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HomeMy WebLinkAbout05-6774IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JASON C. BACON AND KIMBERLY R. HAGEMEYER Plaintiffs VS. TAMARA N. SEWELL Defendant No. 0 ?5 - (e -7 7 CUSTODY Action-Law COMPLAINT FOR CUSTODY 1. The Plaintiffs are Jason C. Bacon, who is the Father of Ariyanna Hope Tayler, (hereinafter "Child") and who currently resides at 233 A. East :Locust Street, Mechanicsburg, PA 17055, and Kimberly R. Hagemeyer, who is the in loco parentis Mother of the Child and who currently resides at 460A Heisey Road, Mechanicsburg, PA 17055, hereinafter "Plaintiffs." 2. The Defendant is Tamara N. Sewell, and is the Mother of the Child, hereinafter "Defendant" and is believed to currently reside at 725 North U.S. Highway 15 North, Dillsburg, Pennsylvania, 17109. 3. Plaintiffs seek shared legal and primary physical custody of the following Child: Ariyanna Hope Tayler, March 6, 2004, who is currently in the custody of the Defendant and residing at 725 North U.S. Highway 15 North, Dillsburg, Pennsylvania, 17109. AGE: 22 months The Child was born out of wedlock. During the past five years, the Child has resided with the following persons and at the following addresses: From birth to April 2005, with the in loco parentis Mother and the Defendant at 5328 Oxford Circle Apt. 27, Mechanicsburg, PA 17055. From April, 2005, to December 26th, 2005, with the in loco parentis Mother and the Defendant at 460A Heisey Road, Mechanicsburg, PA 17055. From December 26, 2005, with the Defendant, Jennifer Schultz-Jacob, Jennifer's former lesbian partner, Jodilynn Jacob, and four children, Leroy Jacob age 12, Austin Jacob age 10, Cody Jacob age 7, and Catie Jacob age 5. 4. The relationship of Plaintiffs to the Child is that of Father to Daughter and in loco parentis Mother to Daughter The in loco parentis Mother currently resides alone. The Father currently resides alone 5. The relationship of Defendant to the Child is that of Mother to Daughter. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the Child in this or another court. Plaintiff has no information of a custody proceeding concerning the Child pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the Child or claims to have custody or visitation rights with respect to the Child. 7. The best interest and permanent welfare of the Child will be served by granting the relief requested because: It is in the best interest of the Child in that her financial, physical, and emotional well being shall be served by Child's in loco parentis Mother having shared legal and primary physical custody of the Child with the Father and Mother to have partial physical custody and visitation with the Child. 8. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the Child will be given notice of the pendency of this action and the right to intervene: There are no other persons having a claim of right to custody. WHEREFORE, Plaintiff requests the court to grant the in loco parentis Mother shared legal and primary physical custody of the Child with Father and Mother to have partial physical custody/visitation with the Child. We verify that the statements made in the foregoing Complaint for Custody are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. k? 4;1 k?- Y laI 7 . . Kimberly Hage er Date son C. Bacon Date Respectfully Submitted #83284 319 South Front Street Harrisburg, PA 17104 (717) 919-4002 . h UEC 2 S 1005 r V IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JASON C. BACON AND KIMBERLY R. HAGEMEYER Plaintiffs vs. TAMARA N. SEWELL Defendant No. 4 - 77t( (?_?' '; CUSTODY Action-Law ORDER OF COURT AND NOW, this _ day of , 2005, upon consideration of the attached Plaintiffs Complaint for Custody and Plaintiffs Petition for Emergency Temporary Custody, it is hereby ordered and decreed that the Child, Ariyanna Hope Tayler be placed in the legal and physical custody of the Father and the in loco parentis Mother pending a hearing and/or conciliation conference on the matter. By the Court: Judge 4 `?°> ? ?? ? N ? r, {_> ?> «, t-? n) CJ N c'> c? _„ ,;=' ? ?T. 1 1..? '?C it { =i :? U IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JASON C. BACON AND KIMBERLY R. HAGEMEYER :No. Plaintiffs vs. :CUSTODY TAMARA N. SEWELL : Action-Law Defendant PETITION FOR EMERGENCY CUSTODY 1. The Plaintiffs are Jason C. Bacon, who is the Father of Ariyanna Hope Tayler, (hereinafter "Child") and who currently resides at 233 A. East Locust Street, Mechanicsburg, PA 17055, and Kimberly R. Hagemeyer, who is the in loco parentis Mother of the Child and who currently resides at 460A Heisey Road, Mechanicsburg, PA 17055, hereinafter "Plaintiffs." 2. The Defendant is Tamara N. Sewell, is the Mother of the Child, hereinafter "Defendant" and is believed to currently reside at 725 North U.S. Highway 15 North, Dillsburg, Pennsylvania, 17109. 3. Plaintiffs seek emergency custody of Ariyanna Hope Tayler, born March 6, 2004, who is currently in the physical custody of the Defendant and residing at725 North U.S. Highway 15 North, Dillsburg, Pennsylvania, 17109. 4. On December 24, 2005, the Defendant telephoned the Paternal Grandmother, Judith Bacon and the Plaintiff Father and requested that they come and get the Child as she felt unstable and did not feel as though she could care for the Child. 5. On December 24, 2005, the Defendant left the residence that she shared with her lesbian partner, the in loco parentis Mother. 6. Before leaving the residence, the Defendant gave the Child to the Paternal Grandfather, Carl Bacon and the Plaintiff Father and did not leave any contact information with the Paternal Grandfather, Father, or the in loco parentis Mother. 