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HomeMy WebLinkAbout06-3968JASON WHITE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, P NNSYLVANIA V. NO. 0 (o - 3 SANDRA B. WHITE, CIVIL ACTION - CUSTODY Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend agains the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE IMAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800-990-9108 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tom acci6n dentro de los pr6ximos veinte (20) dias despu6s de la notifrcaci6n de esta Demanda y Av iso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otroslderechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800-990-9108 Jordan D. Cunningham, Esquire PA I.D. No. 23144 CUNNINGHAM & CHERNICOFF, P.C. 2320 North Second Street Harrisburg, PA 17110 Telephone: (717) 238-6570 Facsimile: (717) 238-4809 Email: icunningham@cclawVc.com JASON WHITE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, P NNSYLVANIA V. NO. 06-396P SANDRA B. WHITE, CIVIL ACTION - CUSTODY Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Jason White, residing at 140 Westover Drive, New Cumberland, Cumberland County, Pennsylvania. 2. The Defendant is Sandra B. White, residing at 2202-A Cedar Run Drive Extended, Camp Hill, Cumberland County, Pennsylvania. 3. The Plaintiff seeks primary custody of the following child: NAME PRESENT RESIDENCE AGE Rebecca D. White 2202-A Cedar Run Drive Extended 7 Camp Hill, PA 17011 The child was not born out of wedlock. The parties, Plaintiff, Jason White, who resides at 140 Westover Drive, New Cumberland, Cumberland County, Pennsylvania, and Defendant, Sandra B. White, who resides at 2202-A Cedar Run Drive Extended, Camp Hill, Cumberland County, Pennsylvania, current share joint custody of the child. During the past five (5) years, the child has resided with the following persons and at the following addresses: ALL PERSONS ALL ADDRESSES ATES a. Jason R.; Jennifer L.; 140 Westover Dr. ugust Jacob R.; and Joey R. New Cumberland, PA 2 03-present White b. Sandra B. White and 2202-A Cedar Run Dr., 2002 - present various boyfriends, names Extended unknown Camp Hill, PA c. Sandra B. White and 45 North Winding Rd. November, 2005 - boyfriend, Robert Knisley Wellsville, PA present d. Jason R. and Jennifer L. 1094 Huron Drive May 2002 - August White Harrisburg, PA 2003 e. Jason R. and Jennifer L. 2311 North Front St. June 2001 - May White Harrisburg, PA 2002 f Sandra B. White 794 Schoolhouse Lane 2001 -2002 Lewisberry, PA The mother of the child is Defendant, Sandra B. White, currently residing at 2202- A Cedar Run Drive, Camp Hill, Cumberland County, Pennsylvania. She is dilvorced. The father of the child is Plaintiff, Jason White, currently residing at 140 Westover Drive, New Cumberland, Cumberland County, Pennsylvania. He is married. 2 4. The relationship of Plaintiff to the child is natural father. The Plaintiff currently resides with the following persons: NAME a. Jennifer L. White RELATIONSHIP wife b. Jacob R. White c. Joey R. White son daughter 5. The relationship of Defendant to the child is that of natural m+er. The Defendant currently resides with the following persons: NAME RELATIONSHIP a. Robert Knisley boyfriend b. Eric Murray brother c. Zeric brother's child d. Caneesa brother's child e. Taylor boyfriend's child 6. Plaintiff has not participated as a party or witness, or in anothe} 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 these physical custody of the child or claims to have custody or visitation ri€ child. 3 who has pect to the The best interests and permanent welfare of the child will be served by granting the relief requested because the Plaintiff has been the primary caretaker of the'', child, can provide a stable, safe, and secure environment and can provide for the child's emotional, psychological and spiritual needs. Further, the child views the Plaintiff as a source of stabilL , a source of love, and a source of emotional support. 8. Defendant has advised Plaintiff that she intends to relocate to School District, to reside at her boyfriend's home prior to the beginning of academic school year despite the fact the parties' Marital Settlement Plaintiff and Defendant will not move out of the West Shore School District minority. 9. The parties' child is going into the second grade. the child's 10. The best interests of the minor child would not be served by her transfer to the Northern School District. 11. The Defendant, over the course of the past five (5) years has resided at numerous locations and with various individuals and relatives, all of which is not conducive to the development of the child. 12. The Plaintiff, on the other hand, has established a stable life-style, has acquired a home, re-married and has had children who the child has established a close bond. I Northern 2006/2007 provides that 4 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or isitation of the child have been given notice of the pendency of this action and the right to intervene: None. WHEREFORE, Plaintiff requests the Court to grant primary physical to the Plaintiff and grant periods of partial physical custody to the Defendant. Respectfully submitted, Date: 1 Z GYj By: r an . Cunningham, Esquire I.D. # 144 2320 orth Second Street P. O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 (Attorneys for Plaintiff) F:\HOMEWHEWITTDOCS\W-Z\WHITE\CUSTCOMP. WPD of the child , P.C. 5 VERIFICATION The undersigned, verifies that the statements contained in the foregoing are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unswom falsification to authorities. Dated: CERTIFICATE OF SERVICE I do hereby state that on the day of July, 2006, I served a true and correct copy of the foregoing Complaint for Custody in the captioned matter, by placing the same in the United States mail, certified, return receipt requested, postage prepaid, and in United States mail, first class, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Sandra B. White 2202-A Cedar Run Drive Extended Camp Hill, PA 17011 Angela L. Hewitt Legal Secretary 7U ?' O ? ?