Loading...
HomeMy WebLinkAbout02-1514BONNIE J. CRAMER, Plaintiff NICOLE J. LIVINGSTON and ANTHONY W. RICCO III, Defendants PA 17013. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : : IN CUSTODY · NO. ~ -- /~1~ / COMPLAINT FOR CUSTODY The Plaintiff is Bonnie J. Cramer, residing at 3139 Springs Road, Carlisle, 2. The Defendants are Nicole J. Livingston, who resides at 48 North East Street, Carlisle, PA 17013 and Anthony W. Ricco, III, who resides at 209 Snuff Ridge Road, New Salem, PA 15468-1141. 3. Plaintiff seeks custody of Jacob Ryan Cramer, born August 22, 1999. The child was bom out of wedlock. The child is presently in the custody of Bonnie J. Cramer, who resides at 3139 Springs Road, Carlisle, PA 17013. following addresses: Since birth, the child has resided with the following persons and at the Bonnie J. Cramer, Mark A. Cramer and Nicole J. Cramer (now Nicole J. Livingston) 3139 Springs Road Carlisle, PA 17013 Birth to November 23,2000 Bonnie J. Cramer and Mark A. Cramer 3139 Springs Road Carlisle, PA 17013 November 23, 2000 to the Present The mother of the child is Nicole J. Livingston, who currently resides at 48 North East Street, Carlisle, PA 17013. She is marded. The father of the child is Anthony W. Ricco, III, currently residing at 209 Snuff Ridge Road, New Salem, PA 15468-1141. He is married. 4. The relationship of Plaintiff to the child is that of maternal grandmother. The Plaintiff currently resides her son, Mark A. Cramer, and Jacob Ryan Cramer. 5. The relationship of Defendants to the child is that of natural mother and father. Defendant, Nicole J. Livingston, currently resides with her husband, Donald Livingston. Defendant, Anthony W. Ricco, III, currently resides his wife and daughter along with his parents, Anthony Ricco, II and Twila Ricco. 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. 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 dghts with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: Jacob. (a) Plaintiff can provide a more stable and nurturing environment for (b) Plaintiff will assure that Defendants have periods of partial custody of the child at times mutually agreed upon. 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. WHEREFORE, Plaintiff requests the court to grant custody of the child to her. ~andra L. Meilton, I~squ~re, ~32551 TUCKER ARENSBERG & SWARTZ 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 A'I-I'ORNEYS FOR PLAINTIFF VERIFICATION I, the undersigned, Bonnie J. Cramer, acknowledge that the facts stated in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to authorities. Bonnie J. Cra~r Dated: 48284.1 BONNIE J. CRAMER : PLAINTIFF V. NICOLE J. LIVINGSTON AND ANTHONY W. RICCO III DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-1514 CIVIL ACTION LAW IN CUSTODY AND NOW, Tuesday, April 09, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jaequeline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 25, 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 ant~y 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/ [acaueline M. Vernev. Esa. ~ 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 2 Liberty Avenue Carlisle, pennsylvania 17013 Telephone (717) 249-3166 BONNIE J. CRAMER, Plaintiff NICOLE J. LIVINGSTON and ANTHONY W. RlCCO III, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : iN CUSTODY : NO. 02-1514 AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF DAUPHIN ) AND NOW, this ~' n ~day of April, 2002, personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Gloria M. Rine, legal assistant to Sandra L. Meilton, who being duly sworn according to law, deposes and says that on April 16, 2002, she mailed a certified copy of a Complaint for Custody with attached scheduling Order and accompanying letter (copy of letter to Jacqueline Verney, Custody Conference Officer, rescheduling the conference) to Nicole Livingston, 48 North East Street, Carlisle, PA 17013, by certified mail no. 7099 3400 0016 3623 5866, return receipt requested, and the same was received on April 18, 2002 by Nicole