7. The in loco parentis Mother did not know she had rights to custody under the law as a primary caretaker even though she was the primary caretaker of the Child since birth, and it was a joint decision between the Defendant and the in loco parentis Mother to have the Child and rear the Child together 8. On December 26th, 2005, the Defendant went to the Paternal Grandmother's residence and demanded the Child be returned to her from the Father. 9. The Child was moved to the Defendant's residence that is shared by her paramour, Jennifer Schultz-Jacob, Jennifer's former lesbian partner, Jodilynn Jacob and four children, Leroy Jacob age 12, Austin Jacob age 10, Cody Jacob age 7, and Catie Jacob age 5. 10. The four children that reside in the current residence of the Defendant, include two boys, Leroy Jacob and Austin Jacob, who have been sexually assaultive. 11. The Plaintiffs believe that the Defendant is not fit to care for the Child as the Defendant cannot control her anger. 12. Defendant's current paramour, Jennifer Schultz-Jacob in retaliation to one of the Children, in her current residence, holding a pillow over the face of another Child removed the perpetrator to the bedroom and held a pillow over the perpetrators face. 13. The Defendant has been suicidal in the past and was an outpatient at Holy Spirit Hospital where she was diagnosed with severe reoccurring mood disorder. 14. On Tuesday December 27th, 2005, the Plaintiffs contacted Children and Youth of York County and raised their concerns for the safety of the Children. 15. On Wednesday December 28th, York County Children and Youth replied to the Plaintiffs that the Child was considered to be on a visit and therefore would not be involved. 16. Plaintiffs fear for the Child's safety in the care of the Defendant and in the current residence of the Defendant. 17. Plaintiffs fear that the Defendant will leave the jurisdiction of the Commonwealth of Pennsylvania with the Child as she has relatives in Missouri and has threatened to do so. WHEREFORE, Plaintiffs requests the court to grant the in loco parentis Mother and Father legal and physical custody of the Child. I We verify that the statements made in the foregoing Petition for Emergency Custody are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Kimberly kMaggem Date ? L' a ' J on C. Bacon Date Respectfully Submitted b At om for laintiffs Derek Co - r, Esquire. #83284 319 South Front Street Harrisburg, PA 17104 (717) 919-4002 JASON C. BACON AND : IN THE COURT OF COMMON PLEAS OF KIMBERLY R. HAGEMEYER, : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS V. TAMARA N. SEWELL, DEFENDANT 05-6774 CIVIL TERM ORDER OF COURT AND NOW, this Z? day of December, 2005, the petition for an emergency custody hearing, IS DENIED. The complaint for custody shall proceed to conciliation. By the Edgar Derek Cordier, Esquire For Jason C. Bacon :sal Ive r er.f I- U3-oL -.I 03 :Z IJ 6Z 3--?0 SUN JASON C. BACON AND KIMBERLY R. IN THE COURT OF COMMON PLEAS OF HAGEMEYER PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-6774 CIVIL ACTION LAW TAMARA N. SEWELL DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, January 06, 2006___, 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, February 07, 2006 at 8:30 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: Is/ Dawn S. Sundays L Custody Conciliator ?I The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 M JASON C. BACON AND KIMBERLY R. HAGEMEYER Plaintiff vs. TAMARA N. SEWELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 05-6774 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this Z\ day of 2006, upon consideration of the attached Custody Conciliation Report, it is ordered pd directed as follows: 1. Tamara N. Sewell and Kimberly Hagemeyer shall have shared legal custody of Ariyanna Hope Taylor, born March 6, 2004. Each party shall have an equal right, to be exercised jointly with the other party, 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 this paragraph each party shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. Tamara Sewell shall have primary physical custody of the Child. 3. Kimberly Hagemeyer shall have partial physical custody of the Child on alternating weekends from Friday at 7:00 p.m. through Sunday at 7:00 p.m. and every Wednesday from 4:00 p.m. until 7:30 p.m. Kimberly Hagemeyer shall pick up the Child directly from daycare on Wednesdays for her period of custody. Kimberly shall not pick up the Child at daycare at any time not expressly authorized in this Order without the written consent of Tamara Sewell. 4. The Father, Jason Bacon, shall have periods of visitation with the Child on alternating Saturday mornings from 9:00 a.m. until 12:00 noon at the Mother's residence, unless otherwise agreed between the parties. 5. The parties shall share having custody of the Child on holidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run from 4:00 p.m. until 10:00 p.m. on Christmas Eve, and Segment B, which shall run from Christmas Eve at 10:00 through December 26 at 12:00 noon. In every year, Kimberly shall have custody during Segment A and Tamara shall have custody during Segment B. In the event Segment B of the Christmas holiday schedule supercedes Kimberly's regular weekend period of custody, the parties shall cooperate in establishing appropriate make-up time for the lost period of regular custody. The Father may have a period of custody with the Child during Segment A as arranged between the Father and Kimberly. B. Mother's Day/Father's Day: In every year, Tamara shall have custody of the Child on Mother's Day and the Father and Kimberly shall have custody of the Child on Father's Day from 9:00 a.m. until 7:00 p.m. C. Remaining Holidays: The parties shall share or alternating having custody of the Child on the remaining holidays as arranged by agreement. D. The holiday custody schedule shall supercede and take precedence over the regular custody schedule. 