_ ? ? tJ r?? Jordan D. Cunningham, Esquire Pa. Supreme Court I.D. 23144 Cunningham & Chernicoff, P.C. 2320 North 2"^ Street P.O. Box 60457 Harrisburg, PA 17106-0457 Telephone: 717-238-6570 Facsimile: 717-238-4809 Attorneys for Plaintiff' JASON WHITE, Plaintiff V. SANDRA B. WHITE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-3968 CIVIL ACTION - CUSTODY PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Please filed the attached as Proof of Service in the above matter indicating service of the Complaint for Custody upon the Defendant in this matter on July 15, 2006. Respectfully submitted, 'P.C. Dated: July 1Q, 2006 r an Dttunningham, Esquire D.#23144 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 F:\HOMEWHEWITr\DOCS\W-Z\WHITE\PRAPROOF. WPD ¦ RMR your urns and e1d aM on tha w4am ac that we W rokm the owd to you. s Much itch lied to d a book of tlls rradlplew, or on the trait n opine parks. 1.. Ar" Addwaad t0: o?ck?- R ? Run ooll 2. ArWaN~ ii it i i ! i::; _. A. x ,J or YdWWsd*MdtlpWtfwmkemt4 'QYae oy xMrw below , W YES enter , dewrt : O No ' worood Mao ? e?r.ea Mil Sol" , O Rdum RW W for Mwdm d" 4. Rabic hd DeovepR flkaa Fey ? Yea s, OW S ?5/?6-? RbhWy' 4 ; ' wMaw Rwan RaOalpt 10259602-.M840 if CERTIFICATE OF SERVICE I do hereby state that on the 4 day of July, 2006, I served a true and correct copy of the foregoing Praecipe to File Proof of Service in the captioned matter, by placing the same in the United States mail, first class, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Sandra B. White 2202-A Cedar Run Drive Extended Camp Hill, PA 17011 ()Atk:? Angela L. ewi Legal Secretary w L.. r :,= , .. ,,: t ?, :'.? ?_ ? JASON WHITE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-3968 CIVIL ACTION LAW SANDRA B. WHITE IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, July 18, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, August 23, 2006 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Dawn S. Sunday Esq. ?Yf 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 ?4 61 L AP _Irv ??y,yyvN?77 ? ~ a` ? ?i1 I2ECEIV?.s AUG Z 4 No BY:., JASON WHITE IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 06-3968 CIVIL ACTION LAW SANDRA B. WHITE Defendant IN CUSTODY ORDER OF COURT AND NOW, this ',`111 day of 2006, upon consideration of the attached Custody Conciliation Report, it i ordered and directed as follows: The custody provisions of the parties' Marital Settlement Agreement dated June 11, 2002 are incorporated into this Order and shall continue in effect as modified by this Order. 2. The parties shall share having physical custody of the Child on an alternating weekly basis, with the exchange to take place every Friday at 6:00 p.m. The alternating weekly schedule under this provision shall begin with the Father having custody on Friday, September 1, 2006. The non-custodial parent shall have custody of the Child on Tuesdays and Thursdays from after school/work until 8:00 p.m. 3. The parties shall submit themselves, their minor Child and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by Stanley Schneider, or other professional selected by agreement of the parties. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best meet the needs of the Child in light of the Mother's plan for relocation after the current school year and other issues raised by the parties. The parties shall sign any authorizations deemed necessary by the evaluator to obtain additional information pertaining to the Child or the parties. The parties shall share the costs of the evaluation, with the Father to be responsible for sixty percent and the Mother to be responsible for forty percent of the total costs. 4. The parties shall schedule an appointment for the Child and the parties with Bridget Weible to assess the need for ongoing or temporary counseling for the Child. The Mother shall provide the Father with a copy of the letter previously provided to the Mother from the counselor. Both parties shall have equal access to feedback from the counselor. Each party shall notify the other parent in advance of any medical or other appointments or activities for the Child to enable the other parent to attend if available. 6. The parties shall communicate directly with each other, rather than through the Child, concerning issues involving the Child or the custodial arrangements. The parties shall avoid involving the Child in custodial issues. Neither party shall make derogatory comments about the other parent in the presence or hearing of the Child. To the contrary, the parties shall foster the relationship between the Child and the other parent to the extent possible. The parties shall ensure that third parties having contact with the Child comply with this provision. 