Livingston, as indicated by the return receipt card which is attached hereto. In addition, on April 16, 2002, an additional certified copy of said pleading and additional copy of said letter to Ms. Verney was forwarded to Lindsay McClay, Esquire, as counsel for Defendant, Anthony W. Ri(}co, III. /~ Glori~ M. Rine Sworn to and subscribed before me this ,-~ day of April, 2002. l Notarial Seal (SEAL) Pauline Patti Thomas, Not0,w~. Harrlsburg, Dauphin rjr c;.r, rnmlssion Expires Postage Certified Fee Return Receipt Fee (En~tomement Required) Restricted Delivery Fee (Engo-ssment Requireq) T~, Po~e. &,... $ 4/16/02 Postmark Hem s.Nicole Livinqston SENDER: · delivered. 3. Adicle A~ressed to: Mrs. Nicole Livingston CART.ZmLE PA 17013 5. Received By: (Print Name) --~ PS For~ 3811,~enl~er 1994 I also wish to receive the following services (for an extra fee): 1. [] Addressee's Address 2. [] Restricted Delivery Consult postmaster for fee. 4a. Article Number 7099 3400 0016 3623 586E 4b. Service Type [] Registered ::~ Certified D Express Mail [] Insured [] Return Receipt for Merchandise [] COD 7' Date °' D~y~e~ ~c 8, Addressee's Address (Only if requested and fee is paid) ~(~5gs-~-~-o~9 Domestic Return Receipt BONNIE J. CRAMER, Plaintiff NICOLE J. LIVINGSTON and ANTHONY W. RICCO, III, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-1514 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this ,ch-- day of r~ ~ ,2002, upon consideration of the attache~-~ustody Conciliation Re~ort, it is ordered and directed as follows: 1. The Grandmother, Bonnie J. Cramer, the Mother, Nicole J. Livingston and the Father, Anthony W. Ricco, III, shall have shared legal custody of Jacob Ryan Cramer, bom August 22, 1999. 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 his health, education and religion. o child: Grandmother shall have primary physical custody of the child. Mother shall have the following periods of partial physical custody of the A. For the months of May and June, 2002: 1. Beginning May 8, 2002, every Wednesday from 4:00 p.m. to 7:00 p.m. 2. Beginning May 11, 2002, alternating Saturdays from 9:00 a.m. to 5:00 p.m. 3. Beginning May 17, 2002, alternating Fridays from 5:00 p.m. to 8:00 p.m. Bo For the months of July and August, 2002: 1. Every Wednesday from 4:00 p.m. to 7:00 p.m. 2. Continue the alternating Fridays from 5:00 p.m. to 8:00 p.m. 3. Alternating Saturdays and Sundays from 9:00 a.m. to 5:00 p.m. For the month of September, 2002: 1. Every Wednesday from 4:00 p.m. to 7:00 p.m. 2. Continue the alternating Fridays from 5:00 p.m. to 8:00 p.m. 3. Alternating weekends from Saturday at 9:00 a.m. to Sunday at 6:00 p.m. D. For the month of October, 2002: 1. Every Wednesday from 4:00 p.m. to 7:00 p.m. 2. Continue alternating Fridays from 5:00 p.m. to 8:00 p.m. 3. Alternating weekends from Friday at 6:00 p.m. to Sunday at 6:00 p.m. E. Mother shall begin a parenting class and provide proof thereof and consistent attendance to Grandmother prior to overnights being permitted. Fo An additional prerequisite for overnights to begin is Mother's exercise of at least 85% of the partial custody listed heretofore, emergencies of the parties notwithstanding. Notice of emergency or conflict in the schedule shall be provided 24 hours in advance if possible. 4. Father shall have the following periods of partial physical custody of the child: A. For the months of May and June, 2002: 1. Beginning May 19, 2002, alternating Sundays from 2:30 p.m. to 6:30 p.m. in the Carlisle area. For the first period of partial physical custody, Father shall spend the first one-hour with the child in Grandmother's presence. B. For the months of July and August, 2002: 1. Alternating Sundays from 10:30 a.m. to 6:30 p.m. in the Carlisle area. C. For the month of September, 2002: 1. For the first period of partial custody in the month, continuing the alternating Sunday from 10:30 a.m. to 6:30 p.m. in the Carlisle area. 2. For the next alternating weekend, Father shall have an overnight with the child at Father's home from Saturday at 4:00 p.m. to Sunday at 11:00 a.m. Grandmother shall transport the child for this period of custody. D. For the month of October, 2002: 1. For the first period of partial custody in the month, continuing the alternating weekend schedule, Father shall have an overnight with the child at Father's home from Saturday at 12:00 noon to Sunday at 4:00 p.m. Grandmother shall transport the child for this period of custody. 