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HomeMy WebLinkAbout05-3023 MELANIE LYNN WISE, IN THE COURT OF COMMON PLEAS OF Plaintiff vs. CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05- 3o;g CIVIL TERM VINCENT WISE, Defendant CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Melanie Lynn Wise, hereinafter referred to as Mother. Mother's permanent residence is 31 Sheryl Drive, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Vincent Wise, hereinafter referred to as Father, residing at 130 North East Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Mother seeks a schedule for periods of partial custody of the minor children: Name Damien Wise Present Residence 130 North East Street Carlisle, PA 17013 Age 9/25/99 DOB, 5 Y:z yrs old Larissa Wise 130 North East Street Carlisle, P A 17013 11/14/02 DOB, 2 Y:z yrs old The minor child, Damien, was born out of wedlock. The minor child, Larissa, was born during the parties' marriage. The children are presently in the custody of Father. 4. During Damien's lifetime, he has resided with the following persons and at the following addresses: Name Address Date Melanie Wise Vincent Wise 161 North East Street birth - 12/99 Carlisle, P A 17013 Melanie Wise Barbara Allen Megan Allen 101 Cockleys Drive 12/99 - 12/31/99 Mechanicsburg, P A 17055 Melanie Wise Vincent Wise 161 North East Street 12/31/99 - 5/00 Carlisle, PA 17013 Melanie Wise Confidential Location 5/00 - 5/00 Melanie Wise 161 North East Street 5/00 - 7/00 Carlisle, P A 17013 Melanie Wise 161 North East Street 7/00 - 9/00 Vincent Wise Carlisle, P A 17013 Melanie Wise Safe Harbor 9/00 - 9/00 Carlisle, P A 17013 Melanie Wise 161 North East Street 9/00 - 1 1102 Vincent Wise Carlisle, PA 17013 Melanie Wise 161 North East Street 11/02 - 5/03 Vincent Wise Carlisle, P A 17013 Larissa Wise Melanie Wise 130 North East Street 5/03 - 8/03 Vincent Wise Carlisle, P A 17013 Larissa Wise Melanie Wise 130 North East Street 8/03 - 9/03 Vincent Wise Carlisle, P A 17013 Larissa Wise Marcus Wise Melanie Wise 101 Cockleys Drive 9/03 - 10/03 Larissa Wise Mechanicsburg, PA 17055 Barbara Allen Megan Allen Melanie Wise 130 North East Street 10/03 - 12/28/03 Vincent Wise Carlisle, P A 17013 Larissa Wise Marcus Wise Vincent Wise 13 0 North East Street 12/28/03 - 2/04 Marcus Wise Carlisle, PA 17013 Melanie Wise 130 North East Street 2/04 - 1105 Vincent Wise Carlisle, PAl 7013 Larissa Wise Marcus Wise Melanie Wise 13 0 North East Street 1105 - 3/05 Vincent Wise Carlisle, P A 17013 Larissa Wise Vincent Wise Larissa Wise 130 North East Street Carlisle, PA 17013 3/05 - present During Larissa's lifetime, she has resided with the following persons and at the following addresses: Name Melanie Wise Vincent Wise Damien Wise Melanie Wise Vincent Wise Damien Wise Melanie Wise Vincent Wise Damien Wise Marcus Wise Melanie Wise Damien Wise Barbara Allen Megan Allen Melanie Wise Vincent Wise Damien Wise Marcus Wise Melanie Wise Barbara Allen Megan Allen Melanie Wise Vincent Wise Damien Wise Marcus Wise Melanie Wise Vincent Wise Damien Wise Vincent Wise Damien Wise Address Date 161 North East Street birth - 5/03 Carlisle, PAl 7013 130 North East Street 5/03 - 8/03 Carlisle, PA 17013 130 North East Street 8/03 - 9/03 Carlisle, P A 17013 101 Cock1eys Drive 9/03 - 10/03 Mechanicsburg, P A 17055 130 North East Street 10/03 - 12/28/03 Carlisle, PA 17013 101 Cockleys Drive 12/28/03 - 2/04 Mechanicsburg, P A 17055 130 North East Street 2/04 - 1/05 Carlisle, P A 17013 130 North East Street 1/05 - 3/05 Carlisle, P A 17013 130 North East Street 3/05 - present Carlisle, P A 17013 5. Mother currently resides with the following persons: Name Relationship Jason Newell Boyfriend Karen Newell Boyfriend's Mother Roger Newell Boyfriend's Father Justin Newell Boyfriend's brother 6. It is believed that Father currently resides with the following persons: Name Damien Wise Larissa Wise Relationship Son with Mother Daughter with Mother 7. Mother has not participated as a party or witness, or in another capacity, in other custody litigation concerning the custody of the children in this or another court. Mother was awarded primary physical custody of the children as part of a Temporary Protection From Abuse Order, dated May 7,2003, and docketed at 03-2166. Mother later vacated the Protection From Abuse Petition prior to receiving a Final Order, thus setting aside the custody determination therein. 8. Mother has no information of a custody proceeding concerning the children pending in a court ofthis Commonwealth. 9. Mother does not know of a person not a party to the proceedings who has physical custody ofthe children or claims to have custody or visitation rights with respect to the children. 10. