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HomeMy WebLinkAbout06-5373Leslie Lamp, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Greg Stahl, No. b(, -,T.3?Q4 CIVIL Defendant IN CUSTODY COMPLAINT FOR CUSTODY The plaintiff is Leslie Lamp, residing at 50 Bonnybrook Road, Lot 48, Carlisle, Cumberland County, Pennsylvania 17013. II 2. The defendant is Greg Stahl, residing at 30 Gasoline Alley, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Skate Stahl 50 Bonnybrook Rd. Lot 48 3-19-01 5 years Carlisle, Pa 17013 The child was born out of wedlock The child is presently in the custody of Leslie Lamp, residing at 50 Bonnybrook Rood, Lot 48, Carlisle, Cumberland County, Pennsylvania 17013. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Leslie & Marcia Lamp New Kingston 2001 to 2002 Greg Stahl Leslie Lamp 20 W. Springville Road 2002 to 2005 Greg Stahl Boiling Springs, Pa Leslie Lamp 50 Bonnybrook Road, Lot 48 2005 to present Dan Smyser Carlisle, Pa 17013 IIII 4. The mother of the child is Leslie Lamp, residing at 50 Bonnybrook Road, Loth 48, Carlisle, Cumberland County, Pennsylvania 17013. She is unmarried. The father of the child is Greg Stahl, residing at 30 Gasoline Alley, Carlisle, Cumberland County, Pennsylvania 17013. 5. He is unmarried. The relationship of plaintiff to the child is that of Mother. The plaintiff currently resides with the following persons. Name Skate Stahl Dan Smyser 6. Relationship Son Friend The relationship of defendant to the child is that of Father. The defendant currently resides with the following persons. Name Himself 7 8 Relationship Plaintiff has not participated as a party or witness, or in another capacity, in ether litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pe ding in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has p lysical custody of the child and claims to have custody or visitation rights with resp ct to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the child. Plaintiff is best able to provide the care and nurture which the child needs for a healthy development. A Court Order of custody and structured visitation is desired so that the Plain?iff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so thatlthe child is not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established and the continued stability of the household is in the best in',erest of the child. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. Defendant frequently abuses alcohol and is therefore unreliable as custodian Of the child. II', WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody subject to structured partial custody by the Defendant. Respectfully submitted, ROMINGER & WHARE Date: If q D 6 - It Leslie A. Tom o, Esquire 155 South Ha over Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 200198 Attorney for Plaintiff Leslie Lamp, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Greg Stahl, No. CIVIL Defendant IN CUSTODY VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. illl Leslie Lamp, Plai ff I? Leslie Lamp, Plaintiff V. Greg Stahl, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. CIVIL IN CUSTODY CERTIFICATE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Plaintiff do hereby certify that I this a copy of the within Complaint for Custody upon the following by depositing same States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Greg Stahl 30 Gasoline Alley Carlisle, Pa 17013 Date: q lcf D 6 1,8 fie A. Tome q, Esquire 155 South Hano er Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 200198 Attorney for Plaintiff day mailed the United 1 O V V r l r n. 77 .: 3 LESLIE LAMP IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. GREGSTAHL DEFENDANT 06-5373 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, September 20, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, October 27, 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/ Hubert X. GRro Es q. 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 ?iNn- 8 02 83S t10Z Dr-1 a, 2D?6 LESLIE LAMP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06-5373 CIVIL ACTION - LAW GREG STAHL, IN CUSTODY Defendant COURT ORDER AND NOW, this 0`4 day of I.TnrG- k , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Leslie Lamp, and the Father, Greg Stahl, shall enjoy shared legal custody and shared physical custody of the minor child, Skate A. Stahl, born March 19, 2001. 2. Physical custody shall be handled pursuant to an equal physical custody arrangement with the schedule to be arranged between the parties. 