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HomeMy WebLinkAbout06-3363Jay R. Braderman, Esquire Attorney I.D. No.: 07047 126 Locust Street P.O. Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 Attorney for Plaintiff LAURA CRUM, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. -33L3 CIVIL ACTION -LAW ANTHONY MOFFA, CUSTODY Defendant. : COMPLAINT FOR CUSTODY AND NOW, comes the above-named Plaintiff, Laura Crum, by and through her attorney, Jay R. Braderman, Esquire and represents as follows: 1. The Plaintiff is Laura Crum, an adult individual residing at 1105 Yverdon Drive, Apt. C-5, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. The Defendant is Anthony Moffa, an adult individual residing at 704 Wood Street, Mount Joy, Lancaster County, Pennsylvania, 17552. 3. Plaintiff seeks custody of the following child: Kaleb Moffa, presently residing at 1105 Yverdon Drive, Apt. C-5, Camp Hill, Cumberland County, Pennsylvania, 17110. The child is four months of age, having been born February 8, 2006. The child was born out of wedlock. The child is presently in the custody of his Mother, Laura Crum, who resides at 1105 Yverdon Drive, Apt. C-5, Camp Hill, Cumberland County, Pennsylvania, 17110. Since birth the child has resided with his Mother, Laura Crum, who resides atl 105 Yverdon Drive, Apt. C-5, Camp Hill, Cumberland County, Pennsylvania, 17110. The Mother of the child is Laura Crum, who resides atl 105 Yverdon Drive, Apt. C-5, Camp Hill, Cumberland County, Pennsylvania, 17110. She is single. The Father of the child is Anthony Moffa, currently residing at 704 Wood Street, Mount Joy, Lancaster County, Pennsylvania, 17552. He is single. 4. The relationship of Plaintiff to the child is that of Mother. The Plaintiff currently resides with her infant son Kaleb Moffa. 5. The relationship of Defendant to the child is that of Father. 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 in 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. 2 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. The Plaintiff has been the primary caregiver to the child since his birth; b. Defendant has repeatedly stated to Plaintiff that Plaintiff should never have given birth to the child; and, c. Defendant refuses to spend any meaningful time 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. WHEREFORE, Plaintiff requests the Court to grant her sole legal custody of the child and primary physical custody of the child with periods of partial physical custody with the Father of the child. Date: K?y ail an, Esquire tto a No.: 07047 126 Loc st Street P.O. Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 Attorney for Plaintiff 3 VERIFICATION I verify that the statements made in this pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unworn falsification to authorities. DATE: 14ut a ? I Aa Pni u LAURA CRUM (V c c ?J („r= ?? LAURA CRUM IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ANTHONY MOFFA DEFENDANT 06-3363 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Friday, June 16, 2006 , 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 MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Friday, August 04, 2006 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. 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/ Melissa P. GreevyEsq. f/ 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 j P7i q© oz? ,. a i3AI LAURA CRUM, IN THE COURT OF CO CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 06-3363 CIVIL TERM V. : CIVIL ACTION - LAW ANTHONY MOFFA, : IN CUSTODY Defendant ORDER OF COURT AND NOW, this day of September, 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. The parties, Laura Crum and Anthony Moffa, shall have shared legal custody of the minor child, Caleb Moffa, born February 8, 2006. 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 his health, education and religion. Pursuant to the terms of 23 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. 