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including, but not limited to the following: a) Mother lives in a stable home environment that is safe and appropriate for periods of partial physical custody with Damien and Larissa. b) Mother lives with her boyfriend's family who are willing to open their home to Damien and Larissa and help Mother nurture and protect her relationship with the children. c) Mother is willing to communicate with and work cooperatively with Father to co-parent the children and will encourage their relationship with their father. d) Mother has been the primary caretaker of the children since their birth and recognizes the importance of maintaining her relationship with the children despite the dissolution of her relationship with Father. e) Father has not acted in the best interest of the children in ways including but not limited to the following: i) Father has denied Mother all contact with the children since she left the marital residence in late March 2005. ii) Father prevents Mother from maintaining her relationship with the children by refusing to allow them to have contact with each other. iii) Mother fears that without a custody order in place, Father will continue to deprive her of any contact with the children, which will cause her relationship with them to deteriorate. iv) Mother fears that Father's ongoing refusal to allow her to see the children will confuse them and cause them to believe that she no longer wants to be a part oftheir lives. 11. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children, have been named as parties to this action. WHEREFORE, Mother requests this Court to grant the following relief: a) Grant the parties shared legal custody of the children. b) Grant Father primary physical custody of the children. c) Grant Mother periods of partial custody: I. While school is out of session, every Tuesday and Thursday from 12:00 noon until 7:30 p.m. 2. While school is in session, every Tuesday and Thursday: a. From 12:00 noon until 7:30 p,m. for the minor child, Larissa and, b. From after school until 7:30 p.m. for the minor child, Damien. 3. Alternating Sundays from 9:00 a.m. until 9:00 p.m. 4. Alternating Saturdays from 9:00 a.m. until 9:00 p.m. d) Establish an appropriate holiday schedule to allow each parent time with the children. e) Any additional relief this Court finds just and proper. lca Diam dstone, Mid Penn gal Services 8 Irvine ow Carlisle, P A 17013 (717) 243-9400 VERIFICATION The above-named PLAINTIFF, MELANIE LYNN WISE, verifies that the statements made in the above complaint For custody are true and correct. plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: ~\.f\Q ';) )~ ~l~\\.'-hL:kQ--, MEL IE LYNN W E MELANIE LYNN WISE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05- CIVIL TERM VINCENT WISE, Defendant CUSTODY AFFIDA VlT OF SERVICE BY MAIL I, Jessica Diamondstone, do hereby swear that I served Vincent Wise with a Complaint the person and addres , 2005 by certified mail, return receipt, restricted delivery, to For Custody on Vincent Wise 130 North East Street Carlisle, PA 17013 I, Jessica Diamondstone, verify that the statements made in this Affidavit of Service 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. Date: / ') iv/l/ lCOF j ,------ (') ~;- ,..., c' <_~,:::J c.n ,- ~~ - <....> --.- "', --j --. :"-'" ';l: ....p ~ ~iI1 __)en :by (~C) ~~.'~ , I ?:i ~i, ~< c- eo - o MELANIE LYNN WISE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-.J~ CIVIL TERM VINCENT WISE, Defendant : CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Melanie Lynn Wise, to proceed in forma pauperis. I, Jessica Diamondstone, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. -.--:7 Jessica Jamondstone, Esquire MidPenn Legal Services 8 Irvine Row Carlisle, PAl 7013 (717) 243-9400 o ~; "" l.. c:: :2'", ::;; ....., = = "" '- c:: z ~ :i!..,.., fl1r= -om6 ~o t) ) ~~~ S ~...... "i::J :< w ", :J1: '!? .". -. :NO. 05-3023 CIVIL TERM MELANIE LYNN WISE, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW :CUSTODY VINCENT WISE Defendant PRAECIPE FOR ENTRY OF APPEARANCE Please enter the appearance ofthe Family Law Clinic on behalf of Vincent Wise, Defendant in the above-captioned action. Papers may be served at the address set forth below. Date: ~~ ,;J..OO5 ~j2~-it: THO . PLACE ROBERT . RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 Phone: (717)243-2968 Fax: (717) 243-3639 Supervising Attorney () c -, ....., = ~ """ ,- S~~ "~ o -n -< rn:n c-y -om :'70 :: ,.1 :::.jCJ ;I;. :;.~ >"..;(~ ~jrr'l C1' :s:.: N o ~6 -.J .< MELANIE LYNN WISE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-3023 CIVIL ACTION LAW VINCENT WISE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Mouday, Juue 20, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X, Gilroy, Esq, at 4th Floor, Cumberlaud Couuly Courthouse, Carlisle on Thursday, July 14,2005 , the conciliator, 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. 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 hearin\!. FOR THE COURT, By: Isl Hubert X Gilro 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 infonnation 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 HA VE 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 rI' ~t -~$/,p 5/Jm:f :.pf7p ~ ~ #rI&;} 5(J-(Je-#) 5"X ~ ~ ~.p7J SO' oe'l VUI.,\-rr-11 (,i, ,('~ ""r ,,\,.,.1.1' 1\.L1 \\ ';r,:~\ ,- ',:'" ~;:f.'J "",::",.1(1~ . .)1~, t.) Sll:8 lid Q'? 'I " !'lor SGOl ^t1vlON(}lL(Y-i,~ 'JU 1 '0 4,,! ' ....'