3. Commencing January, 2007 for purposes of school registration, the child shall be considered to be residing with Mother solely on the school issue so that the child may be registered at the Moreland Elementary School in Carlisle. However, the physical custody and legal custody arrangement as set forth above shall continue. 4. In light of the fact that the Father does not have a driver's license, Mother shall handle transportation for exchange of custody. However, Father shall endeavor to attempt to get some friends or family members who will help lessen the burden for Mother for transportation. Additionally, when and if Father does get a driver's license, Father shall reciprocate to Mother for a similar period of time of solely handling the transportation. BY THE COURT, ?I Judge Cc: -chael O. Palermo, Jr., Esquire r. Greg Stahl l , `,0 ? 1 1 t ?'f y,ti 1 ? lr ? _, ?, v r rs°i{ 1?.? ?. ??? t ? \?.l 4r ? 4 ? ?? ? -1+x.1...1 LESLIE LAMP, Plaintiff VS. GREG STAHL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5373 CIVIL ACTION - LAW IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Skate A. Stahl, born March 19, 2001 2. A Conciliation Conference was held on October 27, 2006 with the following individuals in attendance: The Mother, Leslie Lamp, with her counsel, Michael O. Palermo, Jr., Esquire The Father, Greg Stahl, who appeared without counsel 3. The parties agreed to the entry of an Order in the form as attached. Date: October , 2006 Hubert X. Gil y, Esquire Custody Co iliator LESLIE LAMP Plaintiff, V. GREG STAHL Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 06-5373 CIVIL TERM IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW comes the Plaintiff, Leslie Lamp, by and through her attorney, Mark F. Bayley, and in support of the within petition avers as follows: 1. Petitioner is Leslie Lamp (hereafter "Mother"), who is currently residing at 111 Herman Ave., Lemoyne, and is employed at Ski Roundtop and Nathan's Cafe in Enola. 2. Respondent is Greg Stahl (hereafter "Father"), who is currently residing at 235 N. Front St., Newport, PA 17074 (Father indicated to undersigned counsel that said address should become his address of record) and is currently unemployed. 3. The child at issue is Skate A. Stahl, born March 19, 2001. 4. The parties previously agreed on an Order that was entered by the Honorable Kevin A. Hess on November 2, 2006 (attached as "Exhibit A"); said Order provides for shared legal custody and an "equal physical custody arrangement with the schedule to be arranged between the parties." 5. The Order also directed that the child be enrolled in Moreland Elementary School; however, the parties agreed in 2006 to have the child enrolled at Middlesex Elementary where he has attended up until Friday, January 22, 2010. 77 w? U -71 6. Up until January 25, 2010 the parties had been swapping physical custody every weekend, Mother had every Monday and Tuesday, and Father had every Wednesday and Thursday (Father had been residing at 30 Gasoline Alley, Carlisle). 7. Within a few days of Mother's usual Monday custodial period scheduled for January 25, 2010, Father without notice relocated to Newport with the child and is in the enrolment process at Newport Elementary. 8. Father has not permitted Mother to see the child since the end of her previous custodial period on January 19, 2010. 9. Should the child attend school in Newport it will be impossible to maintain the custodial schedule that has been in place since 2006 and impossible for the parties to equally share physical custody pursuant to the current Order. 10. Father has unilaterally breached the current Order by failing to involve Mother in a decision that clearly required agreement or further Court Order. 11. If Father wishes to remain in Newport the only fair resolution is for the child to be enrolled in Washington Heights Elementary (West Shore School District) and reside primarily with Mother pending conciliation/trial. 12. Mother believes it to be in the child's best interests to attend school at Washington Heights Elementary; she however has no intention of enrolling the child without Court permission. 