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HomeMy WebLinkAbout02-1004 SAlOIS SHUFF, FLOWER & LINDSAY A1TORNEYS'AT'!.AW 26 W. High Street Carlisle. P A ROBERT HOLTER and LINDA HOLTER, Petitioners v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. D;) -/1)07 CIVIL CIVIL ACTION - VISITATION CHRISTINA HOLTER, Respondent PETITION FOR VISITATION AND NOW comes the Petitioners, Robert and Linda Holter, by and through their attorneys, Saidis, Shuff, Flower & Lindsay and respectfully aver the following: 1. Your Petitioners are Robert and Linda Holter, adult individuals residing at 2131 Circle Road, Carlisle, Cumberland County, Pennsylvania. 2. Your Respondent is Christina Holter, an adult individual residing at 331 North College Street, Carlisle, Cumberland, Pennsylvania. 3. The Petitioners are the grandparents of two children, William Alexander Holter, date of birth 3/24/87 and Derek Austin Holter, date of birth 3/27/90. 4. The Respondent is the natural mother of the subject children. 5. The natural father of the subject children, Gregory Dean Holter, was the son of the Petitioners, and died on October 31, 1996; at the time of his death he was separated from the Respondent. SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYSeAT.UW 26 W. High Street Carlisle, PA 6. The Petitioners, at one time, had visitation and contact with the children, and have not for the past year and a half. 7. The children are presently in the custody of the Respondent, who resides with her boyfriend. 8. The Petitioners also have a minor child, Jordan Holter, age 12, who resides with them. 9. Petitioners have not participated as a party or a witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 10. The best interests and permanent welfare of the children will be served by granting them visitation rights with the children because they have been denied contact for the last year and a half with the children by the Respondent. She has physically kept the children away from them. Gifts were purchased for the grandchildren, but since they were never allowed to see their grandparents, they had to be returned to the stores. She has moved out of the state with the children and not advised the Petitioners of where they have gone and has prevented any continuing relationship with their grandchildren. The Petitioners would like to reestablish the relationship with their grandchildren, especially while they are still in the area. 2 SAlOIS SHUFF, FLOWER & LINDSAY A1TORNEYS.ATeLAW 26 W. High Street Carlisle, P A WHEREFORE, Petitioners respectfully request Your Honorable Court to enter an Order granting them periods of partial physical custody/visitation for the children as the Court may deem appropriate. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Dated: d- ,;).'1-0",;( 3 VERIFICATION 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 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: <~-~If~~~ fl&!f?' 14& SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYSeAT.LAW 26 W. High Street Carlisle. PA VERIFICATION 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 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: ,.1;.