2. Physical Custody. Mother shall have primary physical custody subject to Father's rights of partial custody, which shall be arranged as follows: A. September 2, 2006 and September 9, 2006 from 9:00 a.m. until 7:00 p.m. September 16, 2006 and September 17, 2006 from 9:00 a.m. until 6:00 p.m. B. Commencing September 29, 2006, on alternating weekends, from Friday at 5:30 p.m. until Monday no later than 9:00 a.m. 3. Transportation. Father shall provide transportation incident to the custodial exchanges, with the exception of holidays. For holidays, the parent receiving custody shall provide transportation. 4. The child shall not be exposed to second-hand smoke in confined spaces. IRECEIVED sip ? ? zoas 5. Holidays. The attached holiday schedule shall supersede the regular schedule. NO. 06-3363 CIVIL TERM The parties may vary from the terms of this Order by their mutual agreement. However, in the absence of their mutual agreement, the terms of this Order shall control. BY THE COURT: J. Dist: Korey Leslie, Esquire, 40 E. Philadelphia Street, York, PA 17401 Jay R. Braderman, Esquire, P. O. Box 11489, Harrisburg, PA 17108-1489/ 7 j>(p IJ (I ., ? . ; c.. ,? ,_ ;J NO. 06-3363 HOLIDAYS AND TIMES EVEN ODD SPECIAL DAYS YEARS YEARS Easter Day From 6pm the evening before the Mother Father holiday to 6pm the day of the holiday Memorial Day From 6pm the evening before the Father Mother holiday to 6pm the day of the holiday Independence Day From 6pm the evening before the Mother Father holiday to 6pm the day of the holiday Labor Day From 6pm the evening before the Father Mother holiday to 6pm the day of the holiday (commencing in 2008) Thanksgiving From 9am to 6pm Thanksgiving Day Mother Father Christmas 1St Half From 9am on 12/24 to 3pm on 12/25 Mother Father Christmas 2nd Half From 3pm on 12/25 to 3pm on 12/26 Father Mother Mother's Day From 6pm the evening before the Mother Mother holiday to 6pm the day of the holiday Father's Day From 6pm the evening before the Father Father holiday to 6pm the day of the holiday :282423 LAURA CRUM, Plaintiff ??I?TL?'I? SEP 0 5 X006 IN THE COURT OF COM ? ? f}F-- CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-3363 CIVIL TERM V. ANTHONY MOFFA, Defendant CIVIL ACTION - LAW 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 Caleb Moffa February 8, 2006 CURRENTLY IN THE CUSTODY OF Mother IN CUSTODY 2. Mother filed a Complaint for Custody on June 13, 2006. A Custody Conciliation Conference was scheduled for August 4, 2006. Upon stipulation of counsel, the Conciliation was rescheduled for August 25, 2006. Present for the conference were: the Father, Anthony Moffa, and his counsel, J. Korey Leslie, Esquire; the Mother, Laura Crum, and her counsel, Jay R. Braderman, Esquire. 3 The parties reached an agreement in q_11-11 Date Order as attached. Melissa Peel Greevy, Esquire Custody Conciliator :282419 LAURA CRUM, Plaintiff/Petitioner V. § IN THE COURT OF COMMON PLEAS OF § CUMBERLAND COUNTY, PENNSYLVANIA § NO. 06-3363 CIVIL TERM § CIVIL ACTION- CUSTODY ANTHONY MOFFA, Defendant/Respondent PETITION FOR MODIFICATION OF PARTIAL CUSTODY OR VISITATION ORDER PURSUANT TO 23 Pa.C.S. 5310 AND NOW, comes the Plaintiff/Petitioner, Laura Crum, by her attorney, Tanner Law Offices, LLC, and represents as follows: Petitioner is the above named Plaintiff, Laura Crum, an adult individual currently residing at 117 Clapsaddle Road, Gettysburg, Adams County, Pennsylvania 17325. 2. 3. c);ti 2.461 4. ?0.00 f"J Tatnnett ,gyp a 2.3 9 4,94 t? u._ .v, C) C13 cv Respondent is the above named Defendant, Anthony Moffa, an adult individual currently residing at 20880 Croghan Pike, Orbisonia, Huntingdon County, Pennsylvania. The parties are the parents of one minor child, namely Kaleb Moffa, born February 8, 2006. During the past 5 years the child has resided with the following persons at the following addresses: Address Residing, With Dates T - 117 Clapsaddle Rd Mother 7/06 - Present Gettysburg, PA 17325 Uncle 1005 Yverdon Dr., Apt. C-5 Mother 2/06-7/06 Camp Hill, PA 17011 u 5. Petitioner respectfully represents that on September 6, 2006, an Order of Court was entered regarding custody of the parties' minor child, a copy of which is attached hereto as Exhibit "A". 6. Father has never abided by the terms of the September 6, 2006 Order of Court. 