8. Within sixty days of receipt of the written custody recommendations from the evaluator, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary. 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. BY THE COURT, ?k UA % ? - cc: /ordan D. Cunningham, Esquire - Counsel for Father tZoward Krug, Esquire - Counsel for Mother IOU a - - 2 :t O_ N : - y r ?s (.D Q CL O d N U JASON WHITE IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. SANDRA B. WHITE Defendant 06-3968 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Rebecca D. White April 13, 1999 Mother/Father 2. A custody conciliation conference was held on August 23, 2006, with the following individuals in attendance: The Father, Jason White, with his counsel, Jordan D. Cunningham, Esquire, and the Mother, Sandra B. White, with her counsel, Howard Krug, Esquire. 3. The parties agreed to entry of an Order in the form as attached. &? L?? Date Dawn S. Sunday, Esquire Custody Conciliator _ j OCT 486 JASON WHITE vs. Plaintiff SANDRA B. WHITE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-3968 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 10 day of O t? oAn. t rr , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated August 24, 2006, incorporating the provisions of the parties' Marital Settlement Agreement dated June 11, 2002 shall continue in effect with the exception of paragraphs 2, 3 and 4, which are replaced with the provisions of this Order. 2. The parties shall have physical custody of the Child in accordance with the following schedule: A. During the school year, the Father shall have primary physical custody of the Child and the Mother shall have partial physical custody on alternating weekends from Thursday, when the Mother shall pick up the Child after school, through Sunday at 7:00 p.m. and on every Monday from 5:00 p.m. until 8:00 p.m. B. During the summer school break, the parties shall share having physical custody of the Child on an alternating weekly basis. 3. The parties shall contact Deborah Salem within ten (10) days of the date of this Order to schedule the initial co-parenting counseling sessions. The parties shall attend a minimum of four (4) joint co-parenting counseling sessions unless otherwise recommended by the counselor. The purpose of the co-parenting counseling shall be to address issues which have arisen with regard to the custody schedule and to establish sufficient cooperation and communication to enable the parties to effectively co-parent the Child. All costs of the counseling shall be shared equally between the parties. The parties shall follow the counselor's recommendation as to the involvement of third party family or household members in the co-parenting sessions. 4. The Father shall contact Dr. Schneider's office within ten (10) days of the date of this Order to provide the list of counselors covered under the Father's insurance plan in order to obtain a referral for a separate counselor for the Child. Within ten (10) days of receiving Dr. Schneider's referral or recommendation as to a counselor for the Child, the Father shall contact that professional's office to schedule the initial appointment. !'? s'"t i `? ?? ??? t 1 ?, , 5. After the parties have participated in a minimum of three (3) joint co-parenting counseling sessions, counsel for either party may contact the conciliator to schedule a follow-up custody conciliation conference if necessary to review the custodial arrangements. 6. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, -V, ?xl - `k M. L. Ebert, Jr. J. cc: Howard B. Krug, Esquire - Counsel for Mother Jordan D. Cunningham, Esquire - Counsel for Father 06pt#s t-^`alLL /1/07 JASON WHITE Plaintiff VS. SANDRA B. WHITE Defendant Prior Judge: M. L. Ebert, Jr. OCT $ 8 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-3968 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Rebecca D. White April 13, 1999 Father/Mother 2. A custody conciliation conference was initially held on August 8, 2007, with the following individuals in attendance: the Father, Jason White, with his counsel, Jordan D. Cunningham, Esquire, and the Mother, Sandra B. White, with her counsel, Howard B. Krug, Esquire. 3. At the initial conciliation conference, the parties discussed Dr. Schneider's custody recommendations following an evaluation and other considerations in establishing an ongoing parenting schedule. A tentative agreement was reached on a schedule to be followed for a minimum of three (3) weeks and it was also agreed that counsel would schedule a telephone conference with the conciliator during the first week of October to review the arrangements, after which time a proposed Order would be submitted. Accordingly, the telephone conference was held on October 17, 2007 with the Mother's counsel, Howard B. Krug, Esquire, and counsel for the Father, Kelly M. Knight, Esquire (due to Jordan Cunningham, Esquire's unavailability) participating. 4. The conciliator recommends an Order in the form as attached. CY? ?? ;?00 - ?a -1? Date Dawn S. Sunday, Esquire Custody Conciliator JASON WHITE IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 06-3968 CIVIL ACTION LAW SANDRA B. WHITE . Defendant IN CUSTODY ORDER OF COURT AND NOW, this I(D%V\ l day of 0 V ?VY1,1Q e,,r 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated August 24, 2006, incorporating the provisions of the parties' Marital Settlement Agreement dated June 11, 2002 shall continue in effect with the exception of paragraphs 2, 3 and 4, which are replaced with the provisions of this Order. 