<10 V , ;::t:. ~ ~~. Holter ~ SAIDIS SHUFF, FLOWER & LINDSAY ATrORNEYSeAT-LAW 26 W. High Street Carlisle, P A ~~ - 1+ ~ - ~ ~ ~o() ,. @ C:i (:) . ,~ @ ---==-~ ~ ~ (') (\~ , (") 0 C) c: 1"<) 1 ~~ "It ..._~, -oUI ~.:... mr"n ;',"0 -- Z:X.' " ."'J~:U ze" I )",.....' U)),;: S::: (J:) ~6 ;po . r. (~::5 ~~ ~8 :Ji: "'7 <,._ "";:;;:rn >~ - ~ .. ~ Co,,) ~ (::> -< PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA ROBERT HOLTER AND LINDA HOLTER v. 02-1004 CIVIL ACTION LAW CHRISTINA HOLTER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, March 07, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, April 03, 2002 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Jacqueline M. Verney. Esq:. OW' Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . . ~ ~-~'lJ~ ~~~ -~'Z ~ ~lL, -r;41'~~~~P9 VfNVAlASNN3d AlNn08 O~til1:B8i'VnO 01 :OIIIV g"I:l~W 20 AiY/IONC,: 'I; . .~ :10 ;:JI:l;-I(}--OfiU eO-3. [' ('cJ. ,$. E: e t;l.,$- f: ROBERT HOLTER AND LINDA HOLTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-1004 CIVIL ACTION LAW v. CHRISTINA HOLTER, Defendant IN CUSTODY PRELIMINARY OBJECTIONS AND NOW, comes the Defendant, Christina Holter, by and through her attorneys, THE LAW OFFICES OF PAUL BRADFORD ORR, Gregory 1. Cutler, Esquire, and Paul Bradford Orr, Esquire, file these Preliminary Objections in accordance with Pa. R. Civ. P. 1028 and respectfully avers as follows: 1. On March 1, 2002, a custody complaint was filed by Robert and Linda Holter requesting visitation of their grandchildren, William A. Holter (born March 23,1987) and Dereck A. Holter (born March 26, 1990). 2. On March 7,2002, an Order of Court was issued requiring all parties to appear at a Pre-Hearing Custody Conference now scheduled for April 3, 2002. 3. On approximately March 9, 2002, the Defendant received the Order of Court dated March 7, 2002, via regular mail. 4. On March 13, 2002, Plaintiffs' counsel sent the Defendant's counsel a complaint via facsimile transmittal. 5. The above named Defendant, Christina Holter, was never served a copy of the custody complaint filed by the Plaintiffs in this action as required by Pa. R. Civ. P. 1930.4. 6. On May 27, 1987 this Honorable Court granted legal and physical custody of William A. Holter to Wayne Eugene Jewell and Pamela Dale Jewell. (Defendant's Exhibit "A"). Page 1 of 2 7. Wayne Eugene Jewell and Pamela Dale Jewell are necessary parties that the Plaintiff's must include as Defendants, and who must be served pursuant to Pa. R. Civ. P. 1930.4. WHEREFORE, the Defendant requests that the Complaint filed on March 1,2002, be dismissed. Respectfully Submitted, THE LAW OFFICES OF PAUL BRADFORD ORR Date: J /;}5" fr), By4~!"~ Attorney for Defendant 50 East High Street Carlisle, P A 17013 (717) 8-8558 up e ourt ID Dore 3{ as[ 01- aul Bradfor , Esquire Attorney for Defendant 50 East High Street Carlisle, P A 17013 (717) 258-8558 Supreme Court ID #71786 By: Page 2 of 2 ROBERT HOLTER AND LINDA HOLTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 02-1004 CML ACTION LAW CHRISTINA HOLTER, Defendant IN CUSTODY CERTIFlCA TE OF SERVICE I, Gregory L. Cutler, Esquire, hereby certify that a copy of the attached Preliminary Objections was served upon the following by depositing a true and correct copy of the same in the United States mail, first class, postage prepaid on the date referenced below and addressed as follows: Johnna J. Kopecky, Esquire SAlDIS, SHUFF, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 Date: 3/J- S 1o:J-- HOLTER IN THE COURT OF COMMON PLEAS OF CUMBERLANO COUNTY, PENNSYLVANIA CIVIL ACTION . CUSTODY CIVIL 1987 ... ~ .Qf f.Q.!!.!ll NOW, this.2'1 day of May, 1987, uponceview.of the Petition for Custody, and the attached Consents , it is hereby ordered and decreed that William Alexander , born March 23, 1987, age two (2) months, be placed in the and physical custody of Wayne Eugene Jewell and Pamela Dale' " the maternal grandparents of the child. .. itation with the parents of William Alexander Holter and grandparents of said child shall be as the parties 8Y THE COURT, /0/ ~ '$; %: 'd'; A TRUE COpy Ff<OM~~ . " Temmony w~e'''''''f. I hl!rt1:H""t~;S!lt rrtf.... ~n.j the ~ol .f')f Sq,.i C!lurt of C~~lfsl~~ Po. hIS~.....,~Ji ot.......