13. Undersigned counsel spoke with Father on the below date in an unsuccessful attempt to resolve this matter informally; Father is opposed to the entry of the proposed order and continues the enrolment process in Newport. WHEREFORE, Mother respectfully requests permission to enroll the child in Washington Heights Elementary and to exercise primary physical custody pending conciliation and/or a hearing on the matter. Respectfully submitted, BAYLEY & MANGAN Date: v I \ Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 VERIFICATION I, LESLIE LAMP, verify that the statements made in this Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: ?? /d LESLIE LAM ,Plaintiff X1312a LESLIE LAMP, Plaintiff VS. GREG STAHL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5373 CIVIL ACTION - LAW IN CUSTODY COURT ORDER AND NOW, this 04 day of Vnw--fir , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Leslie Lamp, and the Father, Greg Stahl, shall enjoy shared legal custody and shared physical custody of the minor child, Skate A. Stahl, born March 19, 2001. 2. Physical custody shall be handled pursuant to an equal physical custody arrangement with the schedule to be arranged between the parties. 3. Commencing January, 2007 for purposes of school registration, the child shall be considered to be residing with Mother solely on the school issue so that the child may be registered at the Moreland Elementary School in Carlisle. However, the physical custody and legal custody arrangement as set forth above shall continue. 4. In light of the fact that the Father does not have a driver's license, Mother shall handle transportation for exchange of custody. However, Father shall endeavor to attempt to get some friends or family members who will help lessen the burden for Mother for transportation. Additionally, when and if Father does get a driver's license, Father shall reciprocate to Mother for a similar period of time of solely handling the transportation. BY THE COURT, Judge Cc: -chael O. Palermo, Jr., Esquire r. Greg Stahl 4. ?lY 1 - , , olA ?jj LESLIE LAMP, Plaintiff VS. GREG STAHL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5373 CIVIL ACTION - LAW IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 19153-5(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Skate A. Stahl, born March 19, 2001 2. A Conciliation Conference was held on October 27, 2006 with the following individuals in attendance: The Mother, Leslie Lamp, with her counsel, Michael O. Palermo, Jr., Esquire The Father, Greg Stahl, who appeared without counsel 3. The parties agreed to the entry of an Order in the form as attached. Date: October 3b , 2006 Hubert X. Gily6y, Esquire Custody Co;&iliator LESLIE LAMP : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW GREG STAHL : NO. 06-5373 CIVIL TERM Defendant. : IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the foregoing document upon the following by First Class U.S. Mail: Greg Stahl 235 N. Front St. Newport, PA 17074 ?' '?('--?D Mark F. Bayley, Esquire BAYLEY & MANGAN Mark F. Bayley, Esquire Attomey I.D. #: 87663 17 West South Street Carlisle, PA 17013 (717) 241-2446 LESLIE LAMP Plaintiff, VS. GREG STAHL Defendant FILED- t??M1 I ?^ ?f7 ,4rr? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW No. 06-5373 CIVIL TERM IN CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Plaintiff, Leslie Lamp, in the above- captioned matter. 0 Date: Mark F. Bayley, Esquire Bayley & Mangan 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 ../ . I. LESLIE LAMP IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW GREG STAHL No. 06-5373 CIVIL TERM Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Greg Stahl 235 N. Front Street Newport, PA 17074 U_AR l Mark F. Ba yley, Esquire Dated: IIIJJJ NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF ?rt 21CfE- v F ii F-0c, i? C-,: .1 iy F (: iJ LESLIE E. LAMP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 2006 - 5373 CIVIL GREG A. STAHL, Defendant : IN CUSTODY PETITION FOR SPECIAL RELIEF NOW COMES the defendant, Greg A. Stahl, by and through his counsel, Nathan C. Wolf, Esquire, and presents the following petition for special relief and in support thereof represents as follows: 1. The plaintiff/respondent is Leslie E. Lamp, the natural mother of the child who is the subject of this action (hereinafter referred to as "Mother"), an adult individual residing at 111 Herman Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 2. The defendant/petitioner is Greg A. Stahl, the natural father of the child who is the subject of this action (hereinafter referred to as "Father"), an adult individual residing at 235 North Fifth Street, Borough of Newport, Perry County, Pennsylvania 17074. 3. Father seeks primary physical and joint legal custody of the following child: Name Present Residence Age Skate Alen Stahl 111 Herman Avenue 8 years, 11 months Lemoyne, PA 17043 (DOB 3/19/2001) 4. The parties are subject to an Order issued January 27, 2010, providing Mother with primary physical custody of the child, Father with partial physical custody of the child on alternating weekends from Friday after school until Sunday at 7:00 p.m. The Order also provided the parties 47o.oo PO A TYY kT -a 3goyb with shared legal custody of the child and permitting Mother to enroll the child in Washington Heights Elementary School in the West Shore School District. (A true and correct copy of said order is attached hereto as Exhibit A). 