7. On February 8, 2008, on the child's second birthday, Father requested time with the parties' child. 8. Mother granted this request and Father regularly visited with the child for the next few months, transitioning from a few hours each weekend to an eventual overnight Saturday to Sunday schedule. 9. Mother also accommodated Father by providing the transportation for the child to visit with Father at Father's residence on several occasions. 10. After the "newness" of this regular time with their son wore off, however, Father then would be late for the exchanges, or would not show at all, leaving their child longingly waiting at the window for his Father to pick him up and Mother having to explain why his Father would not be coming. 11. Father made no attempts to see Kaleb after approximately Thanksgiving 2008. 12. The inconsistency resulted in Kaleb wetting the bed and becoming very aggressive at daycare and at home. 13. 'The pediatrician recommended that Kaleb receive a psychological evaluation to determine the cause of this behavioral change. Father, however, has still refused to sign the necessary consent forms to permit this evaluation, leaving Kaleb without the treatment his pediatrician recommenced. 14. After Thanksgiving 2008, Father made no contact or inquiries regarding Kaleb until May 28, 2009 when he sent Mother a message through Facebook and then had no further communication until October 2009. 15. Approximately one week ago, Father again made contact with Mother (5 months after the last contact and more than 1 year since he has seen Kaleb) and stated that his Father is a state police officer and if she does not provide Kaleb to him on Easter Sunday 2010, he would have his Father arrest her. 16. Mother seeks to modify the terms of the September 6, 2006 Order of Court because she believes that it is in Kaleb's best interest to do so. IT The best interests and permanent welfare of the child will be served by granting the relief requested. 18. ;Mother has no information concerning a custody proceeding regarding this child pending in a court of the Commonwealth of Pennsylvania. 19. 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. 20. There are no other persons who are known to have or claim a right to custody or visitation of the child to be given notice of the pendency of this action and the right to intervene. WHEREFORE, Petitioner requests that the Court modify the existing order for Custody to provide Mother with primary physical custody and Father limited contact with the child until he can demonstrate a willingness to participate in a regular schedule with the child. Respectfully submitted, ?? ?? l?,tA7iylpir Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 Attorney for Petitioner/Plaintiff TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements made herein may subject me to penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: U?Lbk? Laura K. Crum R ZE CEIVED SEP 0 20A6 LAURA CRUM, IN THE COURT OF CO CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 06-3363 CIVIL TERM V. CIVIL ACTION - LAW ANTHONY MOFFA, IN CUSTODY Defendant ORDER OF COURT AND NOW, this day of September, 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed -as follows: 1. The parties, Laura Crum and Anthony Moffa, shall have shared legal custody of the minor child, Caleb Moffa, born February 8, 2006. 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 his health, education and religion. Pursuant to the terms of 23 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. 2. Physical Custody. Mother shall have primary physical custody subject to Father's rights of partial custody, which shall be arranged as follows: A. September 2, 2006 and September 9, 2006 from 9:00 a.m. until 7:00 p.m. September 16, 2006 and September 17, 2006 from 9:00 a.m. until 6:00 p.m. B. Commencing September 29, 2006, on alternating weekends, from Friday at 5:30 p.m. until Monday no later than 9:00 a.m. 3. Transportation. Father shall provide transportation incident to the custodial exchanges, with the exception of holidays. For holidays, the parent receiving custody shall provide transportation. 4. The child shall not be exposed to second-hand smoke in confined spaces. 