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HomeMy WebLinkAbout01-5371ROBERTA M. KLEIN, PLAINTIFF MICHAEL SQUILLARIO, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 53'71 C ;,t l CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY Name FRANCESCA SQUILLARIO ("Franki") o 5. following addresses: Persons Roberta M. Klein, Plaintiff 1. Plaintiff is ROBERTA M. KLEiN, residing at 4830 Brian Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is MICHAEL SQUILLARIO, residing at 1929 Munster Road, Cambria County, Portage, Pennsylvania. 3. Plaintiff seeks custody of the following child: Present Residence Age 4830 Brian Road 10 years Mechanicsburg, PA 17055 bom 6/01/91 The child was bom out of wedlock. The child is presently in the custody of Plaintiff. During the past five (5) years, the child has resided with the following persons and at the Roberta M. Klein, Plaintiff Robert Klein Carol Klein Addresses 4830 Brian Road Mechanicsburg, PA 403 Lamp Post Lane Camp Hill, PA Dates April 1999 to Present May 1992 to April 1999. 6. The mother of the child is Roberta M. Klein. Mother was never married to the father of the child, Michael Squillario. 7. The relationship of Plaintiff to the child is that of mother. Plaintiff currently resides with the following persons: None. 8. The relationship of Defendant to the child is that of father. Defendant currently resides with the following persons: Unknown. 9. 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. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 10. The best interests and permanent welfare of the child will be served by granting the relief requested because: A. B. C. D. E. Plaintiffis a fit parent. The child has expressed a preference to be in the custody of Plaintiff. The child does not see Defendant as a source of love and affection. Plaintiff believes that Defendant's recent behavior is erratic and unstable. Placing custody with Plaintiff will provide continuity, stability and certainty to the child's life. 11. 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. WHEREFORE, Plaintiffrequests this Court to grant legal and physical custody of the child to Plaimiff, Roberta M. Klein. Date: Respectfully submitted, SMIGEL, ANDERSON & SACKS By: Le~Rc~ Sm~/el,' Esquire ID #09617 Ann V. Levin, Esquire ID #70259 2917 North Front Street Harrisburg, PA 17110-1260 (717) 234-2401 Attorneys for Plaintiff VERIFICATION I, Roberta Klein, verify that the statements contained in the foregoing Complaint are tree and correct to the best of my knowledge, information and beliefi I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date: R6~,kta Klein fl II I I I I 2 I m ROBERTA M. KLEIN, PLAINTIFF MICHAEL SQUILLARIO, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY ORDER ~/[¢4 }o ~e--, [oc~ 2001, upon consideration of AND NOW, this I day of 5¢ , Plaintiffs Emergency Petition to Confirm Custody, it is hereby ordered that sole physical and legal custody of the minor child, FRANCESCA SQUILLARIO, whose date of birth is June 1, 1991, is confirmed in Plaintiff. This Order shall remain in effect until further Order of Court. Further, Defendant shall have periods of visitation as the.~arties ar~_able to agree. It is further ordered that under no circumstances shall ~ remove the child from Cumberland,~ounty, Pennsylvania. c~.,~ ]~ ~c..~ t;c~ ~,ac Co-~vt'Jz-¢°-D' A.I.N~O0 . q ROBERTA M. KLEIN, PLAINTIFF MICHAEL SQUILLARIO, DEFENDANT : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. Ol~~.'5-.°)'e'/J dt~t[I : CIVIL ACTION - CUSTODY EMERGENCY PETITION TO CONFIRM CUSTODY 1. Plaintiff is ROBERTA M. KLEIN, residing at 4830 Brian Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is MICHAEL SQUILLARIO, residing at 1929 Munster Road, Cambria County, Portage, Pennsylvania. 3. The minor child who is the subject of this Petition is FRANCESCA ("Franki") SQUILLARIO. Her date of birth is June 1, 1991. 4. The Defendant has never resided nor exercised any physical or legal custody rights with the child during the past nine years. 5. Physical custody and care of the child has been with Plaintiff. Except for a one week visitation in the year 2000 and a ten day visitation in the year 2001, the child has had no other extended visitation with Defendant. 6. On September 11, 2001, in the early morning hours, at approximately 2:00 a.m., Defendant arrived at Plaintiff' s residence. 7. Later on September 11, 2001, Defendant also appeared at the child's school and attempted to remove her without Plaintiff's permission or knowledge. 