2. For the next alternating weekend, Father shall have an overnight with the child at Father's home from Saturday at 12:00 noon to Sunday at 6:00 p.m. Father shall be responsible for all transportation for this period of partial custody. E. A prerequisite for overnights to begin is Father's exercise of at least 85% of the partial custody listed heretofore, emergencies of the parties notwithstanding. Notice of emergency or conflict in the schedule shall be provided 24 hours in advance if possible. 5. 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. Another Conciliation Conference is scheduled for November 8, 2002 at 10:30 a.m. BY THE COURT, cc: Sandra L. Meilton, Esquire, Counsel for Grandmother David Lopez, Esquire, MidPenn Legal Services, Counsel for Mother Lindsay Gingrich Maclay, Esquire, Counsel for Father BONNIE J. CRAMER, Plaintiff NICOLE J. LININGSTON and ANTHONY W. RICCO, III, Defendants PRIOR JUDGE: None : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2002-1514 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCII,IATION 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 Jacob Ryan Cramer DATE OF BIRTH August 22, 1999 CURRENTLY IN CUSTODY OF Grandmother 2. A Conciliation Conference was held in this matter on May 6, 2002, with the following individuals in attendance: The Grandmother, Bonnie J. Cramer, with her counsel, Sandra L. Meilton, Esquire, the Mother, Nicole J. Livingston, with her counsel, David Lopez, Esquire of MidPenn Legal Services and the Father, Anthony W. Ricco, III, with his counsel, Lindsay Gingrich Maclay, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date ~Jacqffe. lin_e M...V. emey, Esquire Custody Conciliator NOV 1 8 ZOO2 BONNIE J. CRAMER, Plaintiff V. NICOLE J. LIVINGSTON and ANTHONY W. RICCO, III, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : NO. 2002-1514 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this I q ~' day of /Vo-n.4~ ,2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated May 8, 2002 is hereby vacated and replaced with the following. 2. The Grandmother, Bonnie J. Cramer, the Mother, Nicole J. Livingston and the Father, Anthony W. Ricco, III, shall have shared legal custody of Jacob Ryan Cramer, born August 22, 1999. 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 his health, education and religion. child: Grandmother shall have primary physical custody of the child. Mother shall have the following periods of partial physical custody of the A. Beginning the week of November 11, 2002: 1. Every Wednesday from 4:00 p.m. to 7:00 p.m. However, if Mother's ParentWorks classes require the child to be present, then Mother's Wednesday shall be replaced with one day every week for three hours when the ParentWorks class is scheduled. 2. Alternating Fridays from 5:00 p.m. to 8:00 p.m. 3. Alternating Saturdays and Sundays from 9:00 a.m. to 5:00 p.m. B. Once Mother completes the first three sessions of the ParentsWorks program, then: 1. Every Wednesday from 4:00 p.m. to 7:00 p.m. However if Mother's ParentWorks classes require the child to be present, then Mother's Wednesday shall be replaced with one day every week for three hours when the ParentWorks class is scheduled. 