-''-' ..llU. -l :;)<,)<:1:'0--0311:J ~ - JRECEIVED JUL 212005 ~ MELANIE LYNN WISE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW VINCENT WISE, Defendant NO. 2005-3023 IN CUSTODY COURT ORDER AND NOW, this ~~. day of July, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Melanie Lynn Wise, and the father, Vincent Wise, shall enjoy shared legal custody of Damien Wise, born September 25, 1999, and Larissa Wise, born November 14, 2002. 2. The father shall enjoy primary physical custody of the minor children. 3. The mother shall enjoy periods of temporary physical custody of the minor children as follows: a. During the summer months, every Sunday from 9:00 a.m. until 7:00 p.m. and one other day during the week from 9:00 a.m. until 7:00 p.m., that day to be agreed upon by the parties. b. During the school year, every Sunday from 9:00 a.m. until 7:00 p.m. Additionally, on one week day per week with mother having custody of Larissa from noon until 7:00 p.m. and of Damien from after school until 7:00 p.m c. At such other times as the parties may agree. FILED-o,eF :C::: OF THE F:~r)T:-':':::\\;()"[AEY Lnas jUL 25 fIt'l II: [I I cu~:/~:_.,:" :'/JNTY - 4. Parties shall do an alternating custodial arrangement on holidays to include New Years, Easter, Memorial Day, July 4th, Labor Day, and Thanksgiving. Mother shall have custody in odd numbered years on New Years, Memorial Day and Labor Day with father having custody for Easter, July 4th and Thanksgiving. During even numbered years, the arrangement shall alternate. 5. The father shall always have custody of the minor children on Father's Day and the mother shall always have custody of the minor children on Mother's Day. This provision shall supercede any other provision of this Order. Mother shall also be afforded a few hours of custody with the minor children on their birthdays. Where a birthday falls on a school day, the parties shall at least try to arrange mother's periods of custody on the day before or the day after the birthday. 6. For Christmas 2005, mother shall have custody from noon until 7:00 p.m. Future Christmas Holidays shall be arranged between the parties. 7. When mother has custody of the minor children, she shall not take the children to a prison to visit her boyfriend or anyone else. However, in the event the mother's father does not make parole as anticipated in September and the parties are unable to reach an agreement on the children visiting their grandfather in prison, legal counsel for the mother may contact the Conciliator again to schedule a Custody Conciliation Conference via telephone conference to address that particular issue. 8. Neither party shall consume alcohol to a degree of intoxication when they have custody of the minor children. Nor shall the custodial parent allow the children to be in the presence of other individuals who are under the influence of alcohol or other illegal substances. 9. Uuless agreed otherwise by the parties, exchange of custody shall take place at the Weis Market on High Street in Carlisle. Father shall provide mother with car seats to transport the children at exchanges of custody, with mother returning those car seats to father at the end of her period of temporary custody. BY THE COURT, AtL cq)J6ugIas Boorstein, Dickinson School of Law Family Law Clinic ~ica Diamondstone, Esquire MELANIE LYNN WISE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CML ACTION - LAW VINCENT WISE, Defendant NO. 2005-3023 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Damien Wise, born September 25, 1999 and Larissa Wise, born November 14, 2002. 2. A Conciliation Conference was held on July 14, 2005, with the following individuals in attendance: The mother, Melanie Lynn Wise, with her counsel, Jessica Diamondstone, Esquire, and the father, Vincent Wise, with his student attorney, Douglas Boorstein, of the Dickinson School of Law Family Law Clinic. 3. The parties agreed to the entry of an Order in the form as attached. f)-)O-OS'" DATE Hubert X. Gilro , Esquire Custody Conciliator MELANIE LYNN WISE (NEWELL), : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. T : NO. 2005-3023 CIVIL TERM VINCENT WISE,' -'Y Defendant IN CUSTODY -s, -71 rn rn c . w. z -=, : ; PRAECIPE TO PROCEED IN FORMA PAUPERIS c=nr' -- }a -<; o --lc:, r - - :.. To the Prothonota —0ry� � rs 7.1; .� -.. . Kindly allow Melanie Lynn Wise (Newell), Plaintiff in the above-capti net` matter,• `to proceed in forma pauperis. I, Paul D. Edger, Esquire of MidPenn Legal Services, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Date: r!O /16 hit Respectfully Submitted Air/ nn Legal ices Paul D. Edge quire Supreme Court I.D. 312713 401 E. Louther St., Suite 103 Carlisle, PA 17013 Attorney for Plaintiff MIDPENN LEGAL SERVICES By: Jennifer Reed, Certified Legal Intern Paul D. Edger, Esquire Supreme Court I.D. 312713 401 E. Louther Street, Suite 103 Carlisle, PA 17013 (717) 243-9400 pedger@midpenn.org Attorney for Plaintiff JUN 16 PM 2: 33 CUMBERLAND COUNTY PENNSYLVANIA MELANIE LYNN WISE (NEWELL), : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2005-3023 CIVIL TERM VINCENT WISE. Defendant : IN CUSTODY PETITION