5. The Court also directed the Court Administrator to arrange a conciliation conference in this matter. 6. Previously the parties had been subject to an Order of Court issued November 2, 2006, providing for shared legal and physical custody of the child, resulting from an agreement reached at a conciliation conference on October 27, 2006. (A true and correct copy of said order is attached hereto as Exhibit B). 7. Mother correct states in her petition for special relief filed on January 26, 2010 that Father and Mother had agreed to enroll the child at Middlesex Elementary School rather than Mooreland Elementary School in 2006 and that the child's enrollment continued until January 22, 2010. 8. On January 25, 2010, Father had relocated to the above-listed address in Newport, Perry County as a result of an eviction from his prior residence at 30 Gasoline Aly, Carlisle, Pennsylvania 17013, where he had lived for approximately five years. 9. Father's residence was located at his prior place of employment, Carlisle Auto Salvage. 10. Father was injured at work on October 27, 2009 and has filed a claim for workers' compensation which is currently pending. 11. Father submits that his eviction was in retaliation for his claim for workers' compensation benefits. 12. Father notified Mother that he would be relocating in early November 2009, by telephone, and explained that he would have to change the child's school enrollment as a result. 13. Mother did not voice an objection to the relocation or the enrollment change for this academic year, but rather requested that the child would be enrolled in her school district for the 2010-2011 school year. 14. Father voiced concerns with Mother over the child's academic performance while in Mother's custody but indicated that the parties could discuss the situation following the current school year. 15. Thereafter on or about January 5, 2010 Father contacted Mother to inform her that he had found a new home in Newport and Mother again voiced no objection to the relocation or change in school enrollment. 16. Father submits that during the time period from approximately January 2007 until September 2008, Father had custody of the child approximately 5 days (including overnight) per week. 17. Thereafter, from September 2008 until January 2010, Father exercised custody of the child on at least 4 overnights each week. Mother would generally have custody of the child on Tuesday nights and alternating weekends from Friday until Sunday. 18. During Mother's periods of custody, it is believed that the child spent a significant portion of time with his maternal grandmother, particularly overnights. 19. Thus, Father submits that he has effectively enjoyed primary physical custody since January 2007. 20. Mother has been employed since sometime in October 2009 as a bartender at Nathan's Cafe in Enola, Pennsylvania. 21. Upon information and belief, Mother is often required to work late weekend hours and is therefore unavailable to care for the child. 22. Mother is also employed at Ski Roundtop working night shifts during the week. 23. Mother averred in her petition for special relief filed January 26, 2010, that Father had refused to allow Mother to see the child since January 19, 2010. 24. It is averred that Mother purposely mislead the Court by failing to disclose the from 9:00 a.m. on January 18, 2010 until sometime on January 24, 2010, Mother was serving two consecutive 72 hour sentences for DUI offenses in the Cumberland County Prison. A true and correct copy of the sentencing Order dated January 14, 2010 is attached hereto as Exhibit C. 25. Mother did not inform Father of when her actual incarceration was scheduled to occur or how long it would last. Rather Father only learned of her incarceration at the time of the preparation of the instant petition. 26. Mother was charged with a DUI offense as recently as May 1, 2009, when Mother was accused of not only driving under the influence, but refusing chemical testing, and several other misdemeanor counts of Disorder Conduct for her unruly, obscene behavior including fighting with police officers during the course of her arrest. (A true and correct copy of the affidavit of probable cause from this incident is attached hereto as Exhibit D). 