5. Holidays. The attached holiday schedule shall supersede the regular schedule. Exhibit "A" NO. 06-3363 CIVIL TERM The parties may vary from the terms of this Order by their mutual agreement. However, in the absence of their mutual agreement, the terms of this Order shall control. J. Dist: Korey Leslie, Esquire, 40 E. Philadelphia Street, York, PA 17401 Jay R. Braderman, Esquire, P. O. Box 11489, Harrisburg, PA 17108-1489 R."M ill, W! r?8?9&Aft pa f ?t0 NO. 06-3363 HOLIDAYS AND SPECIAL DAYS TIMES EVEN YEARS ODD YEARS Easter Day From 6pm the evening before the holiday to 6pm the day of the holiday Mother Father Memorial Day From 6pm the evening before the holiday to 6pm the day of the holiday Father Mother Independence Day From 6pm the evening before the holiday to 6pm the day of the holiday Mother Father Labor Day From 6pm the evening before the holiday to 6pm the day of the holiday Father (commencing in 2008) Mother Thanksgiving From gam to 6pm Thanksgiving Day Mother Father Christmas 18t Half From 9am on 12/24 to 3pm on 12/25 Mother Father Christmas 2"d Half From 3pm on 12/25 to 3pm on 12126 Father Mother Mother's Day From 6pm the evening before the holiday to 6pm the day of the holiday Mother Mother Father's Day From 6pm the evening before the holiday to 6pm the day of the holiday Father Father :282423 LAURA CRUM IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ANTHONY MOFFA 2006-3363 CIVIL ACTION LAW IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, _ -Wednesday, April 07, 2010 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 Thursday, April 29, 2010 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. 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. Verne Es _ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For 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. $. JO CfX-. r- C8P Mo?\eamberland County Bar Association C 32 South Bedford Street -to Pm%? Ta.Rm - Carlisle, Pennsylvania 17013 14• $• 10 ma„% ke k0 Telephone (717) 249-3166 y • g• o for ??aae?d n A- Vc C7 F.- f -' C "" -cE :1 :•:J CC) C; r?- c_7 MAY 0 7 2010 3 LAURA CRUM, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2006-3363 CIVIL ACTION - LAV~j ~ ~ p t_~ u~ ANTHONY MOFFA ~- ~ -n Defendant : IN CUSTODY ~ -`- `` Cl) -r; "~• "-- W - 7 f <~ ~-a ~` ' ~,~ ~ ORDER OF COURT =' ~ r - u, -c N AND NOW, this ~ day of r ~' ~l , 2010, upon consideration of the attached Custody ConciliatioK Report, it is ordered and directed as follows: 1. A Hearing is sched~d in Court Room No. `3 , of the Cumberland County Court House, on the ~ day of"~"~~.2s~, . a''~1•, 2010, at / ~ ~ ~~1~f o'clock, _. M., at which time testimony will be 1'ak For purposes of this Hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party, or each party, shall file with the Court and opposing counsel or party a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the Hearing date. 2. The prior Order of Court dated October 6, 2006 is hereby vacated. 3. Pending further Order of Court or agreement of the parties, the following shall remain in full force and effect. 4. Mother, Laura Crum, shall have sole legal custody of Kaleb Moffa, born February 8, 2006. Mother shall provide all important information, including but not limited to medical, religious, educational, to Father in a timely manner. 5. Mother shall have primary physical custody of the child. 6. Father shall have contact with the child in a therapeutic setting. 7. The parties shall cooperate with the scheduling of therapeutic family counseling between Father and child. Father shall be responsible for the cost of counseling. The location of the counseling may be no more than one hour from Mother's residence. ~- 8. The parties shall abide by any recommendations of the counselor regarding contact between Father and child. 9. 