2. The parties shall have physical custody of the Child in accordance with the following schedule: A. During the school year, the Father shall have primary physical custody of the Child and the Mother shall have partial physical custody on alternating weekends from Thursday at 5:00 p.m. through Sunday at 7:00 p.m. In addition, during weeks following the Father's weekends, the Mother shall have custody on Monday from 5:00 p.m. until 8:00 p.m. and during weeks following the Mother's weekends, the Mother shall have custody from Thursday at 5:00 p.m. until Friday morning when the Mother shall put the Child on the bus for school. B. During the summer school break, the parties shall share having physical custody of the Child on an alternating weekly basis. 3. The parties shall contact Deborah Salem within ten (10) days of the date of this Order to schedule the initial co-parenting counseling sessions. The parties shall attend a minimum of four (4) point co-parenting counseling sessions unless otherwise recommended by the counselor. The purpose of the co-parenting counseling shall be to address issues which have arisen with regard to the custody schedule and to establish sufficient cooperation and communication to enable the parties to effectively co-parent the Child. All costs of the counseling shall be shared equally between the parties. The parties shall follow the counselor's recommendation as to the involvement of third party family or household members in the co-parenting sessions. 4. The Father shall contact Dr. Schneider's office within ten (10) days of the date of this Order to provide the list of counselors covered under the Father's insurance plan in order to obtain a referral for a separate counselor for the Child. Within ten (10) days of receiving Dr. Schneider's referral or recommendation as to a counselor for the Child, the Father shall contact that professional's office to schedule the initial appointment. 5. After the parties have participated in a minimum of three (3) joint co-parenting counseling sessions, counsel for either party may contact the conciliator to schedule a follow-up custody conciliation conference if necessary to review the custodial arrangements. 6. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc: Award B. Krug, Esquire - Counsel for Mothe ordan D. Cunningham, Esquire - Counsel for I*t\ -?, ?3A M. L. Ebert, Jr. 4 J. f0.! a _.. .. ti tjj C 1 .6 WV 9, A0 N L0,OZ Mvic" 20 JASON VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2006-3968 CIVIL ACTION LAW c ?= ? 1-n rn =- :.:a r -vm Ln crz IN CUSTODY SANDRA B. WHITE Plaintiff Defendant Court ORDER OF COURT " NOW, this 2 day of p 1 2011, upon of the attached Custody Conciliation Report, it i ordered and directed as follows: As he Father has indicated through counsel an intention not to proceed with the Petition for ,ati n which was the subject of a July 20, 2010 conciliation conference, the prior Order of this ate November 26, 2007 shall continue in effect without modification. cc: D. Cunningham, Esquire - Counsel for Father I B. Krug, Esquire - Counsel for Mother Maded BY THE COURT, JASON VS. SANDRA 13. WHITE IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 2006-3968 CIVIL ACTION LAW Defendant IN CUSTODY Prior Judg?: M. L. Ebert, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. 7 he pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Rebecca D.1 White April 13, 1999 Mother/Father 2. custody conciliation conference was held on the Father's Petition for Modification on July 20, 2010, ith the following individuals in attendance: the Father, Jason White, with his counsel, Jordan D. Cunningham, Esquire, and the Mother, Sandra B. White, with her counsel, Howard B. Krug, Esquire. 3. The Father filed the Petition for Modification seeking to reduce the Mother's periods of custody wi the Child from the currently shared schedule. By the end of the conference, the parties were discussing the possibility of participating in co-parenting counseling to address the underlying issues before determining whether a change in the schedule was necessary. The parties also discussed whether it as advisable for the Child to continue in her current counseling. Counsel for the parties requested that the conciliator hold this matter open to enable them to discuss the counseling issue with the Child's current counselor, Dennis Graybill. Subsequently a telephone conference was held with counsel on October 26, 2010 and counsel reported that the Child was no longer seeing Mr. Graybill in counseling as the Mother had objected and counsel were working on assisting the parties in selecting a different c unselor for the Child. Again, counsel requested that this matter be held open pending selection o the counselor. 4. Order entf Father's c( conciliator Date ng had no further request to either reconvene the conciliation conference or to have the identifying a selected counselor for the Child, upon the conciliator's inquiry, the ;1's office advised that no further Order is necessary at this time. Accordingly, the mmends an Order in the form as attached. 0, C40 1 / Dawn S. Sunday, Esquire Custody Conciliator