27. Father's residence had been approximately 19 miles and 26 minutes from Mother before his relocation. 28. Father's residence is now approximately 29.5 miles and 41 minutes from Mother's residence. 29. Father's relocation to Newport was out of necessity rather than by choice and resulted in a difference in driving distance of 10.5 miles or 15 minutes at most from Mother's residence. 30. However, the child's maternal grandmother, whom Mother uses frequently for childcare resides in Mt. Holly Springs, Cumberland County an approximate distance of 26 miles and taking approximately 34 minutes. 31. Mother's averment that it is impossible for the parties to share equal physical custody of the child is both inaccurate, because she has not shared equal custody of the child for nearly 3 years and is misleading because Mother's own childcare is just a far from her home as Father's home is, both in distance and time. 32. Father believed that Mother did not object to his relocation and therefore did not seek Court permission prior to relocating or he would have most certainly done so. 33. Mother's driver's license has been suspended as a result of her refusal to submit to chemical testing of her blood following her arrest in May. 34. On November 23, 2009 Mother signed an acknowledgment of suspension, indicating that her license had been suspended on August of 2009 for her refusal. 35. As recently as January 31, 2010, Mother was seen driving her jeep Wrangler on Market Street in Lemoyne. 36. It is believed that Mother continues to drive despite the fact that she does not have a valid driver's license, including her transportation of the child. 37. Mother was convicted of driving without a license on November 6, 2009, by Magisterial District Court 02-3-05, in Lancaster County, as evidence by the attached docket sheet. (A true and correct copy of the docket information obtained from the AOPC internet website is attached hereto as Exhibit E) 38. Upon information and belief Mother continues to consume alcohol in violation of her conditions of probation, imposed on January 14, 2010. 39. Until recently, Father has taken the child to Awainas (a youth group similar to boy scouts) on Wednesday nights in Carlisle since 2008. 40. Likewise, Father has consistently taken the child to Cub Scouts on Monday nights in Middlesex Township since 2007. 41. Father submits that attendance records can be provided from these activities to support his claim that Mother did not have custody of the child on Mondays as she has averred. Rather this evidence will support Father's position that he has exercised primary physical custody of the child. 42. Father submits that he is actively involved in the child's education and has been since school began in 2006. 43. Father attends parent teacher conferences and activities at the school regularly, though he did miss conferences this year due to his work-related injury. 44. Father submits that the child is an above-average student and that the child rode the school bus to and from school four days per week and that the child's maternal grandmother was responsible for the child's transportation on the remaining weekday. 45. Father believes that Mother's petition for special relief was motivated by the fact that Father sought public assistance benefits which triggered a requirement for Father to seek child support from Mother. 46. While Mother was not required to actually pay support after a conference on January 11, 2010, it is believed that Mother's actions are in retaliation for the filing, even though the complaint filed because of a requirement on Father and not by his choice. 47. Mother has not had a good history of ensuring that the child's schoolwork is done when the child is in her care. 48. Father submits that Mother frequently leaves the child without adequate supervision while in her custody. 49. The child has indicated that he is frightened when Mother has left him alone in her house for hours at night. 50. The child has indicated that he would strongly prefer to attend school in Father's school district and to live with Father on a primary basis. 51. It is believed that Mother has attempted to manipulate the child by threatening that if Father obtains an Order for primary custody that Father will keep Mother and the child's maternal grandmother from seeing the child. Such threats are wholly baseless and Father would ensure that the child continues to have a strong relationship with his Mother. 