLI IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2000-7027 CIVIL ACTION LAW JOSEPH S. DICKINSON 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 BIRTH YEAR CURRENTLY IN CUSTODY OF Mallory Taramelli-Dickinson 2000 Mother/Father 2. A custody conciliation conference was held on June 10, 2014, with the following individuals in attendance: the Mother, Maria F. Taramelli, with her counsel, J. Paul Helvy Esquire, and the Father, Joseph S. Dickinson, with his counsel, Linda A. Clotfelter Esquire. 3. This Court previously entered an Order in this matter on August 2, 2005, after hearing, under which the parties have shared legal and physical custody of the Child on a split week and alternating weekend schedule. The Order also permitted the Mother to enroll the Child in St. Joseph's school unless otherwise agreed between the parties. The Child is now beginning high school in the 2014-2015 school year and, as the parties have been unable to agree on the school district in which to enroll the Child for high school, the Father filed this Petition seeking to enroll the Child in the Cumberland Valley School District and to obtain consent for the Child to participate in cheerleading at Cumberland Valley during the summer. The Mother lives in the Mechanicsburg School District and proposes to enroll the Child at Trinity High School. 4. The parties agreed to entry of an Order in the form as attached resolving the issue of the Child being able to participate in cheerleading at Cumberland Valley while reserving a final determination on the Child's school enrollment to be addressed in therapeutic family counseling with the option for scheduling a hearing at a later date if all issues are not resolved through the counseling process. 1, ao Date Dawn S. Sunday, Esquire Custody Conciliator