8. At approximately 11:00 p.m. on September 1 l, 2001, after taking the child to dinner, Defendant returned to Plaintiff's residence. Due to his behavior, he was asked to leave. Defendant responded that in order to have him leave, Plaintiffwould have to call 911. When Plaintiff used the phone to call for assistance, Defendant left. However, Defendant indicated that he would be back on Monday, September 17, 2001, at which time he intended to remove the child without Plaintiff's consent. 9. Plaintiff is in fear for the safety of the child if she is removed from the jurisdiction by Defendant. Defendant has resided in Wyoming which is the place where he has taken the child during his only extended visitation in 2001. 10. The child's school principal at Sporting Hill Elementary, has indicated to Plaintiff that should Defendant come to remove the child they would not be able to prevent him from doing so without a Court Order confirming custody in Plaintiff. 11. Plaintiff is afraid that Defendant will take the child and leave the area. 12. Plaintiff believes that Defendant's recent behavior is erratic and unstable. 13. Plaintiffhas filed a Complaint for Custody with the above court of even date with the filing of this Petition. 14. Plaintiff is able to provide a stable and safe environment for her child. If custody of the child is confirmed in her, Plaintiff will ensure that Defendant will continue to receive appropriate periods of visitation. WHEREFORE, it is respectfully requested that this Court enter an Order confirming physical and legal custody of the minor child in Plaintiff. Date: Respectfully submitted, SMIGEL, ANDERSON & SACKS Ann V. Levin, Esquire ID #70259 2917 North Front Street Harrisburg, PA 17110-1260 (717) 234-2401 Attorneys for Plaintiff VERIFICATION I, Roberta Klein, verify that the statements contained in the foregoing Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: ROBERTA M. KLEIN PLAINTIFF V. MICHAEL SQUILLARIO DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-5371 CIVIL ACTION LAW 1N CUSTODY AND NOW, Tuesday, September 18, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Tuesday, October 23, 2001 at 9:15 a.m. 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/ Me!issa P. Greevy. 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 heating 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 ATi'ORNEY 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 VINVA]A~NN3~t AJ_NNO0 L'I:OINI] O~ct3S 10 ROBERTA M. KLEIN, Plaintiff MICHAEL SQUILLARIO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 01-5371 CIVIL CIVIL ACTION - CUSTODY DEFENDANT'S RESPONSE TO EMERGENCY PETITION TO CONFIRM CUSTODY AND REQUEST FOR A PROMPT INTERMEDIATE HEARING 2. 3. 4. Admitted. Admitted. Admitted. Denied. It is specifically denied that Defendant has never exercised any physical or legal custodial rights with the child during the past nine years. Specifically, the parties had made arrangements for Defendant to exercise custodial periods of the minor child when he was scheduled off of work. Defendant has had regular and continuous contact with his daughter. This a blatantly false allegation for the sole purpose of seeking an emergency order to confirm custody. 5. Admitted in part and denied in part. It is admitted that Plaintiff has exemised primary physical custody of the child since her birth. It is specifically denied that Defendant's partial custody periods have been limited to those outlined in this averment. 6. Denied as stated. It is admitted that Defendant appeared at Plaintiff's home. However, it had been the parties practice to have the Defendant stay at Plaintiff's home while -1- exercising his partial physical custody. 7. After reasonable investigation, Defendant is without knowledge of this averment and strict proof thereof is required. 8. Denied. This averment is directly contradictory to the averment contained in paragraph 6. By way of further answer, Defendant has never indicated an intent to remove the child without Plaintiff's consent. Monday, September 17, was a previously scheduled custodial period of time based on Defendant's schedule. By way of further answer, Plaintiff has elected to unilaterally prohibit Defendant's contact with the minor child. 9. Denied. Plaintiff resides in Cambria County and has never expressed an intention to remove the child from Pennsylvania. 10. Denied after reasonable investigation. Defendant is without knowledge of this averment and strict proof thereof is required. 