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. r"~.'' BY , ~ COURT, Edward E. Guido, J. cc~etha A. Tanner, Esquire, counsel for Mother Anthony Moffa, pro se 20880 Croghan Pike Orbisonia, PA 17243 s 13~rD ~. LAURA CRUM, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2006-3363 CIVIL ACTION -LAW ANTHONY MOFFA, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, 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: 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 Kaleb Moffa February 8, 2006 Mother 2. A Conciliation Conference was held May 6, 2010 with. the following individuals in attendance: The Mother, Laura Crum, with her counsel, Tabetha A. Tanner, Esquire, and the Father, Anthony Moffa, pro se. 3. The Honorable Edward E. Guido previously entered an Order of Court dated October 6, 2006 providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends. 4. Mother's position on custody is as follows: Mother seeks sole legal and primary physical custody, with Father having aphased-in period of physical custody starting with contact in a therapeutic setting. Mother requests sole legal custody because Father refused to consent to counseling for the child previously. Mother asserts that Father has not seen the child for 1'/z years. When Father did see the child, the child began aggressive behaviors and bedwetting. 5. Father's position on custody is as follows: Father seeks shared legal custody and periods of partial physical custody. He admits refusing to sign a consent for counseling, but only because he requested a copy of the recommendation and did not receive it. ~i 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and granting Mother sole legal custody and primary physical custody with Father having periods of contact with the child in a therapeutic setting. It is expected that the Hearing will require one-half day. ,~ - ~ -/ v ~(. ~ Date acq line M. Verney, F,squire Custody Conciliator '~ LAURA CRUM, IN THE COURT OF COMMON PLEA5 OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006-3363 CIVIL TERM ANTHONY MOFFA, CIVIL ACTION - LAW Defendant CUSTODY ORDER OF COURT AND NOW, this 29th day of July, 2010, after hearing, all prior custody Orders are vacated and replaced with the following: 1. Mother, Laura Crum, shall have sole legal custody of Kaleb Moffa, born February 8, 2006. Provided, however, that Mother shall keep Father apprised of all medical, religious and educational matters in a timely fashion. 2. Mother shall have primary physical custody of the Child. 3. Father shall participate in the individual counseling with Amy L. Hershey, L.S.W., until he successfully completes it. 4. The Child shall continue in counseling with Amy L. Hershey, L.S.W., and Father may visit with the Child in the therapeutic setting with said counselor as recommended by said counselor. 5. We will hold a further hearing on this matter on December 13, 2010, at 9:30 a.m., to determine the nature and extent of the parties' progress in counseling and to set a s partial custody schedule for Father. Father shall be responsible for the costs of the therapeutic counseling to the extent that it is not covered by insurance. By the Court, Edward E. Guido, J. vTabetha A. Tanner, Esquire Attorney for Plaintiff v Anthony Moffa 507 Mifflin Street Huntingdon, PA 16652 Defendant, Pro se srs pies r-1a . jcal 7~a4~iv a :t C ~: ~, ~ ;_ ~, ,:,: -- .~ ~~. ~ LAURA CRUM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006-3363 CIVIL TERM ANTHONY MOFFA, CIVIL ACTION - LAW Defendant CUSTODY ORDER OF COURT AND NOW, this 13th day of December, 2010, after hearing, it is hereby ordered and directed as follows: 1. Mother, Laura Crum, shall have sole legal custody of Kaleb Moffa, born February 8, 2006. Provided, however, that upon request from Father, Mother shall apprise him of all medical, religious and educational matters regarding the Child. 2. Mother shall have primary physical custody of the Child. 3. Absent further Order of this Court, Father is to have no contact with the Child except in a therapeutic setting with the Child's counselor and as recommended by the Child's counselor. 4. The Child shall continue in counseling with Amy L. Hershey, L.S.W., or such other counselor as Mother selects. By the Court, Edward E. Guido, J. ? Tabetha A. Tanner, Esquire Attorney for Plaintiff Anthony Moffa 507 Mifflin Street Huntingdon, PA 16652 / srs G p;e!5 kwe,. Itxd ?a ?13/Ill R1c .-) C -V3 rnco :z rn u,r- 5= r.s c? r c-? W NJ w co -s -gym ;oc:; c) i ?p =-Tj