52. Father believes that without an Order for emergency relief, the child's best interests and permanent welfare will be substantially at risk if permitted to be in Mother's primary physical custody because Mother's availability to care for the child and Mother's own alcohol abuse issues and disregard for her driver's license suspension reflect Mother's inability to make good decisions for her own well-being, let alone her child's well-being. 53. Father submits that the child's best interests and permanent welfare would be best served by granting him primary physical custody and permitting Father to re-enroll the child to attend Newport Elementary School. 54. Father submits that this relief would permit the child to have the greatest level of stability and care and reflects the child's preference as well. 55. Concurrence in the instant petition was sought from Mother's counsel by the undersigned and such concurrence was not given. 56. The prior judge assigned to this matter is the Honorable Kevin A. Hess, P .J. 57. Father believes that the best interests of the child will be served by granting the relief requested herein. WHEREFORE, for the reasons set forth herein, defendant, Greg A. Stahl, respectfully requests that the Court enter a temporary order granting physical custody of the child to the Father, granting Mother partial custody on Tuesday nights and alternating weekends and directing that the child may be enrolled in the Newport Elementary School effective immediately, until this matter can be heard by the Court via hearing or, at a minimum, until the conciliation conference can occur, along with any additional relief that the Court may deem appropriate and just. Date: February 1, 2010 By: Respectfully submitted, WOLF & WOLF, Attorneys at Law Nathan , Esquire 10 West ' h Street Carlisle, PA 17013 Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Defendant VERIFICATION I do hereby verify that I am the defendant in the foregoing action and that the facts set forth in this petition are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. February J , 2010 JAN P 6 201 nLESLIE LAMP : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW GREG STAHL : NO. 06-5373 CIVIL TERM Defendant. : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2009, upon consideration of Plaintiffs Petition for Special Relief and pending further order; it is hereby directed that Plaintiff shall exercise primary physical custody of Skate Stahl (D.O.B. March 19, 2001) subject to Father's periods of partial physical custody every other weekend from Friday after school to Sunday at 7:00 p.m. Mother may immediately enroll the child in Washington Heights Elementary. The parties shall continue to share legal custody. The, previous A-Fdex- of ?Nevefnber- 2, 2096 is vaeeAed, la the meantiffte, ft g is se or e m The court administrator shall arrange this matter to be scheduled for conciliation. BY THE COURT: Mark F. Bayley, Esq. Greg Stahl - 235 N. Front Street, Newport, PA 17074 TRUE t.`WY FROM RECORD M T680"OW 1090 1 hM WMO Nt rrvy hand and 9W a" of aw at COMIK Pa. T j? d SS .20.6_ hOfhonota ry OCT 3 1 2006 LESLIE LAMP, Plaintiff VS. GREG STAHL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-5373 : IN CUSTODY COURT ORDER CIVIL ACTION - LAW AND NOW this day of e- Q , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Leslie Lamp, and the Father, Greg Stahl, shall enjoy shared legal custody and shared physical custody of the minor child, Skate A. Stahl, born March 19, 2001. 2. Physical custody shall be handled pursuant to an equal physical custody arrangement with the schedule to be arranged between the parties. 3. Commencing January, 2007 for purposes of school registration, the child shall be considered to be residing with Mother solely on the school issue so that the child may be registered at the Moreland Elementary School in Carlisle. However, the physical custody and legal custody arrangement as set forth above shall continue. 4. In light of the fact that the Father does not have a driver's license, Mother shall handle transportation for exchange of custody. However, Father shall endeavor to attempt to get some friends or family members who will help lessen the burden for Mother for transportation. Additionally, when and if Father does get a driver's license, Father shall reciprocate to Mother for a similar period of time of solely handling the transportation. BY THE COURT, Judge TRUE Cn'm' v nM RECORD In T--: .t my hand Cc: Michael O. Palermo, Jr., Esquire Pa. J Mr. Greg Stahl Q,0 V •. `? f h `?j?