11. Denied after reasonable investigation. Defendant is without knowledge of this averment and strict proof thereof is required. 12. It is denied that Defendant's behavior has been erratic or unstable. Defendant is without knowledge of this averment and strict proof thereof is required. By way of further answer, Plaintiff has decided to unilaterally restrict Defendant's access to his daughter. Further, she utilized the Court to confirm sole legal and physical custody when the status quo permitted for partial physical custody with Defendant. 13. Admitted. 14. Denied after reasonable investigation. Defendant is without knowledge of this averment and strict proof thereof is required. By way of further answer, Plaintiff has ensured that -2- Defendant has not seen his daughter and/or talked to her on the telephone. Her behavior in restricting his access to Defendant's daughter prior to filing this Petition has continued. WHEREFORE, it is respectfully requested that this Court revoke its Order dated September 14, 2001 and provide Defendant with shared legal partial physical custody. In the alternative, Defendant requests an immediate hearing with the Court to address this Order. Respectfully submitted, Reager & Adler, PC Ddt~ra Den~&9_~ Cantor, Esquire I.D. #66378 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 Attorney for Defendant -3- VERIFICATION I, Michael Squillario, hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom verification to authorities. DATE: lqfic6ael Squillafio~) - CERTIFICATE OF SERVICE I, Debra Denison Cantor, Esquire, Attorney for Defendant, Michael Squillario, do hereby certify that this date I served the foregoing DEFENDANT'S RESPONSE TO EMERGENCY PETITION TO CONFIRM CUSTODY AND REQUEST FOR A PROMPT INTERMEDIATE HEARING by depositing a tree and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: LeRoy Smigel, Esquire Smigel, Anderson & Sacks, LLP 2917 North Front Street Harrisburg, PA 17110-1260 Date: ]e~b ~Esquire I.D. #66378 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 DEC 0 ? ~001 L~ ROBERTA M. KLEIN, VS. MICHAEL SQUILLARIO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5371 : : CIVIL ACTION - LAW Defendant : CUSTODY Oler, J.- AND NOW, this [ i~' day of December, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. The Mother, Roberta M. Klein, shall have primary physical custody of the minor Child, Francesca Squillario, born June 1, 1991. Father's custodial schedule will rotate over a three week plan: During week one Father shall have custody on Friday from the time of school dismissal until 9:00 p.m. During week two Father shall have custody from Wednesday from the time of school dismissal until 9:00 p.m. During week three Father shall have custody from Saturday at 8:00 a.m. until Sunday at 8:00 p.m. 2. The above-described schedule commences with Father's period of Friday custody on November 30, 2001. 3. Father will provide private sleeping arrangements for the Child during any overnight periods of custody. 4. Father will endeavor to adapt to the Child's weekend schedule with his custodial schedule in such a way to accommodate the weekend activities. In the event that the Child would prefer to sleep at Mother's home during Father's custodial weekends, it shall be permissible for Father to make those arrangements with Mother. 5. Trans0ortation. Father shall provide all transportation incident to his periods of custody on Wednesdays and Fridays. On those weekends when Father is exemising weekend custody at his home, Mother shall meet him half-way at Exit 13 on Saturday morning at 8:00 a.m. In the event that there are no sports or extracurricular activities for the Child on Sunday of Father's custodial weekend, Mother shall meet Father at Exit 13 for the exchange of custody. No. 01-5371 - Civil Term 6. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Neither party shall make derogatory comments about the other party in the presence of the child. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. Both parents shall establish a no-conflict zone for their Child so that any discussion of parenting issues shall not occur in the presence or earshot of the child. 7. The non-custodial parent shall be entitled to reasonable telephone contact with the Child. Unless otherwise agreed, Father may have weekly telephone contact with the Child on Sundays at such time as the parties shall agree. 