2. Continue the alternating Fridays from 5:00 p.m. to 8:00 p.m. 3. Alternating weekends from Saturday at 9:00 a.m. to Sunday at 6:00 p.m. 4. This schedule shall continue for four calendar weeks or upon completion of the ParentWorks program, whichever is later. C. Once the ParentWorks program is successfully completed or four calendar weeks of having Paragraph 4B above in effect, whichever is later, then: 1. Every Wednesday from 4:00 p.m. to 7:00 p.m. 2. Continue alternating Fridays from 5:00 p.m. to 8:00 p.m. 3. Alternating weekends from Friday at 6:00 p.m. to Sunday at 6:00 p.m., except that said alternating weekends shall also be alternated with Grandmother. On Grandmother's alternating weekend, Mother shall be entitled to partial physical custody from Monday at 6:00 p.m. to Wednesday at 6:00 p.m. During M ' other s Monday to Wednesday periods, Mother shall use the same caregivers presently used for the child, if necessary. In the event Mother works an overnight shift, the child shall be returned to Grandmother for the night. 4. This schedule shall continue until the next Conciliation Conference. D. Mother shall begin a parenting class the week of November 11, 2002 and provide proof of attendance and completion thereof. E. Notice of emergency or conflict in the schedule shall be provided 24 hours in advance if possible. F. No unlicensed drivers shall transport the child. 4. Father shall have the following periods of partial physical custody of the child: A. Beginning November 8, 2002 and continuing through the month of December: Alternating weekends from Friday at 7:00 p.m. (pickup at Bedford McDonald's) to Sunday at 7:00 p.m. Father shall return the child to Grandmother. B. Beginning the first weekend in January 2003 and continuing until the next Conciliation conference: Friday at 7:00 p.m. icku McDonald's) to Monday at 5 00 m Fathe (p p at Bedford Grandmother. : P. . r shall return the child to C. Notice of emergency or conflict in the schedule shall be provided 24 hours in advance if possible. D. No unlicensed drivers shall transport the child. 5. The Thanksgiving holiday shall be shared as follows: Grandmother shall have physical custody of the child until 12:00 noon on Thanksgiving Day. Father shall have physical custody of the child from 12:00 noon on Thanksgiving Day to Friday at 5:00 p.m. when he will deliver the child to Mother. Mother shall have physical custody of the child on the Friday after Thanksgiving Day from 5:00 p.m. to 8:00 p.m. 6. The Christmas holiday shall be shared by the parties. Father shall have the child from December 21, 2002 at 12:00 noon (instead of his normal weekend pickup on December 20), pick up at Bedford McDonald's, to December 24 at 3:00 p.m. Father shall deliver the child to Grandmother on December 24 at 3:00 p.m. Grandmother shall have the child from Christmas Eve at 3:00 p.m. to Christmas Day at 5:00 p.m. Mother shall have the child from Christmas Day at 5:00 p.m. to December 26 at 5:00 p.m. 7. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for March 14, 2003 at 10:30 a.m. BY THE COURT, cc: Sandra L. Meilton, Esquire, Counsel for David Lopez, Esquire, MidPenn Legal Services, Counsel for Mother Lindsay Gingrich Maclay, Esquire, Counsel for Father BONNIE j. CRAMER, Plaintiff NICOLE J. LININGSTON and ANTHONY W. RICCO, III, Defendants PR/OR JUDGE: Kevin A. Hess, J. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 2002-1514 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: I. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Jacob Ryan Cramer DATE OF BIRTH August 22, 1999 CURRENTLY IN CUSTODY OF Grandmother 2. A Conciliation Conference was held in this matter on November 8, 2002, with the following individuals in attendance: The Grandmother, Bonnie J. Cramer, with her counsel, Sandra L. Meilton, Esquire, the Mother, Nicole J. Livingston, with her counsel, David Lopez, Esquire of MidPenn Legal Services and the Father, Anthony W. Ricco, III, with his counsel, Lindsay Gingrich Maclay, Esquire. 3. A prior Order of Court was entered by the Honorable Kevin A. Hess dated May 8, 2002, providing for shared legal custody, primary physical custody with Grandmother and the parents having phased in periods of physical custody. 4. The parties agreed to the entry of an Order in the form as attached. Date~------~ custody Conciliator BONNIE J. CRAMER, Plaintiff NICOLE J. LIVINGSTON and ANTHONY W. RICCO, III, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-1514 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this / ~' ' day of tm a~ th ., 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order dated November 14, 2003 is hereby vacated. 