FOR MODIFICATION AND NOW comes the Petitioner, Melanie Lynn Wise (Newell), by and through Jennifer Reed, Certified Legal Intern, and Paul D. Edger, Esquire of MidPenn Legal Services, and avers the following in support of her Petition for Modification: 1. The Plaintiff/Petitioner is Melanie Lynn Wise (Newell) (hereinafter "Mother"), an adult individual with a record address of 101 Cockleys Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant/Respondent is Vincent Wise (hereinafter "Father"), an adult individual with a record address of 17 E. Louther Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of the minor Children, Damien Wise, whose date of birth is September 25, 1999, and Larissa Wise, whose date of birth is November 14, 2002 (hereinafter the "Children"). 4. The Children are presently in the custody of Father. 5. On July 25, 2005, the Honorable President Judge Kevin A. Hess entered an Order of Custody awarding shared legal custody to both Mother and Father. Father was awarded primary physical custody. A true and correct copy of the Custody Order is attached hereto as Exhibit "A." 6. Paragraph three (3) of the Order provides for Mother to enjoy periods of temporary physical custody of the Children as follows: a. During the summer months, every Sunday from 9:00 a.m. until 7:00 p.m. and one other day during the week from 9:00 a.m. until 7:00 p.m., that day to be agreed upon by the parties. b. During the school year, every Sunday from 9:00 a.m. until 7:00 p.m. Additionally, on one week day per week with mother having custody of Larissa from noon until 7:00 p.m. and of Damien from after school until 7:00 p.m. c. At such other times as the parties inay agree. 7. Paragraph six (6) provides that for Christmas 2005, Mother shall have custody from noon until 7:00 p.m. and that future Christmas Holidays shall be arranged between the parties. 8. In 2007, the parties agreed to allow Mother to have primary physical custody of Damien. Mother had primary physical custody of Damien until 2009 when the police enforced the Court Order, at Father's request, and returned Damien to Father. 9. From August 2009 to August 2010, Father and Mother lived together with the Children and shared primary physical custody. Father and Mother briefly remarried during this time. 10. From August 2010 to August 2013, Mother was permitted infrequent visitation with the Children. Father relocated several times without notifying Mother of his new address or phone number and blocked her on Facebook. Mother visited with children approximately a dozen times during this period and briefly lived with Father and Children in June 2012. 11. From August 2013 to November 2013, Father and Children resided with the Children's maternal grandmother and Mother was permitted frequent visitation with Children. Mother often helped the children with their homework after school. 12. Mother has not been permitted consistent visitation with the Children since November 2013. Mother has called Father approximately once a week to arrange visits with the Children but has only been permitted to see them three times. 13. Mother was permitted to visit with the Children for a few hours the week of Christmas. 14. Mother was also permitted to visit with the Children at Father's residence on May 22 and June 8, 2014. 15. Mother is in communication with the Children via Facebook. Mother exchanges Facebook messages with Larissa almost daily. 16. Mother has met with Damien individually approximately three times since Christmas. Damien reached out to Mother at least half a dozen times to arrange meetings with Mother. On several occasions, Mother arrived at the designated meeting place but Damien did not arrive. 17. Both Damien and Larissa have expressed a desire to visit with Mother. 18. Mother seeks reunification with the Children and to modify the current custody order, to include language providing for a visitation arrangement with the Children and any other terms which are in the best interests of the Children. 19. The best interests and permanent welfare of the Children will be served by granting the modification for reasons including, but not limited to the following: a. Mother lives in a stable home environment that is safe and appropriate for periods of visitation with the Children; b. Mother lives with the Children's maternal grandmother, who is willing to open her home to the Children and help Mother nurture and protect her relationship with the Children; c. Mother is willing to communicate with and work cooperatively with Father to co- parent the children; d. Mother was primary caretaker of the Children during their early childhood years and had primary physical custody of Damien from 2007-2009. Mother recognizes the importance of maintaining her relationship with the children; e. Mother is concerned about Damien's failing grades, as he has just failed seventh grade for the second time; Mother would like the opportunity to help Damien succeed and encourage him in his schoolwork; f. Mother fears that without a custody order in place, Father will continue to deprive her of contact with the