6. The Father shall make arrangements to ensure that the Child's paternal grandparents engage in a minimum of two counseling sessions which Tamara shall also attend with Reverend Cindy Garis. The purpose of the counseling shall be to address issues and conflicts which have arisen with regard to the return of custody of the Child to the Mother, with the goal of reestablishing and reinforcing trust and cooperation between the paternal grandparents and Tamara. 7. With the exception of the weekday periods of custody for Kimberly, who shall provide all transportation on Wednesdays, the party relinquishing custody shall be responsible to provide transportation for the exchanges of custody under this Order. 8. The parties shall refrain from smoking in the car or in the same room of the house when the Child is present and shall ensure that third parties having contact with the Child comply with this provision. 9. The parties agree that the Child shall not be left alone in the care of a child or children who are under 16 years of age. 10. In the event any party intends to relocate his or her residence outside Cumberland, Dauphin or York Counties, that party shall provide at least 60 days advance notice to the other parties of the intended relocation. The purpose of the notice under this provision is to enable the parties to establish alternative custodial arrangements by agreement upon relocation or to obtain resolution through the legal process. 11. Each party shall ensure that the other parties have his or her current address and telephone number at all times. 12. Kimberly may contact the Child by telephone at 8:45 p.m. on days when she does not have a period of custody. In the event the Child is not at home to receive the telephone call at that time, Tamara shall initiate the call to Kimberly to ensure that the contact takes place. The Father may contact the Child by telephone while she is in Tamara's custody two times per week. 13. The parties and counsel shall attend an additional custody conciliation conference in the office of the conciliator, Dawn S. Sunday, on May 2, 2006 at 8:30 a.m. to review the custodial arrangements. 14. None of the parties shall do or say anything which may estrange the Child from the other parties, injure the opinion of the Child as to the other parties, or hamper the free and natural development of the Child's love and respect for the other parties. All parties shall ensure that third parties having contact with the Child comply with this provision. 15. 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 consent. In the absence of consent, the terms of this Order shall control. cc: Derek Cordier, Esquire - Counsel for Plaintiffs Heather Z. Reynosa, Esquire - Counsel for Defendant ?; _;?: «_ <:? JASON C. BACON AND KIMBERLY R. HAGEMEYER Plaintiff VS. TAMARA N. SEWELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 05-6774 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Ariyanna Hope Taylor March 6, 2004 Mother 2. A custody conciliation conference was held on February 7, 2006, with the following individuals in attendance: The Father, Jason Bacon and the Mother's former partner, Kimberly Hagemeyer, with their counsel, Derek Cordier, Esquire, and the Mother, Tamara N. Sewell, with her counsel, Heather Z. Reynosa, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator JASON BACON AND KIMBERLEY HAGEMEYER Plaintiffs VS. TAMARA N. SEWELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 05-6774 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this day of \4 j - , 2006, upon consideration of the attached Custody Conciliation Repo , rt s or re and directed as follows: The prior Order of this Court dated February 21, 2006 shall continue in effect as modified by this Order. During alternating weeks, Kimberley Hagemeyer's Wednesday evening periods of custody with the Child shall be expanded overnight through Thursday morning when she shall transport the Child to daycare. The overnight periods of custody under this provision shall begin on the first Wednesday in July unless otherwise agreed between the parties. 2. Paragraph 5A of the prior Order is amended to expand Segment A of the Christmas holiday period of custody, which shall run from December 23 at 7:00 p.m. (or earlier as arranged by agreement) through December 24 at 10:00 p.m. The parties agree to continue cooperating in working gradually toward unsupervised periods of custody for the Father with the Child. 4. Paragraph 6 of the prior Order is vacated. The parties may have periods of vacation custody with the Child as arranged by agreement. 6. 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, Edgar B. Bayley ' J. cc: er k Cordier, Esquire - Counsel for Plaintiffs ather Z. Reynosa, Esquire - Counsel for Defendant 0`Y 6 r 4~) _ CZ) - o? LL ?- 1 - cv :J JASON BACON AND KIMBERLY HAGEMEYER Plaintiffs VS. TAMARA N. SEWELL Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 05-6774 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Airyanna Taylor March 6, 2004 Defendant Mother 2. A Custody Conciliation Conference was held on June 22, 2006, with the following individuals in attendance: The Father, Jason Bacon, and the in loco parentis Mother, Kimberley Hagemeyer, with their counsel, Derek Cordier, Esquire, and the biological Mother, Tamara N. Sewell, with her counsel, Heather Z. Reynosa. 