-? Prothonotary COMMONWEALTH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CP-21-CR-1989-2008 CHARGE: (2) DUI, HIGHEST RATE (1ST) AFFIANT: PTL. ROBERT RESSLER c OTN: L414096-4 CP-21-CR-1456-2009 CHARGE: (3) DUI, GENERAL IMPAIRMENT WITH REFUSAL (1ST) AFFIANT: PTL. WARREN CORNELIOUS LESLIE EDEN LAMP OTN: L481584-5 IN RE: SENTENCING ORDER OF COURT AND NOW, this 14th day of January, 2010, the Defendant having appeared for sentence, and the Court being in receipt of a sentencing report that was recently prepared in connection with 1456 Criminal 2009, the sentence at 1456 Criminal 2009 is that she pay the costs of prosecution, a fine of $1,000.00, and that she undergo imprisonment in the Cumberland County Prison for not less than 72 hours nor more than 6 months. The sentence of the Court at 1989 Criminal 2008 is that she pay the costs of prosecution, a fine of $1,000.00, and that she undergo imprisonment in the Cumberland County Prison for not less than 72 hours nor more than 6 months. Said sentence to run consecutive to the sentence imposed above. The Defendant is directed to self-report to the Cumberland County Prison by 9:00 a.m. on Monday, January 18, 2010, for commencement of sentence. If she is not a discipline problem at the prison, she shall be paroled at the expiration of her minimum sentence without further Order of Court. Said parole to be with supervision and subject to the following .,; - .6 special conditions: 1. That she obtain a drug and alcohol evaluation and comply with all treatment recommendations. 2. That she attend and successfully complete the DUI alcohol highway safety school. 3. That she be and remain on good behavior. 4. That she comply with'all other directions of her parole officer. A specific condition shall be that she not drink alcohol. By the Co , Edward E. Guido, J. Jonathan R. Birbeck, Esquire Office of the District Attorney Arla M. Waller, Esquire Office of the Public Defender Probation Sheriff CCP Victim - Witness Court Administrator !-? M ? :11 ZJ10 srs CRIMINAL COMPLAINT COMMONWEALTH VS LESLIE EDEN LAMP INFORMATION: ON FRIDAY, MAY 1, 2009 THIS OFFICER WAS WESTBOUND IN THE 2300 BLK OF MARKET STREET WHEN I OBSERVED AN ORANGISH OLDSMOBILE TRAVELING EASTBOUND IN THE 2400 BLK OF MARKET STREET WEAVING ON THE ROADWAY. IT WAS NOTED THAT AS THE VEHICLE MOVED RIGHT BACK INTO IT'S PROPER LANE OF TRAVEL THAT IT STRUCK THE PEDESTRIAN SIGN ON THE ROADWAY, CAUSING IT TO MOVE. THIS OFFICER TURNED AROUND AND ATTEMPTED TO CATCH UP TO THE VEHICLE WHICH WAS EXCEEDING THE PROPERLY POSTED 25 MPH SPEED ZONE. ONCE IN THE 1700 BLK OF MARKET STREET THE VEHICLE AGAIN DRIFTED LEFT STRADDLING THE CENTER LINE OF THE ROADWAY AS IT CRESTED A HILL. ONCE IN THE 1200 ELK OF MARKET STREET I ACTIVATED MY EMERGENCY WARNING LIGHTS IN AN ATTEMPT TO STOP THE VEHICLE. THE VEHICLE DID YIELD MY WARNING AND PULLED TO THECURB IN THE 900 BLK. OF MARKET STREET AT OR ABOUT 0119 HRS. I APPROACHED THE DRIVERS SIDE OF THE VEHICLE AND REQUESTED THE DRIVER TO EXHIBIT HER DRIVERS LICENSE, REGISTRATION AND INSURANCE CARD. THE DRIVER ASKED IF SHE WAS SPEEDING AND AS SHE SPOKE I COULD DETECT AN ODOR OF AN ALCOHOLIC BEVERAGE EMANATING FROM HER AND NOTED HER EYES TO BE BLOODSHOT AND GLASSY IN APPEARANCE. WHEN ASKED WHERE SHE WAS COMING FROM SHE ADVISED ME A FRIEND'S HOUSE. WHEN ASKED HOW MUCH SHE HAD TO DRINK SHE ADVISED 1 BEER. THE DRIVER WAS ABLE TO PROVIDE ME WITH ALL OF THE REQUESTED DOCUMENTATION AND WAS IDENTIFIED FROM HER PA DRIVERS LICENSE AS LESLIE EDEN LAMP. LAMP WAS REQUESTED TO STEP FROM THE VEHICLE SO THAT I COULD ADMINISTER THE STANDARDIZED FIELD SOBRIETY TESTS TO HER. ** SEE CONTINUATION ADDENDUM ATTACHED ** 1, 1 Q EJN --kQTr C0 #q1UCgL IDl1J , BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION J%ND BELWF. Sworn to me and subscribed before me this day of _ kl&A _ a6*Cf 5_1 _6! Date , Magisterial District Judge my commission expires first Monday of January, SEAL C-Xhlb+ 0 75 3802 Al AFFIDAVIT of PROBABLE CAUSE 18 5505 PUBLIC DRUNKENESS SU 1 18 5503 A2 DISORDERLY CONDUCT-UNREASONABLE NOISE M3 1 18 5503 A3 DISORDERLY CONDUCT OBSCENE LANG/LEST MA 1 18 5503 Al DISORDERLY CONDUCT ENGAGE IN FIGHTING Mg 1 PAGE: 2 CRIMINAL COMPLAINT ADDENDUM DEFENDANT: LAMP LESLIE EDEN INCIDENT NO: 20090500004 SHE DID COMPLY WITH MY REQUEST AND EVEN OUT OF THE VEHICLE I COULD STILL DETECT AN ODOR OF AN ALCOHOLIC BEVERAGE EMANATING FROM HER. LAMP WAS WEARING A WHITE T-SHIRT, BLUE JEANS, SNEAKERS AND A WHITE AND BLCK CHECKERED SCARF. I PROCEEDED TO ADMINISTER THE STANDARDIZED FIELD SOBRIETY TESTS TO HER TO WHICH SHE SHOWED SIGNS OF INTOXICATION ON ALL OF THE TESTS THAT I ADMINISTERED TO HER. THIS LED ME TO BELIEVE THAT SHE WAS UNDER THE INFLUENCE OF ALCOHOL TO A DEGREE THAT SHE COULD NOT SAFELY OPERATE A MOTOR VEHICLE AND AT