Children, causing her relationship with them to deteriorate. Mother fears that Father's ongoing refusal to allow her to see the Children will confuse them and cause them to believe that she no longer wants to be part of their lives. WHEREFORE, the Petitioner Melanie Lynn Wise (Newell) respectfully requests this Honorable Court to grant the following relief: a. Modify the existing custody order to grant Mother periods of visitation: 1. Tuesdays and Thursdays from 5:00 p.m. to 9:00 p.m. 2. Saturdays from 9:00 a.m. to 9:00 p.m. b. Establish an appropriate holiday schedule to allow each parent time with the children on Christmas; c. Any additional relief this court finds proper. Date: 6116 (01 Respectfully Submitted, Jen ifer Celtified rn 1D. Ed qu re Supre u I.D. 312713 MidPenn Legal Services 401 E. Louther St., Suite 103 Carlisle, PA 17013 (717) 243-9400 Attorney for Petitioner VERIFICATION I, Melanie Wise (Newell), verify that the statements made in the above pleading are true and correct. 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: U) —13 1 L('(4S?.D..c‘.1Lk weW Melanie Newell, Petitioner Exhibit "A" MELANIE LYNN WISE, Plaintiff v VINCENT WISE, Defendant `RECEIVED. JUL 212005 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2005-3023 : IN CUSTODY COURT ORDER AND NOW, this z 5 day of July, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Melanie Lynn Wise, and the father, Vincent Wise, shall enjoy shared legal custody of Damien Wise, born September 25, 1999, and Larissa Wise, born November 14, 2002. 2. The father shall enjoy primary physical custody of the minor children. 3. The mother shall enjoy periods of temporary physical custody of the minor children as follows: a. During the summer months, every Sunday from 9:00 a.m. until 7:00 p.m. and one other day during the week from 9:00 a.m. until 7:00 p.m., that day to be agreed upon by the parties. b. During the school year, every Sunday from 9:00 a.m. until 7:00 p.m. Additionally, on one week day per week with mother having custody of Larissa from noon until 7:00 p.m. and of Damien from after school until 7:00 p.m c. At such other times as the parties may agree. 4. Parties shall do an alternating custodial arrangement on holidays to include New Years, Easter, Memorial Day, July 0, Labor Day, and Thanksgiving. Mother shall have custody in odd numbered years on New Years, Memorial Day and Labor Day with father having custody for Easter, July 4th and Thanksgiving. During even numbered years, the arrangement shall alternate. 5. The father shall always have custody of the minor children on Father's Day and the mother shall always have custody of the minor children on Mother's Day. This provision shall supercede any other provision of this Order. Mother shall also be afforded a few hours of custody with the minor children on their birthdays. Where a birthday falls on a school day, the parties shall at least try to arrange mother's periods of custody on the day before or the day after the birthday. 6. For Christmas 2005, mother shall have custody from noon until 7:00 p.m. Future Christmas Holidays shall be arranged between the parties. 7. When mother has custody of the minor children, she shall not take the children to a prison to visit her boyfriend or anyone else. However, in the event the mother's father does not make parole as anticipated in September and the parties are unable to reach an agreement on the children visiting their grandfather in prison, legal counsel for the mother may contact the Conciliator again to schedule a Custody Conciliation Conference via telephone conference to address that particular issue. 8. Neither party shall consume alcohol to a degree of intoxication when they have custody of the minor children. Nor shall the custodial parent allow the children to be in the presence of other individuals who are under the influence of alcohol or other illegal substances. 9. Unless agreed otherwise by the parties, exchange of custody shall take place at the Weis Market on High Street in Carlisle. Father shall provide mother with car seats to transport the children at exchanges of custody, with mother returning those car seats to father at the end of her period of temporary custody. BY TRE COURT, Judge Boorstein, Dickinson School of Law Family Law Clinic Diamondstone, Esquire MELANIE LYNN , Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2005-3023 CIVIL TERM r, VINCENT WISE, j -fl i Defendant : IN CUSTODY N r1713 ; _.<.