2. The Grandmother, Bonnie J. Cramer, the Mother, Nicole J. Livingston and the Father, Anthony W. Ricco, III, shall have shared legal custody of Jacob Ryan Cramer, born August 22, 1999. 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 his health, education and religion. In this regard the parties agree that the Child should undergo an MRI and a speech evaluation. If possible, the speech evaluation should be scheduled by Grandmother for a Monday. Grandmother shall provide a copy of the MRI report to the parents as soon as practicable after she receives it. The parents shall be notified of the follow-up doctor's appointment to read the MRI and this too should be scheduled for a Monday if possible. 3. Grandmother shall have primary physical custody of the child. child: Mother shall have the following periods of partial physical custody of the Ao Every Wednesday from 4:00 p.m. to 7:00 p.m. Alternating Fridays from 5:00 p.m. to 8:00 p.m. Alternating weekends from Friday at 6:00 p.m. to Sunday at 6:00 p.m., except that said alternating weekends shall also alternate with Grandmother. On Grandmother's alternating weekend, Mother shall be entitled to partial physical custody from Monday at 6:00 p.m. to Wednesday at 6:00 p.m. During Mother's Monday to Wednesday periods, Mother shall use the same caregivers presently used for the Child, if necessary. In the event Mother works an overnight shift, the Child shall be returned to Grandmother for the night. D. One uninterrupted week in the summer, provided 30 days prior written notice is given. Said week shall coincide with Mother's existing custodial periods. E. Such other times as the parties agree. F. Makeup time shall be provided to Mother in the event Mother misses time with the Child due to the Child's illness or inclement weather. child: Father shall have the following periods of partial physical custody of the A. Beginning March 15, 2003 from Saturday at 12:00 noon (Pickup at Bedford McDonald's) to Monday at 7:00 p.m.. when Father shall retum the Child to Grandmother's home. B. One uninterrupted week in the summer, provided 30 days prior written notice is given. Said week shall coincide with Father's existing custodial periods. C. Such other times as the parties agree. D. Makeup time shall be provided to Father in the event Father misses time with the Child due to the Child's illness or inclement weather. 6. Notice of emergency or conflict in the schedule shall be provided 24 hours in advance if possible. 7. No unlicensed drivers shall transport the Child. 8. The parties shall cooperate with a custody evaluation performed by Georgi Anderson. Grandmother agrees to be responsible for 50% of the cost of the evaluation and the parents agree to be responsible for 25% each of the evaluation. 9. 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 request another Conciliation Conference once the custody evaluation is completed. BY THE COURT, cc: Sandra L. Meilton, Esquire, Counsel for Grand~other David Lopez, Esquire, Counsel for Mother Lindsay Gingrich Maclay, Esquire, Counsel for Father BONNIE J. CRAMER, Plaintiff NICOLE J. LININGSTON and ANTHONY W. RICCO, III, Defendants PRIOR JUDGE: Kevin A. Hess, J. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 2002-1514 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: NAME Jacob Ryan Cramer DATE OF BIRTH August 22, 1999 CURRENTLY IN CUSTODY OF Grandmother 2. A Conciliation Conference was held in this matter on March 14, 2003, with the following individuals in attendance: The Grandmother, Bonnie J. Cramer, with her counsel, Sandra L. Meilton, Esquire, the Mother, Nicole J. Livingston, with her counsel, David Lopez, Esquire and the Father, Anthony W. Ricco, III, with his counsel, Lindsay Gingrich Maclay, Esquire. 3. The parties agreed to the emry of an Order in the form as attached. Date ~flac~eline M. Vemey, 'Esquire Custody Conciliator