3. The parties agreed to entry of an Order in the form as attached. a&, -200& Date Dawn S. Sunday, Esquire Custody Conciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Jason C. Bacon PLAINTIFF Vs. FAMILY COURT DIVISION CIVIL ACTION Or- Grey Tamara N Sewell and Kimberly R Hagemeyer, DEFENDANT PETITION TO MODIFY CUSTODY ORDER 1. Petitioner is Jason C. Bacon is the plaintiff in the custody complaint, and resides at 25 Heidi Terrace, Camp Hill, PA 17011. 2A. Respondent is Tamara N. Sewell is the defendant in the custody complaint, and resides at 310 Shepherd Lane, Shippensburg, PA 17257. 2B. Respondent is Kimberly R. Hagemeyer is the defendant in the custody complaint, and resides at 1612 Catherine Street, Harrisburg, PA 17104. 3. On July 3, 2006, The Honorable Edgar B. Bayley entered the following orders: please see attached documents, dated July 3, 2006, and February 21, 2006. 4. The best interest of the child will be served by the court in modifying said order, because: A. Kimberly Hagemeyer refuses to help pay child support. B. Kimberly Hagemeyer has proven to be a detriment to Ariyanna's care and general well being by not following doctors' orders for Ariyanna's health. 5. Petitioner requests that the order be changed to provide as follows: A. Kimberly Hagemeyer shall be removed of all rights as "in loco parentis", as these privileges will cease to be granted by both the biological mother and biological father. Furthermore, Ms. Hagemeyer will relinquish all visitation privileges and telephone contact privileges with Ariyanna Taylor. B. Tamara N. Sewell and Jason C. Bacon shall have joint legal custody of Ariyanna Hope Taylor, born March 6, 2004. Each party shall have an equal right, to be exercised jointly with the other party, to make all major non-emergency decisions affecting Ariyanna's general well-being including, but not limited to, all decisions regarding her health, education, and religion. Pursuant to the terms of this paragraph, each party shall be entitled to all records and information pertaining to Ariyanna including, but not limited to, school and medical records, and information. C. Tamara Sewell shall have primary physical custody of Ariyanna. D. Jason and Tamara shall alternate weekend custody of Ariyanna. 1.) If the regular alternating schedule needs to be adjusted due to work, vacations, etc., Jason and Tamara will come to an agreement to adjust the schedule as necessary. E. The parties shall share having custody of Ariyanna on holidays as follows: 1.) Christmas: Jason will have custody of Ariyanna from December 23 at 7:00 pm through December 24 at 10:00 pm. Tamara will have custody from December 24 at 10:00 pm through December 25. 2.) Mother's DgL/Father's Day: In every year, Tamara shall have custody of Ariyanna on Mother's Day and Jason shall have custody of Ariyanna on Father's Day. 3.) Remaining Holidays: Jason and Tamara shall share or alternate having custody of Ariyanna on the remaining holidays as arranged by agreement. 4.) The holiday schedule shall supersede and take precedence over the regular custody schedule. F. The party relinquishing custody shall be responsible to provide transportation for the exchanges of the custody under this order. G. In the event any party intends to relocate his or her residence outside Cumberland, Dauphin, or York Counties, that party shall provide at least 60 days advance notice to the other party of the intended location. The purpose of the notice is to enable the parties to establish alternative custodial arrangements by agreement upon relocation or to obtain resolution through the legal process. H. Each party shall ensure that the other party has his or her current address and telephone number at all times. WHEREFORE, Date: Petitioner: 1 prays this court to grant the petition to modify. I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of PA. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: /t/&1(17 Petitioner: LI,Le? C'_ Cac'v , FILED- 31: ;CF OF THE PR'0 tj!"" ;CTARY 2009 NOY -6 AM 10: 14 $?O.oo Po PLFF- OPSK Rx4 a3-way JASON C. BACON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2005-6774 CIVIL ACTION LAW TAMARA N. SEWELL AND KIMBERLY R. HAGEMEYER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, November 10, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, December 10, 2009 at 12:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute, or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Es q. ,, Wk Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 aoer /y7a( ISCL 46 J. t K , 4a?c"LE y VL_, ocrlis 1n-wc t-ccc4a `7.' SIEWELL Cori, .nay r? ?o A'4y z- S`"7 I/ . DEC 2' 2009 JASON BACON and IN THE COURT OF COMMON PLEAS OF KIMBERLEY HAGEMEYER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. 05-6774 CIVIL ACTION LAW TAMARA N. SEWELL Defendant IN CUSTODY ORDER OF COURT AND NOW, this z z -t day of 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court dated February 21, 2006 and July 3, 2006 are vacated and replaced with this Order. 2. Tamara N. Sewell, Kimberley Hagemeyer, and Jason C. Bacon shall have shared legal custody of Ariyanna Taylor, born March 6, 2004. Major decisions concerning the Child including, but not necessarily limited to, her health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. No party shall impair any other party's rights to shared legal custody of the Child. No party shall attempt to alienate the affections of the Child from the other parties. Each party shall notify the other parties of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the others. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other parents of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to any party as a parent as authorized by statute. In the event that after consulting on major decisions, the parents are unable to reach a consensual decision, Tamara N. Sewell shall have final decision making authority. 3. Tamara N. Sewell shall have primary physical custody of the Child. 4. Kimberley Hagemeyer and Jason Bacon shall each have partial physical custody of the Child on every third weekend from Friday evening through Sunday at 7:00 p.m. Tamara N. Sewell shall have custody of the Child on the third weekend in the rotating schedule. other parties of the selected dates. The parties shall cooperate in scheduling vacations at separate times. 6. The parties shall share having custody of the Child on holidays as follows: A. Christmas: Kimberley Hagemeyer shall have custody of the Child from December 23 at 7:00 p.m. through December 24 at 1:00 p.m., Jason Bacon shall have custody of the Child on December 24 from 1:00 p.m. until 10:00 p.m., and Tamara Sewell shall have custody of the Child from December 24 at 10:00 p.m. through December 26 at 10:00 a.m. B. Thanksgiving/Memorial DU/Labor Day: The parties shall rotate having custody of the Child for Thanksgiving, Memorial Day and Labor Day, with each party having custody of the Child for each holiday every three years. C. Parents' Day: Tamara Sewell shall have custody of the Child every year for Mother's Day, Jason Bacon shall have custody of the Child every year on Father's Day and Kimberley Hagemeyer shall have custody of the Child every year for Mommy Kim Day, which is the third Sunday in July. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 7. The parties agree that they shall all work together consistently to ensure that the Child follows her dietary and exercise plan. Until the parties agree that it is no longer useful, Kimberley Hagemeyer shall inform the other parties in writing through an email after each period of custody what the Child has eaten during the weekend. The purpose of this provision is to promote communication between the parties and cooperation in addressing concerns between the parties related to the Child. 8. No party shall do or say anything which may estrange the Child from the other parties, injure the opinion of the Child as to the other parties, or hamper the free and natural development of the Child's love and respect for the other parties. All parties shall ensure that third parties having contact with the Child comply with this provision. 9. The non-custodial parties shall be entitled to have reasonable telephone contact with the Child. 10. 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 the consent of all parties. In the absence of consent, the terms of this Order shall control. BY THE COURT, 0 %?r Edgar B ayley J. cc: ?J on C. Bacon - Father ara N. Sewell - Biological Mother ?Kenneth A. Wise, Esquire, Counsel for In Loco Parentis Mother 04f tE?S r Tk,3l LL 1z f a?.`o? ?'1 11 JASON BACON and KIMBERLEY HAGEMEYER Plaintiff vs. TAMARA N. SEWELL Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 05-6774 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Ariyanna Tayler March 6, 2004 Tamara N. Sewell 2. A custody conciliation conference was held on December 10, 2009, with the following individuals in attendance: the biological Father, Jason C. Bacon, pro se, the biological Mother, Tamara N. Sewell, pro se, and the in loco parentis Mother, Kimberley Hagemeyer, with her counsel, Kenneth A. Wise, Esquire. 3. Kimberley Hagemeyer, Co-Plaintiff in the originally filed action, maintains her status as in loco parentis Mother. 3. The parties agreed to entry of an Order in the form as attached. aumtibe4 900 q Date Dawn S. Sunday, Esquire Custody Conciliator FILE C UIi I O t: ROT H111-1 ??,")YTARY 2009 DEC 22 f h, in: t+ 6 d; JASON BACON and KIMBERLEY HAGEMEYER Plaintiff vs. TAMARA N. SEWELL Defendant JAN 1 12010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 05-6774 IN CUSTODY ORDER OF COURT CIVIL ACTION LAW N _ w r AND NOW, this /?- ' day of 2009, consideration of the attached Custody Conciliation Repo ft, it is rdered and directed as follows: Y -' Y rn upon 1. The prior Orders of this Court dated February 21, 2006 and July 3, 2006 are vacated and replaced with this Order. 2. Tamara N. Sewell, Kimberley Hagemeyer, and Jason C. Bacon shall have shared legal custody of Ariyanna Tayler, born March 6, 2004. Major decisions concerning the Child including, but not necessarily limited to, her health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. No party shall impair any other party's rights to shared legal custody of the Child. No party shall attempt to alienate the affections of the Child from the other parties. Each party shall notify the other parties of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the others. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other parents of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to any party as a parent as authorized by statute. In the event that after consulting on major decisions, the parents are unable to reach a consensual decision, Tamara N. Sewell shall have final decision making authority. 3. Tamara N. Sewell shall have primary physical custody of the Child. 