> 0' <LJ -0 c=-,,, i.D rr:; n_. I, Melanie Wise, hereby swear or affirm, subject to penalties of law including 1T3.',Pa C.S `^ § 4904 relating to unsworn falsification to authorities that: CRIMINAL RECORD / ABUSE HISTORY VERIFICATION 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 Self Other Date of conviction, Sentence household guilty plea, no member contest plea or pending charges ❑ 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) ❑ 18 Pa.C.S. § 2709.1 ❑ ❑ (relating to stalking) Check Crime Self Other Date of conviction, Sentence all that household guilty plea, no apply member contest plea or pending charges ❑ 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) 18 Pa.C.S. § 2910 ❑ ❑ (relating to luring a child into a motor vehicle or structure) ❑ 18 Pa.C.S. § 3121 ❑ ❑ (relating to rape) ❑ 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) Check Crime Self Other Date of conviction, Sentence all that household guilty plea, no apply member contest plea or pending charges ❑ 18 Pa.C.S. § 3125 ❑ ❑ (relating to aggravated indecent assault) ❑ 18 Pa.C.S. § 3126 ❑ (relating to indecent assault) 18 Pa.C.S. § 3127 ❑ ❑ (relating to indecent exposure) ❑ 18 Pa.C.S. § 3129 ❑ ❑ (relating to sexual intercourse with animal) ❑ 18 Pa.C.S. § 3130 ❑ (relating to conduct relating to sex offenders) ❑ 18 Pa.C.S. § 3301 ❑ ❑ (relating to arson and related offenses) ❑ 18 Pa.C.S. § 4302 ❑ ❑ (relating to incest) ❑ 18 Pa.C.S. § 4303 ❑ ❑ (relating to concealing death of child) Check Crime Self Other Date of conviction, Sentence all that household guilty plea, no apply member contest plea or pending charges 18 Pa.C.S. § 4304 0 El (relating to endangering welfare of children) 18 Pa.C.S. § 4305 0 0 (relating to dealing in infant children) O 18 Pa.C.S. § 5902(b) El 0 (relating to prostitution and related offenses) 18 Pa.C.S. 59O3(b)/(d 1111 0 (relating to obscene and other sexual materials and performances) O 18 Pa.C.S. § 6301 0 0 (relating to corruption of minors) 18 Pa.C.S. § 6312 (relating to sexual abuse of children) O 18 Pa.C.S. § 6318 0 0 (relating to unlawful contact with minor) O 18 Pa.C.S. § 6320 0 0 (relating to sexual exploitation of children) Check Crime all that apply Self Other Date of conviction, Sentence household guilty plea, no member contest plea or pending charges 23 Pa.C.S. 6114 0 0 (relating to contempt for violation of protection order or agreement) Driving under the 0 0 influence of drugs or alcohol LJ Manufacture, sale, 0 0 delivery, holding, offering for sale or possession of any controlled substance or other drug or device 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, or involvement with a Children & Youth agency, including the following: Check all that apply LJ A finding of abuse by a Children & Youth Agency or similar agency in Pennsylvania or similar statute in another jurisdiction El Abusive conduct as defined under the Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction Sel Other household m ember Involvement with a Children & Youth 0 0 Agency or similar agency in Pennsylvania or another jurisdiction. Where? Date Check all that apply Self Other Date household member Ri Other: "1-...--\--\-_--k- Lr ❑ o 3. Please list any evaluation co ling or other treatment received following Sit 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 member of the other party's household has or have a criminal/abuse history, please explainer rark_k. , (} r e,5frn p)P (15L 4-> CO rtv ion ar m� rte Sec.vi Mr\OCS , 1 cc i"A , VjeAtc � the 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. Name AkweQ-Q MELANIE LYNN WISE (NEWELL), : IN THE COURT OF COMMON PLEAS Plaintiff. : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2005-3023 CIVIL TERM VINCENT WISE. Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Jennifer Reed, Certified Legal Intern, state that I did mail a copy of the foregoing document upon the following individual(s) and in the manner indicated below: USPS First Class Mail Date: („/ l � 14 Vincent Wise 17 E. Louther St. Carlisle, PA 17013 MELANIE LYNN WISE NEWELL PLAINTIFF V. VINCENT WISE DEFENDANT AND NOW, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANRI 2005-3023 CIVIL ACTION LAW rn � r IN CUSTODY cp ORDER OF COURT Tuesday, June 17, 2014 , upon consideration of the attached Complaint, it is --T CD hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor , Cumberland County Courthouse, Carlisle on Wednesday, July 02, 2014 , the conciliator, 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. 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/ Hubert X. Gilroy, Esq 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. Copie s Anzed a AY .404 1e'se, left' C-,, /ro y, Es g. 6/fil/X Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Melanie Lynn Wise (Newell), IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION IN CUSTODY Vincent Wise, Defendant DOCKET # 2005-3023 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Community Law Clinic on behalf of Vincent Wise, the Defendant, in the above -captioned matter. Date: July 15, 2014 Summer Swanson Certified Legal Intern Megan esmeyer Supervising Attorney COMMUNITY LAW CLINIC 371 West South Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 241-3596 Melanie Lynn Wise (Newell), IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION IN CUSTODY Vincent Wise, Defendant DOCKET # 2005-3023 CERTIFICATE OF SERVICE I, Summer Swanson, hereby certify that I am serving true and correct copies of the Praecipe to Enter Appearance and the Criminal Record/Abuse History Verification on the following person, counsel for Plaintiff, by depositing a copy of the same in the United States mail, postage prepaid, this 15th day of July, 2014: Jennifer Reed, Certified Legal Intern Paul D. Edger, Esquire 401 