~.~~-;;;T...}9Lt. _.....~...~..~;~~1J;;r~:~ ........,.. S ~~ ;,i~~,* DEFENDANT' . ~ ..."...":!~ ,., . · EXHIBIT 'J: .:j' I'/~)) :'",_~ / 1 y"",' "'j -\- VERIFICATION I verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 9 4904, relating to unsworn falsification to authorities. DATE: ~i'\'~ Christina Holter, Defendant >- tr , ~: c'- c-: ~;:_~ ,. .-s 0~J , -' . ) l";'. '. , n 0-; c: f~ ...:c.,_ ., :'; .. C-,I ~.~5 (:J u (.) ROBERT HOLTER AND LINDA HOLTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 02- 1004 CML ACTION LAW CHRISTINA HOLTER, Defendant IN CUSTODY RULE TO SHOW CAUSE AND NOW, this "2-" day of ~ .2002, upon consideration of the Defendant's Preliminary Objections, it is hereby ORDERED that: I. A Rule is issued upon the Plaintiffs to show cause why the Defendant is not entitled to the relief requested; 2. ..,.,1.....~ . 1"4"'- ~h~lI flIp an A...()..~'O'.. t~tb.i P 1" ';ni~' Qbju~jQRO 'L11~1l ,,20) d...J... ...f ~nn('e~ 9r iie an hOfuRSIA G...n'lpl~l '1ng ap,rgpRat- r-..4.;^,,: 3 ~L-;;;;:vr~D.~~.~ ~ ~ eM" v'\IV1~~ ecA- g,,\ ~ BY THE COURy"------ ~ vh?'1 \ -I, ""rlfl'l- J, / , . ., , ~.~$~ ~ hz?~ ~ ~ 4w. r9 " ('V1 {-e'. [ -e'C1- (. r:' . [' \f,NlfiC!ASNf\!3d I ! ~ Ir"',("'{"\ (-~\<\.rJ1.J~i;Ji/,ln""" 1\..l..1\i1 "__ ,,_I '.,1 "_:""_'~' 'V ~ . J' L'7 "I U -'0 o I : ,] I" d t. e,;, G. Al::lV10i'lC,",..i.',,",::..':,j jO :L)r1:-:G--O:;-;:j "F ... ROBERT HOLTER AND LINDA HOLTER, PLAINTIFFS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTINA HOLTER, DEFENDANT 02-1004 CIVIL TERM AND NOW, this ORDER OF COURT l~r day of April, 2002, the preliminary objections of Christina Holter, to plaintiffs' complaint, ARE SUSTAINED.1 Court, Johnna J. Kopecky, Esquire F or Plaintiffs Gregory L. Cutler, Esquire For Defendant ~ ~ If. 0,). oJ.- Q- Jacqueline Verney, Esquire :saa I This order renders moot the issues to be presented at the conciliation conference now scheduled for April 3, 2002, which conference is cancelled. \l!!\Vj'"'~ASr<[,\3d ,\1~'K1C(i ',r""~;:J;:]L"'~n8 Z'l :\llcl"if i - i:Jd~ ZQ :lCJ SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS'AT'LAW 26 W. High Street Carlisle. P A ROBERT HOLTER and LINDA HOLTER, Petitioners v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1004 CIVil : CIVil ACTION - VISITATION CHRISTINA HOLTER, WAYNE EUGENE JEWEll and PAMELA DALE JEWELL, his Wife, Respondents AMENDED PETITION FOR VISITATION AND NOW comes the Petitioners, Robert and Linda Holter, by and through their attorneys, Saidis, Shuff, Flower & Lindsay and respectfully aver the following: 1. Your Petitioners filed a Petition for Visitation on or about March 1,2002, for visitation of William Alexander Holter date of birth 3-24-87 and Derek Austin Holter date of birth 3-27-90. 2. After the filing of the Petition, it has come to the attention of the Petitioners that there was a prior Order dated May 27, 1987 giving custody of one of the children, William Alexander Holter to the maternal grandparents of the child, Wayne Eugene Jewell and Pamela Dale Jewell. 