4. Kimberley Hagemeyer and Jason Bacon shall each have partial physical custody of the Child on every third weekend from Friday evening through Sunday at 7:00 p.m. Tamara N. Sewell shall have custody of the Child on the third weekend in the rotating schedule. 5. Tamara Sewell, Kimberley Hagemeyer and Jason Bacon shall each be entitled to have custody of the Child for one uninterrupted week in the summer each year upon providing notice to the other parties of the selected dates. The parties shall cooperate in scheduling vacations at separate times. 6. The parties shall share having custody of the Child on holidays as follows: A. Christmas: Kimberley Hagemeyer shall have custody of the Child from December 23 at 7:00 p.m. through December 24 at 1:00 p.m., Jason Bacon shall have custody of the Child on December 24 from 1:00 p.m. until 10:00 p.m., and Tamara Sewell shall have custody of the Child from December 24 at 10:00 p.m. through December 26 at 10:00 a.m. B. Thanks ig ving/Memorial Day/Labor Day: The parties shall rotate having custody of the Child for Thanksgiving, Memorial Day and Labor Day, with each party having custody of the Child for each holiday every three years. C. Parents' Day: Tamara Sewell shall have custody of the Child every year for Mother's Day, Jason Bacon shall have custody of the Child every year on Father's Day and Kimberley Hagemeyer shall have custody of the Child every year for Mommy Kim Day, which is the third Sunday in July. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 7. The parties agree that they shall all work together consistently to ensure that the Child follows her dietary and exercise plan. Until the parties agree that it is no longer useful, Kimberley Hagemeyer shall inform the other parties in writing through an email after each period of custody what the Child has eaten during the weekend. The purpose of this provision is to promote communication between the parties and cooperation in addressing concerns between the parties related to the Child. 8. No party shall do or say anything which may estrange the Child from the other parties, injure the opinion of the Child as to the other parties, or hamper the free and natural development of the Child's love and respect for the other parties. All parties shall ensure that third parties having contact with the Child comply with this provision. 9. The non-custodial parties shall be entitled to have reasonable telephone contact with the Child. 10. 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 the consent of all parties. In the absence of consent, the terms of this Order shall control. BY THE COURT, / J. cc: '1J n C. Bacon - Father araN. Sewell - Biological Mother Xnneth A. Wise, Esquire, Counsel for In Loco Parentis Mother 0,6 zs m.-xtL;?C 12/10 J JASON BACON and KIMBERLEY HAGEMEYER Plaintiff r ?. TAMARA N. SEWELL Defendant Prior Judge: Edgar B. Bayley IN THE COURT _OFCOMMON .PLEAS OF CUMBERLAND COUNTY; PENNSYLVANIA 05.6774 CIVIL ACTION LAW IN CUSTODY CUSTODY C!QNCILIATION S.. Y REPURT IN ACCORDANCE WITH CUMBERLAND COUNTY - RULE OF ` CIVIL PROCED THE 191.5.3-8, 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: DAJE OF TH CU NTLY.IN_,CUSTQDY.:OF - Anyanna Tayler March 6, 2004 Tamara N. Sewell 2: A custody conciliation conference was held on December 10,. 2009, with the following individuals in attendance: the biological Father, Jason C. Bacon; pro se, the biological' Mother, Tamara N.>Seweli, pro Se; and the in loco parentis Mother, Kimberley. Hagemeyer, with her counsel, Kenneth A. Wise, Esquire. 3. Kimberley Hagemeyer, Co-Plaintiff in. the. originally filed action, maintains her status as in loco parentis Mother. 3. The parties agreed to entry of an Order in the form as attached: 19 00 Date Dawn S. Sunday,: Esquire Custody Conciliator COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JASON C. BACON, and KIMBERLY R. HAGEMEYER Plaintiff V. TAMARA N. SEWELL, Defendant No. 05-6774 ) Petition for Modification 4'7 T?i r c -? r- M CO ,.? c3 > ..Z . A 06 P ? 70 o s? ql 1. Petitioner is Defendant, TAMARA N. SEWELL, who currently resides at 301 Harvest Lane, Shippensburg, Cumberland County, PA 17257. 2. Respondent is Plaintiff, JASON C. BACON, who currently resides at 25 Heidi Terrace, Camp Hill, Cumberland County, PA 17011 and KIMBERLY R. HAGEMEYER, who currently resides at 2035 Green Street, Harrisburg, Dauphin County, PA 17102. 3. Petitioner and Respondents are the natural parents of the following child: Name Age ARIYANNA H. TAYLER 6 years 4. A custody order was entered on 12th day of January, 2009, in the Cumberland County Court of Common Pleas. A copy of the custody order is attached. 5. Petitioner seeks to modify the custody order because: Kimberly Hagemeyer was instructed via the last court order to notify all parties in writing about the food that was feed to Ariyanna during her periods of custody. To date, I have only received two notices. Nothing was ever mentioned about discontinuing the notices. Ariyanna is scheduled to be returned on Sundays at 7 PM during her period of visitation. Kimberly has repeatedly returned Ariyanna late arriving at the house around 7:30 PM without prior notification that they would be late. Ariyanna has a sibling with special needs. I am looking to relocate out of state to Georgia where I have family who are willing and able to assist with the child with special needs. The weather stays warmer longer, thus allowing more opportunities for Ariyanna to participate in more sports and work on reducing her classification from obese to that of a healthy child. Petition for Modification Page 3 of 5 6. Petitioner believes the custody order should be changed as follows: I am requesting that