E. Louther Street, Suite 103 Carlisle, PA 17013 .Pn XIMv1+/11-1 Summer Swanson Certified Legal Intern COMMUNITY LAW CLINIC 371 West South Street Carlisle, PA 17013 (717) 243-2968 Fax (717) 241-3596 Melanie Lynn Wise (Newell), IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION IN CUSTODY Vincent Wise, Defendant DOCKET # 2005-3023 CRIMINAL RECORD/ABUSE HISTORY VERIFICATION x -: � I, V„g,,ci;/ Gt i , hereby swear or affirm, subject to penalties of law inch*lin .18 5 Pa.C.S. §4904 relating to unsworn falsification to authorities, that: 1. Unless indicated by my checking the box next to the 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 Self Other Date of household conviction, member guilty plea, no contest plea or pending charges ❑ 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) Sentence LI 18 Pa. C.S. §2709.1 0 0 (related to stalking) LI 18 Pa.C.S. §2901 0 0 (related to kidnapping) 0 18 Pa.C.S. §2902 0 0 (relating to unlawful restraint) 0 18 Pa.C.S. §2903 (relating to false imprisonment) LI 18 Pa.C.s. §2910 (relating to luring a child into a motor vehicle or structure) DLI LID O 18 Pa.C.S. §3121 0 0 (relating to rape) O 18 Pa.C.S. §1322.1 (relating to statutory sexual assault) LID O 18 Pa.C.S. §3123 0 0 (relating to involuntary deviate sexual intercourse) LI 18 Pa.C.S. §3124.1 El E (relating to sexual assault) • 18 Pa.C.S. §3125 0 0 (relating to aggravated indecent assault) 0 18 Pa.C.S. §3126 (relating to indecent assault) O 0 • 18 Pa.C.S. §3127 El 0 (relating to indecent exposure) • 18 Pa. C.S. §3129 (relating to sexual intercourse with animal) • 18 Pa.C.S. §3130 (relating to conduct relating to sex offenders O 18 Pa. C.S. §3301 (relating to arson and related offenses) O 0 O 0 O 0 • 18 Pa.C.S. §4302 0 0 (relating to incest) • 18 Pa.C.S. §4303 0 0 (relating to concealing death of child) • 18 Pa.C.S. §4304 (relating to endangering welfare of children) 00 O 18 Pa.C.S. §4305 0 0 (relating to dealing in infant children) El 18 Pa.C.S. §5902(b) (relating to prostitution and related offenses) LID O 18 Pa.C.S. §5903(c) or LI D (d) (relating to obscene and other sexual materials and performances) 18 Pa.C.S. §6301 (relating to corruption of minors) O 18 Pa.C.S. §6312 0 0 (relating to sexual abuse of children) CI 18 Pa.C.S. §6318 0 0 (relating to unlawful contact with minor) LI 18 Pa.C.S. §6320 (relating to sexual exploitation of children) 0 23 Pa.C.S. §6114 (relating to contempt for violation of protection order or agreement) O Driving under the influence of drugs or alcohol D LI LID LID ;-% r-af ed A\ 61 1 Manufacture, sale, delivery, holding, offering for sale or possession of any controlled substance or other drug or device 0 prka-Nn )q -L-71/600 V rod R41 _bispui-00 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, or involvement with a Children & Youth agency, including the following: Check all that apply ❑ A finding of abuse by a Children & Youth Agency or similar agency in Pennsylvania or similar statute in another jurisdiction Abusive conduct as defined under the Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction Involvement with a Children & Youth Agency or similar agency in Pennsylvania or another jurisdiction If yes, Where: 3 V-).QI-\c \ CAA) Self Other Date household member ❑ ❑ 0\ ❑ kV bo -.1W �/- -CM caf6 rdeca 9rk S(71p`� 04er6(5Mosed �L13�0� El . t ,\n oS ker) 0,5 oc e aS 3\0e,2A4, ro ce_v05 V Aft been ❑ Other: 0 ❑ 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: C5 r(Ldh-q),)?/-.0(Cd dru(41fiu/ — eq%,P4 t e s(rif(f)j Maes jJD e autt of sir Care . PS q0,(66o.\39scoscaly, 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. arc �,3 iso,— 0,04•?). tt l 1M 4 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: MAOv' P \ C6 \C\ OA CSS v4,ihe4\the 2Oe u)hf`J tie Ore tIpiSatt, Sb c5mi-t\\ hU3 kko2 V�io►s at 'th k 1v, ` o ne cry wIrah is achUe, (s),,aw r s ia'h 'has W Sto ; f o)'j d hao pttd v1\+6 + t kerr©U of -i c, 4h e+s, 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. ffri , Date Signature \N./ 4 , G✓/� Printed Name MELANIE LYNN NEWELL, Plaintiff v VINCENT WISE, Defendant : IN CUSTODY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2005-3023 CIVIL ACTION - LAW Z zc, ncatx:, (72 .- > PRIOR JUDGE: The Honorable Kevin A. Hess COURT ORDER AND NOW, this it' day of July, 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that all prior Custody Orders in this case are vacated and replaced with the following Order: 1. The mother, Melanie Lynn Newell, and the father, Vincent Wise, shall enjoy shared legal custody of Damien Wise, born September 25, 1999, and Larissa Wise, born November 14, 2002. 2. The father shall enjoy primary physical custody of the minor children. 3. The mother shall enjoy periods of partial physical custody of the minor children as follows: A. Every Tuesday and Thursday evening during the summer from 5:00 p.m. until 9:00 p.m. and on the same days during the school year from 5:00 p.m. until 8:00 p.m. B. Every Sunday from 9:00 a.m. until 9:00 p.m. C. At such other times as the parties may agree. 