8. Summer Vacation. Each party is entitled to one week, to be defined as one seven- day block of time, or summer vacation each year. The parties shall provide with written notice of the dates of their planned vacation by January 30th of each year. In the event that both parties have selected the same week for vacation, the party first providing written notice to the other party shall have choice of the vacation period. 9. Holidays. Christmas. For Christmas 2001, Father shall have custody from 2:00 p.m. Christmas Day until December 30th at Noon. However, Father shall be entitled to visit with the Child at Mother's home on Christmas Day from 8:30 a.m. until 2:00 p.m. Additionally, Father shall be entitled to have a period of custody on Christmas Eve for the purpose of attending early Mass. In 2002 and subsequent years, Christmas shall be arranged on an AJB schedule. Segment A shall be from December 24t~ until December 28th. Segment B shall be from December 28th until January 1st. In 2002 and subsequent even-numbered years, Father shall have Segment A and Mother shall have Segment B. In 2003 and subsequent odd-numbered years, Mother shall have Segment A and Father shall have Segment B. The parties shall alternate the following holidays: Easter, Memorial Day, Independence Day, Labor Day and Thanksgiving. The alternating schedule shall commence in 2002 with Father having custody for Easter. 10. The Custody Conciliation Conference shall reconvene on Monday, March 4, 2002, at 11:00 a.m., at the office of the Custody Conciliator, Melissa Peel Greevy, Esquire, 214 Senate Avenue, Suite 105, Camp Hill, PA 17011. At that time, the parties No. 01-537'1 - Civil Term shall have an opportunity to review the Custody Order as it exists. This agreement was conditioned upon the Order being subject to review specifically with regard to the issues of Father's request for shared legal custody and three weeks of summer vacation time. Therefore, the parties shall be prepared at the next Custody Conciliation Conference to discuss these topics as well as the summer custodial schedule. 11. This Order is temporary in nature and may be modified by mutual agreement of the parties. BYTHECOURT, J/jWesley Ole,J~_.~ f - Dist: LeRoy Smigel, Esquire, 2917 N. Front Street, Harrisburg, PA 17110-1260 Debra Denison Cantor, Esquire, 2331 Market Street, Camp Hill, PA 17011 /.2./.~-o I ROBERTA M. KLEIN, VS. MICHAEL SQUILLARIO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5371 : : CIVIL ACTION - LAW Defendant : 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 Francesca Squillario June 1,1991 Mother 2. A Custody Conciliation Conference was held on November 27, 2001, with the following individuals in attendance: the Mother, Robert M. Klein, and her counsel, Le Roy Smigel, Esquire; the Father, Michael Squiliario, and his counsel, Debra Denison Cantor, Esquire. The parties reached an agreement in the form of an Order as attached. el~ peel Greevy, Esquire ~ Custody Conciliator ROBERTA M KLEIN, Plaintiff V. MICHAEL SQUILLARIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5371 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY OLER, J. ORDER OF COURT AND NOW, this ?~,~,~ day of (/~,.~ ,2002, upon consideration of the attached CustOdy Conciliation Summary RepOrt, it is hereby ordered and directed as follows: 1. The Mother, Roberta M. Klein and the Father, Michael Squillario, shall have shared legal custody of the minor child, Francesca Squillario, born June 1, 1991. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Shared legal custody contemplates that the parties will consult with each other regarding these decisions in order to reach an agreement regarding the child's best interest. In the e~ent that the parties cannot agree, Mother shall have the decision making responsibility subject to Father's right to seek review of her decision in the Court. 2. The Mother, Roberta M. Klein, shall have primary physical custody of the minor Child, Francesca Squillario, born June 1, 1991. Father's custodial schedule will rotate over a three week plan: During week one Father shall have custody on Friday from the time of school dismissal until 9:00 p.m. However during the summer school recess, Father's period of custody for Fridays under the subparagraph shall be from 9:00 a.m. to 9:00 p.m. Unless otherwise agreed, during week two, Father shall have custody from Tuesday at 9:00 a.m. until Wednesday at 9:00 NO. 01-5371 CIVIL TERM p.m. on the following dates in the summer 2002: June 11 and 12, 2002; July 23 and 24, 2002 and August 13 and 14, 2002. During the school year, Father shall have custody from Wednesday at the time school is dismissed until 9:00 p.m. During week three Father shall have custody from Saturday at 8:00 a.m. until Sunday 8:00 p.m. 3. The above-described schedule commences with Father's period of Friday custody on May 22, 2002. 