3. The purpose of this Amended Petition is to join them as party. WHEREFORE, Petitioners respectfully request Your Honorable Court to enter an Order granting them periods of partial physical custodylvisitation for the children as the Court may deem appropriate. Respectfully submitted, SAlOIS, SHUFF, I' ER & Dated: '-f-'2--Z-D~ John Atto 1.0.#5 47 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Petitioners Exhibit A ''''.#il~'''l!{~t,-_'C_..k ::~i, , " ~"":'<'~"'~':""""."--l: ,~(,..i,~.{:,:,i.H""::""'i.:':'!" , .~; :~': . ..~~..--._... ',- ~'.. ,I N ~Er,:": WILLIAM ALEXANDER HOLTER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY CIVIL 1987 -, ;;...J' :;(;. "':': ORDER OF COURT --- ... ---.:.; t:/~' ,;. ,';' .':;~t'L ~, .' ),~:,,:: C' "," . AND NOW, this.:21 day of May, 1987, upon review_of the Petition for Custody, and the attached Consents !i;," 'l':: . "foregoing thereto, .1 ;' . legal and physical custody of Wayne Eugene Jewell and Pamela Dale' _. ;,: ~': '-. "'. Jewell, the maternal grandparents of the child. ,~. , .. Holter, born March 23, 1987, age two (2l months, be placed in the it is hereby ordered and decreed that William Alexander j" . . '.',' :" ., "-, ~ 'j ," .,i;~""r": :~ - . y,; _Yisitation with the parents of William Alexander Holter and '~'i J 1,1 ,'.,the . paternal grandparents of said child shall be as the parties "",'" "','..,' .-, '...... "agree., '. J':'iJ'""...;" <.'... .'. , . .~' ~,' I,' ". ", 1 ~f -. BY THE COURT, '.:ii,;;.a;1::ii;:,] ...... -.&.."....;1".", ....:.. . , .~.!'i;;-t:WJ;.::':~' , 1'iI"'~!I>", " , 'It . '<lI,f'" ~~. It :', -: .' l' .1'J,:....,. f,tJ~ ; 1"1 ,/\~\t.' *.r~..'\' 'tf :;f~..:~e .~%:'.~t~~~~l",ll:,~y~j t':.: " , '- ~~ " ~.;',f.;f \, '0'.. ,"I' ~ i ~ 'I~ ~1iI.tl,~\i." I. , (.~. '':1~,~~ _ ;~.N"'1~:f~~P ,.';l~J : <l':''':~'if'''~)~ ~':,' " , ,l J .J' ';._'''' , . ~'l" ,I- :i IPI1<'~,.. ff . ~ I),: I''''~.;'\:-.:,/;,l.r.,'" . .", 1:;f.. :b, ~~.'l..".." ,If,,,, , '.~ it ~ (~{J !:~~:F) 1.""',!>'~ ~",[;'. . ,:;, i~:;::,.,f\4t,~;F!Y . '-. ..,<1"" ~'-'''''''''''';F'''''' '",:~-/;~:~~~:.tl;,~t,~:i;'~~~:"':{',;, ,l ", '. "Ii'''':~'''',':f<;:f'''"i..,~,....!;,., . <1~.._.., l~", 1.'l'/;..'iJ~J.r.' ,,';'.,_ , :';~ '~:'\," "i5~3:/~;~i:;~;{':,; ;:':!-~.: ;~~," .IS I t:J qaA _ '8,' ~i ' J. :,; , ~ ^ TRUE COpy FROM RI:CORD I) Testimony w~e'~"f. ! herc' unt9,Si:t my.... In.:! the s~o, ,.,f ".-:' ,J C"urr or Car/l'sJe,. Po. :J::J....._ P-" ~hj$..;18....., ~Jy or'.'.'''~'~~l_..~~~..19_,- _....~...~-~;1.'~1;~~~.;~ . ~ DEFENDANT'S tb~; "f't.~~~ EXHIBIT. ': I'"/LJ}) ,_,_,:' /7 <n, ." !.:., SAlOIS SHUFF, FLOWER & LINDSAY A1TORNEYS.AT.LAW 26 W. High Street Carlisle, PA - -~--._._.~._......_--_..~-. ..-.~ CERTIFICATE OF SERVICE On this ~)day of ~ 2002, I, Johnna Kopecky, hereby certify that I served a true and correct copy of the foregoing Amended Petition for Visitation via United States Mail, postage prepaid, addressed as follows: Paul Bradford Orr, Esquire 50 East High Street Carlisle PA 17013 SAlOIS, SHUFF, FLOWER & LINDSAY By: Johnna . opecky /.D. 3 7 26 st High Street Carlisle PA 17013 (717) 243-6222 Counsel for Petitioners ... JO R ~ ~ - ~ ~ q.) ~ ~ J: J:. -.I -I:. --f::. ~ ~ rp ~ CJ) cf () 0 0 C N <:'" -\1 ""U f'~ ,.... .~ ~rJ-) -" ::::IJ :-.0 zt:;~ N i~ .,; ", !:9 .!~: '.' .,--. 