4. Holidays shall be handled with the mother having custody every holiday from 9:00 a.m. until 3:00 p.m. The holiday schedule shall include Christmas, New Year's Day, Easter, Memorial Day, July 4th, Labor Day and Thanksgiving. The holiday schedule shall supercede the schedule set forth above. 5. On the Father' s Day weekend, mother' s Sunday schedule shall be converted to Saturday from 9:00 a.m. until 9:00 p.m. 6. Mother shall give the father at least twenty four hours notice in the event she is not going to exercise the custodial rights set forth in this Order. 7. Both parties shall insure that only licensed drivers are driving the children when the children are in their custody. Additionally, both parties shall insure that any vehicle in which the children are being transported shall have appropriate liability insurance as required under Pennsylvania Law. 8. Unless agreed otherwise, the parties shall exchange custody in the parking lot of the Carlisle Post Office. 9. When mother has custody of the minor children, mother shall always be present with the children when the children are also in the presence of Mr. Shawn Smith. 10. Legal counsel for the parties shall conduct a telephone conference with the Custody Conciliator on Friday, August 29, 2014, at 8:00 a.m. At that time, in the event there is a need to schedule this case for a hearing or another in-person Custody Conciliation Conference, the Custody Conciliator may submit an appropriate Order to the Court. Additionally, if there are any dramatic incidents that merit the Court's attention before this telephone conference is held, legal counsel for either party may contact the Custody Conciliator's office directly to schedule an accelerated telephone conference, after which the Conciliator may submit an appropriate Order to this Court. No party shall be permitted to relocate the residence of the child where said relocation will significantly impair 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. Any party proposing to relocate MUST comply with 23 Pa. C.S. § 5337. BY THE COURT, Kevin Hess, Judge cc: " J fifer Reed, Student Attorney "Summer Swanson, Student Attorney (Community Law Clinic) CO es V1/,y MELANIE LYNN NEWELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v: 2005-3023 CIVIL ACTION - LAW VINCENT WISE, Defendant : IN CUSTODY PRIOR JUDGE: The Honorable Kevin A. Hess CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Damien Wise, born September 25, 1999, and Larissa Wise, bornNovember 14, 2002. 2. A Conciliation Conference was held on July 17, 2014, with the following individuals in attendance: The mother, Melanie Lynn Newell, with her student attorney, Jennifer Reed, and the father, Vincent Wise, with his student attorney, Summer Swanson. Upon the recommendation of the Custody Conciliator, the parties agree to the entry of an Order in the form as attached. Date: July /8 , 2014 Hubert X. Gilro , squire Custody Concil ator MELANIE LYNN WISE NEWELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : 2005-3023 CIVIL ACTION - LAW c) VINCENT WISE, _o Q.., ...,-- --.,, Defendant : IN CUSTODY rn cv cr.) r--- ...< . I- 27 •,< Ci ---4 r-- - >r, COURT ORDER c, ›. C -c.... • • -1 -< AND NOW, this `i * _.. day of September, 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's prior Order of July 18, 2014, shall remain in place subject to the following modifications/clarifications: 1. This is a shared custody arrangement such that both parties are required to share all medical, educational and social information concerning the minor children with the other parent. 2. The Mother's Sunday periods of partial custody with the minor children during the school year shall be from 8:00 a.m. until 8:00 p.m. Neither parent shall take the children to a prison or correctional institution without permission from the other parent. 4. Neither parent shall allow the children to be in the presence of anyone who has consumed alcohol to the point of intoxication. 5. Both parents shall promptly notify the other parent in the event they move from their current location, and both parents shall consistently keep the other parent advised with respect to anyone living in their home. 6. In all other respects, the prior Order of July 18, 2014, shall remain in place. No party shall be permitted to relocate the residence of the child where said relocation will significantly impair 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. Any party proposing to relocate MUST comply with 23 Pa. C.S. § 5337. BY THE COURT, cc:�?,aflz D. Edger, Esquire (MidPenn Legal Services) Gabby Grosso, Student Attorney (Community Law Clinic) MELANIE LYNN WISE NEWELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : 2005-3023 CIVIL ACTION - LAW VINCENT WISE, Defendant : IN CUSTODY PRIOR JUDGE: The Honorable Kevin A. Hess CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: Consistent with the July 18, 2014, Order of Court, the Conciliator conducted a telephone conference with legal counsel for the parties on August 29, 2014. Based upon that telephone conference, the Conciliator recommends an Order in the form as re) attached. Date: August 5 I , 2014 Hubert . Gilroy, Esuire Custody Conciliato