Ariyanna spend the majority of the year residing with me and her siblings. I wish to maintain primary physical custody. Beginning the first week in July 2011 would begin the summer visitation schedule. During the summer months, I am requesting that Ariyanna reside primarily with her father, Jason Bacon, in Camp Hill. 1 request that Kimberly Hagemeyer's visitation be reduced to every other weekend. Ariyanna would be returned to me the last full week of July (July 24, 2011) by 5PM to be able to prepare her for school which begins in Georgia August 1 st. WHEREFORE, Petitioner respectfully requests that this Court modify the Order as requested. Date:Z N. SEWELL, Defendant Verification I, TAMARA N. SEWELL, Defendant, verify that the facts stated in the foregoing Petition are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. ' 4904 relating to unworn falsification to authorities. Date: TA N. SEWELL, Defendant Petition for Modification Page 4 of 5 JAN 1 1 2010 JASON BACON and IN THE COURT OF COMMON PLEAS OF KIMBERLEY HAGEMEYER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. 05-6774 CIVIL ACTION LAW TAMARA N. SEWELL Defendant IN CUSTODY ORDER OF COURT AND NOW, this f.±L,- day of 2009, upon consideration of the attached Custody Conciliation Report, it is or ered and directed as follows: L The prior Orders of this Court dated February 21, 2006 and July 3, 2006 are vacated and replaced with this Order. 2. Tamara N. Sewell, ]Kimberley Hagemeyer, and Jason C. Bacon shall have shared legal custody of Ariyanna Tayler, born March 6, 2004. Major decisions concerning the Child including, but not necessarily limited to, her health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. No party shall impair any other party's rights to shared legal custody of the Child. No party shall attempt to alienate the affections of the Child from the other parties. Each party shall notify the other parties of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the others. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other parents of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to any party as a parent as authorized by statute. In the event that after consulting on major decisions, the parents are unable to reach a consensual decision, Tamara N. Sewell shall have final decision making authority. 3. Tamara N. Sewell shall have primary physical custody of the Child. 4. Kimberley Hagemeyer and Jason Bacon shall each have partial physical custody of the Child on every third weekend from Friday evening through Sunday at 7:00 p.m. Tamara N. Sewell shall have custody of the Child on the third weekend in the rotating schedule. 5. Tamara Sewell, Kimberley Hagemeyer and Jason Bacon shall each be entitled to have custody of the Child for one uninterrupted week in the summer each year upon providing notice to the other parties of the selected dates. The parties shall cooperate in scheduling vacations at separate times. 6. The parties shall share having custody of the Child on holidays as follows: A. Christmas: Kimberley Hagemeyer shall have custody of the Child from December 23 at 7:00 p.m. through December 24 at 1:00 p.m., Jason Bacon shall have custody of the Child on December 24 from 1:00 p.m. until 10:00 p.m., and Tamara Sewell shall have custody of the Child from December 24 at 10:00 p.m. through December 26 at 10:00 a.m. B. Thanksgiving/Memorial Day/Labor Day: The parties shall rotate having custody of the Child for Thanksgiving, Memorial Day and Labor Day, with each party having custody of the Child for each holiday every three years. C. Parents' Day: Tamara Sewell shall have custody of the Child every year for Mother's Day, Jason Bacon shall have custody of the Child every year on Father's Day and Kimberley Hagemeyer shall have custody of the Child every year for Mommy Kim Day, which is the third Sunday in July. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 7. The parties agree that they shall all work together consistently to ensure that the Child follows her dietary and exercise plan. Until the parties agree that it is no longer useful, Kimberley Hagemeyer shall inform the other parties in writing through an email after each period of custody what the Child has eaten during the weekend. The purpose of this provision is to promote communication between the parties and cooperation in addressing concerns between the parties related to the Child. 8. No party shall do or say anything which may estrange the Child from the other parties, injure the opinion of the Child as to the other parties, or hamper the free and natural development of the Child's love and respect for the other parties. All parties shall ensure that third parties having contact with the Child comply with this provision. Child. The non-custodial parties shall be entitled to have reasonable telephone contact with the 10. 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 the consent of all parties. In the absence of consent, the terms of this Order shall control. BY THE COURT, J. cc: Jason C. Bacon - Father Tamara N. Sewell - Biological Mother Kenneth A. Wise, Esquire, Counsel for In Loco Parentis Mother ii a 2 Custody Conciliator JASON C. BACON AND KIMBERLY R. IN THE COURT OF COMMON PLEAS OF HAGEMEYER PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAN t ' + -. o 2 (v-? Chi ? i-'- -'F•i V. 2005-6774 CIVIL ACTION LAW 1_55 r- TAMARA N. SEWELL -; IN CUSTODY 4T DEFENDANT ORDER OF COURT AND NOW, Thursday, March 03, 2011 , upon consideration of the attached Complai nt, 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, April 05, 2011 _ at 12:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunday, Esq. t 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. U ( Cumberland County Bar Association v 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 TC,56 A &0 11 y JASON C. BACON and IN THE COURT OF COMMON PLEAS OF KIMBERLY R. HAGEMEYER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. 