'r" ~c. ~_-_~ (~'1 ;;:;:'r-, :P> , ;Sic, =~:: TI 5 ./,"j 5>e: (:;':-;:-01 ~ -..1 :::> ...." :J.J ..,J -< _.....,.. SAlOIS SHUFF, FLOWER & LINDSAY ATJ'ORNEYS-ATeLAW 26 W. High Street Carlisle. PA ROBERT HOLTER and LINDA HOLTER, Petitioners v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1004 CIVIL CHRISTINA HOLTER, WAYNE EUGENE JEWELL and PAMELA DALE JEWELL, his Wife, : CIVIL ACTION - VISITATION Respondents ACCEPTANCE OF SERVICE I, PAUL BRADFORD ORR, Esquire due hereby accept service of the AMDENDED PETITION FOR VISITATION of the above term and number on behalf of Christina Holter, Wayne E"gene Jewell, and Pamela Dale Jewell, Respondents and 1) 'r)' am a Dated: 4 ( 2. ~( 02- By'(J) . Paul Bradford Orr, Esquire 50 East High Street Carlisle PA 17013 O'm: w , (") c: <'''" c; ii5 n1n.' -::s- - ~'-'! .r-._ ~",_, 71 (/) ;~"~ ~~.'. ~~~~. =:;J -, '""""'l ""'-'''''7 / ,l, <:) N o -'1 ,.. i~ -< I c...; !'iiJ] ~'~? ''::'(.,) -:':-1: '::- -n ',c:;F!~~ ,~ ",J "J =< - - ,'\) co MAY 1 0200" .!> ROBERT HOLTER and LINDA HOLTER, Plaintiffs V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-1004 CIVIL TERM CHRISTINA HOLTER, : CIVIL ACTION - LAW WAYNE EUGENE JEWELL and: PAMELA DALE JEWELL, : VISIT A TION Defendants ORDER OF COURT AND NOW, this '-r.}.. day of ~ ' 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The Order of Court dated May 27, 1987 is hereby vacated. 2. The Mother, Christina Holter, shall have sole legal and physical custody of William Alexander Holter, born March 23, 1987 and Derek Austin Holter, born March 26, 1990. 3. Mother, children and paternal Grandparents shall submit themselves to counselor, Richard Dracha for exploration and determination of whether it would be in the children's best interest to have visitation with paternal Grandparents. Mother, for herself and on behalf of the children and paternal Grandparents shall sign releases for Mr. Dracha to share information with the parties and their respective attorneys. Paternal Grandparents shall pay the expenses associated with their meetings with Mr. Dracha and Mother shall pay the expenses associated with her meetings and the children's meetings with Mr. Dracha. 4. 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. Any party may contact the Conciliator for another Conciliation Conference. J. cc: Johnna J. Kopecky, Esquire, Counsel for paternal Grandparents Paul Bradford Orr, Esquire, Counsel for Mother, maternal Grandparents ~~ !f.I"I.O~ CJ.. ROBERT HOLTER and LINDA HOLTER, Plaintiffs V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2002-1004 CIVIL TERM CHRISTINA HOLTER, : CIVIL ACTION - LAW WAYNE EUGENE JEWELL and: PAMELA DALE JEWELL, : VISITATION Defendants PRIOR JUDGE: Edgar B. Bayley, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF William Alexander Holter Derek Austin Holter March 23, 1987 March 26, 1990 Mother Mother 2. A Conciliation Conference was held in this matter on May 8, 2002 with the following individuals in attendance: The paternal Grandparents, Robert Holter and Linda Holter, with their counsel, Johnna 1. Kopecky, Esquire; the Mother, Christina Holter and maternal Grandparents, Wayne Eugene Jewell and Pamela Dale Jewell were not present but represented by their counsel, Paul Bradford Orr, Esquire who was present. 3. There are two prior Orders of Court. The Order dated May 27,1987 placed legal and physical custody of William Alexander Holter with the maternal Grandparents. The Order of April I, 2002 sustained Mother's preliminary objections objecting to the exclusion of maternal Grandparents from the litigation. 4. The parties agreed to the entry of an Order in the form as attached. 5" - g- -0 ;v Date J, cqu me M. Verney, Esquire Custody Conciliator (") ~ :-0 OJ rrinc., 2::::1:: '2'C' ~IIE:: ~O ~8 J>c;:: < =< .- '*' t::- Co R; :z:: :l::>o -< ,~ \",j -" <...; ,~i : .~.:C; ,....-.. )'/,'::J .", ,I .~~) ,~:..I:-. -ri- ,cj?') C5fn --, ;t.: ;;;0 -< .." -"'1" -