4. Father will provide private sleeping arrangements for the Child during any overnight periods of custody. 5. Neither party will schedule activities to occur during the other parents period of custody without their expressed consent thereto. By agreement of the parties, Father's custodial time has been scheduled not to conflict with Mother's vacation or soccer camps. In the event that the Child would prefer to sleep at Mother's home during Father's custodial weekends, it shall be permissible for Father to make those arrangements with Mother. 6. ~. Father shall provide all transportation incident to his periods of custody on Wednesdays and Fridays. On those weekends when Father is exercising weekend custody at his home, Mother shall meet him half-way at Exit 13 on Saturday morning at 8:00 a.m. In the event that there are no sports or extracurricular activities for the Child on Sunday of Father's custodial weekend, Mother shall meet Father at Exit 13 for the exchange of custody. 7. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Neither party shall make derogatory comments about the other party in the presence of the Child. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. Both parents shall establish a no-conflict zone for their Child so that any discussion of parenting issues shall not occur in the presence or earshot of the Child. 8. The non-custodial parent shall be entitled to reasonable telephone contact with the Child. Unless otherwise agreed, Father may have weekly telephone contact with the Child on Sundays at such time as the parties shall agree. 9. ~dJ~Z~3~Q,tj~. Each party is entitled to two weeks, non-consecutive, to be defined as one seven-day block of time, or summer vacation each year. The parties NO. 01-5371 CIVIL TERM shall provide with written notice of the dates of their planned vacation by January 30th of each year. In the event that both parties have selected the same week for vacation, the party first providing written notice to the other party shall have choice of the vacation period. For summer 2002, Father shall have custody for his vacation July 1, 2002 through July 7, 2002. Mother shall choose the dates for her vacation by May 31, 2002. Following that time, by the agreement of the parties, Father may choose his second vacation week. In the event that Mother's vacation conflicts with Father's Tuesday/Wednesday scheduled periods of custody as detailed more specifically in Paragraph 2 above, Father will be entitled to compensatory time before school resumes on August 26, 2002. h i_G_bd_~. In 2002 and subsequent years, Christmas shall be arranged on an NB schedule. Segment A shall be from December 24 until December 28. Segment B shall be from December 28 until January 1. In 2002 and subsequent even- numbered years, Father shall have Segment A and Mother shall have Segment B. In 2003 and subsequent odd-numbered years, Mother shall have Segment A and Father shall have Segment B. B. The parties shall alternate the following holidays: Easter, Memorial Day, Independence Day, Labor Day and Thanksgiving. The alternating schedule shall commence in 2002 with Father having custody for Easter. 11. Father will advise Mother if he intends to take the Child to visit with her maternal grandparents during any of his periods of custody. 12. This Order is temporary in nature and may be modified by mutual agreement of the parties. Dist: ./['~R~oy Smigel, Esquire, 2917 N. Front Street, Harrisburg, PA 17110-1260 //Jo~nne H. Clough, Esquire, 2331 Market Street, Camp Hill, PA 17011 BY THE COURT: v/)~esley Ol~r, J--~,) MAY ~ 0 ?002 ~ ROBERTA M KLEIN, Plaintiff V. MICHAEL SQUILLARIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5371 CIVIL TERM 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: NAM_~__~E Francesca Squillario June 1,1991 CURRENTLY IN THE CUSTODY OF Mother 2. A Custody Conciliation Conference was held on May 14, 2002. Present for the conference were the Mother, Roberta M. Klein, and her counsel, LeRoy Smigel, Esquire; the Father, Michael Squillario, and his counsel, Joanne Clough, Esquire. 3~_.~The parties reached an agreement in t~an Order as attached. 'Date ( ' sa Peel Greevy, 'Esquire " Custody Conciliator :158382