2005-6774 CIVIL ACTION LAW c n -acs nr- 7o -0 TAMARA N. SEWELL ° 2 Defendant IN CUSTODY na ;Z " CD N CDC rll ORDER OF COURTS -A c AND NOW, this / 3 day of 14,o n 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated January 12, 2009 is vacated and replaced with this Order. 2. Tamara N. Sewell, Kimberly Hagemeyer, and Jason C. Bacon shall have shared legal custody of Ariyanna Tayler, born March 6, 2004. Major decisions concerning the Child including, but not necessarily limited to, her health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. No party shall impair the other parties' rights to shared legal custody of the Child. No party shall attempt to alienate the affections of the Child from the other parties. Each party shall notify the other parties of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the other parties. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other parties of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to any party as a parent as authorized by statute. 3. Tamara N. Sewell shall have primary physical custody of the Child and the parties agree that she may relocate with the Child to Georgia after the end of the 2010-2011 school year. 4. Until the end of the school year in June 2011, Kimberly Hagemeyer and Jason Bacon shall each continue to have partial physical custody of the Child on every third weekend from Friday evening through Sunday at 7:00 p.m. and Tamara Sewell shall have custody of the Child on the third weekend in the rotating schedule. 5. Beginning after the last day of school in June, 2011 and continuing during summers thereafter following the Child's relocation to Georgia, Kimberly Hagemeyer and Jason Bacon shall alternate having custody of the Child in June and July on a weekly basis, with the exchange to take place every week on Sunday at 7:00 p.m. In odd-numbered years, Kimberly Hagemeyer shall begin the summer custody schedule with the first week in June and in even-numbered years, Jason Bacon shall begin the summer custody schedule for the first week in June. The summer custody schedule shall end each year after the third week of July to enable the Child to return to Georgia for the last full week of July to prepare for the next school year which begins the first week of August in Georgia. In 2011, prior to the relocation, Kimberly Hagemeyer shall have the first week after the end of the school year in Pennsylvania. 6. For the Christmas holiday in every year, Kimberly Hagemeyer shall have custody of the Child from December 27 through December 29 and Jason Bacon shall have custody from December 29 through December 31, with the exchange day to be shared equally between them. The Christmas holiday period of custody may be extended in years in which January 1 falls on a Friday and school does not resume until January 3, but the Child shall be returned to Georgia at least one full day prior to the beginning of school. 7. All exchanges of custody between Tamara Sewell and either Jason Bacon or Kimberly Hagemeyer shall take place at the half way point between Central Pennsylvania and Tamara Sewell's residence in Georgia. 8. The parties agree that they shall work together consistently to ensure that the Child follows her dietary and exercise plan. The parties shall cooperate in continuing to communicate about addressing concerns pertaining to the Child's health related issues. 9. The custodial party shall ensure that the Child contacts Tamara Sewell by telephone at least two times each week during periods of partial custody. 10. Kimberly Hagemeyer and Jason Bacon shall be entitled to have reasonable liberal telephone contact with the Child. 11. Tamara Sewell shall continue to share information with the non-custodial parents concerning the Child's school progress and other developments such as report cards, school events, extracurricular activities, and school photos. 12. No party shall do or say anything which may estrange the Child from the other parties, injure the opinion of the Child as to the other parties, or hamper the free and natural development of the Child's love and respect for the other parties. All parties shall ensure that third parties having contact with the Child comply with this provision. 13. 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 the consent of all parties. In the absence of the consent of all parties, the terms of this Order shall control. BY THE COURT, /Z `/7 Kevin A. Ws J. cc: /Kimberly R. Hagemeyer - In Loco Parentis MotVr /Jason C. Bacon - Father ?'Tamara N. Sewell - Mother Mai eopios 1 pr8 JASON C. BACON and IN THE COURT OF COMMON PLEAS OF KIMBERLY R. HAGEMEYER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. 2005-6774 CIVIL ACTION LAW TAMARA N. SEWELL 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 DATE OF BIRTH CURRENTLY IN CUSTODY OF Ariyanna H. Tayler March 6, 2004 Tamara N. Sewell 2. A custody conciliation conference was held on April 5, 2011, with the following individuals in attendance: the biological Father, Jason C. Bacon, the biological Mother, Tamara N. Sewell, and the in loco parentis Mother, Kimberly R. Hagemeyer, none of whom were represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. Aoi 64dc)'I Date Dawn S. Sunday, Esquire Custody Conciliator