OR ABOUT 0130 HRS SHE WAS PLACED UNDER ARREST FOR DUI, HANDCUFFED AND SECURED IN THE REAR OF MY PATROL CAR. AFTER SECURING LAMP IN MY PATROL CAR SHE BEGAN KICKING THE CAR, YELLING OBSCENITIES AND REMOVED THE HANDCUFF FROM HER LEFT WRIST. I OPENED THE REAR DOOR TO THE PATROL CAR AND REQUESTED HER TO STEP OUT 5 TIMES SO THAT I COULD RESECURE THE HANDCUFF. LAMP REFUSED AND BEGAN KICKING AT ME. SHE WAS REMOVED FROM THE CAR RECUFFED AND RESECURED IN THE PATROL CAR. LAMP BEGAN KICKING THE CAR DOOR AGAIN, SCREAMING OBSCENITIES AND WAS ASKED TO STOP TO WHICH SHE REFUSED. AT OR ABOUT 0141 HRS LAMP WAS TRANSPORTED TO THE HARRISBURG HOSPITAL FOR A CHEMICAL TEST OF HER BLOOD AND TO RECEIVE TREATMENT FOR THE AFFECTS OF OC SPRAY. WE ARRIVED AT THE HOSPITAL AT OR ABOUT 0144 HOURS AND WERE SIGNED INTO THE HOSPITAL VIA THE INFORMATION THAT I PROVIDED AS LAMP WAS STILL SCREAMING OBSCENITIES AND BEING UNCOOPERATIVE WITH HOSPITAL STAFF. AT OR ABOUT 0200 HRS LAMP WAS READ THE PENN DOT DL-26 FORM, WHEN ASKED IF SHE WAS WILLING TO SUBMIT TO THE CHEMICAL TEST OF HER BLOOD LAMP STATED "GO FUCK YOURSELF". AT OR ABOUT 0209 HRS. JUSTIN MOUNTZ A STAFF TECHNOLOGIST AT THE HARRISBURG HOSPITAL CAME INTO THE ROOM TO TAKE LAMP'S BLOOD. WHEN ASKED IF SHE WOULD SUBMIT TO THE CHEMICAL TEST LAMP ADVISED, "I'M NOT GOING TO DO ANYTHING". LAMP THEN AGREED TO SUBMIT TO THE TEST AND WAS UNHANDCUFFED SHE WRAPPED HER ARMS UNDER HER BODY AND AGAIN ADVISED SHE WASN'T DOING ANYTHING. LAMP WAS HANDCUFFED AND REFUSED TO LEAVE THE EMERGENCY ROOM. MYSELF AND TWO HOSPITAL SECURITY STAFF WERE FORCED TO CARRY LAMP FROM THE ER. CAUSING STAFF AND PATIENTS TO SCATTER AS SHE YELLED OBSCENITIES KICKED AND WIGGLED TO ESCAPE OUR GRASP. IT IS BELIEVED THAT SUFFICENT PROBABLE CAUSE IS CONTAINED IN THIS AFFIDAVIT TO ISSUE A WARRANT FOR THE ARREST OF LESLIE EDEN LAMP FOR DRIVING UNDER THE INFLUENCE OF ALCOHOL, PUBLIC DRUNKENESS AND DISORDERLY CONDUCT. •L_ Magisterial District Judge 02-3-05 DOCKET Jft Docket Number: TR-0002190-09 Traffic Citation Docket COMMONWEALTH OF PENNSYLVANIA T LAMP, LESLIE EDEN Page 1 of 1 WE INFORW"ON Judge Assigned: STOLTZFUS, ISAAC H Issue Date: 09/07/2009 OTN: File Date: 09/14/2009 Arresting Agency: EMBREEVILLE PSP Case Disp: Guilty By Trial Arresting Officer: TRUPP, JASON M Disp Date: 11/0612009 Complaint/Incident # R0562226-0 Requested: $0.00 County: LANCASTER Judgment: $0.00 Township: SALISBURY TWP Case Status: Adjudicated Name: LAMP, LESLIE EDEN Address: LEMOYNE, PA 17043 Date Of Birth: 12/31/1981 Sex: Female Race: # Charge Grade Description Disposition 1 75 § 1501 §§ A S DRIVING W/O A LICENSE Guilty Schedule Date Event Type Status 11/06/2009 10:00 AM Summary Trial GT % Total Due: $261.50 Total Adj: $0.00 Total Paid: $261.50 Balance: $0.00 e??Y'°`frh'f r"og low L , f Summons Date Summons Action 09/14/2009 SUMMONS ISSUED Name: TRUPP, JASON M 1200 Printed: 02/01/2010 10:36 am Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability asset forth in 18 Pa.C.S. Section 9183. NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF LESLIE E. LAMP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. GREG A. STAHL, : NO. 2006 - 5373 CIVIL Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, attorney for Plaintiff, do hereby certify that this date, I have served a copy of the foregoing Petition for Special Relfefupon the following the following parties, by United States Mail, addressed as follows: Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 (Counsel of Record for Plaintiff) Respectfully submitted, WOLF & WQU /I B// Na olf, Esquire 10 West High Street Carlisle, PA 17013 (717) 241-4436 Supreme Court I.D. No. 87380 Attorney for Defendant Date: February 1, 2010 'JAN 2 6-201%, LESLIE LAMP : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW GREG STAHL : NO. 06-5373 CIVIL TERM Defendant. : IN CUSTODY ORDER OF COURT AND NOW, this Z 7, day of ?Ja,,,,,•-, , 2009, upon consideration of Plaintiffs Petition for Special Relief and pending further order; it is hereby directed that Plaintiff shall exercise primary physical custody of Skate Stahl (D.O.B. March 19, 2001) subject to Father's periods of partial physical custody every other weekend from Friday after school to Sunday at 7:00 p.m. Mother may immediately enroll the child in Washington Heights Elementary. The parties shall continue to share legal custody. The PiaintifPsf. 'elrtivnfi+r SpeeialAefieFiF seEf^. ^•e-e.e- defy of 20 i9 en m The court administrator shall arrange this matter to be scheduled for conciliation. ?1ark F. Bayley, Esq. ? Greg Stahl - 235 N. Front Street, Newport, PA 17074 //27 f [d -fin. (25py BY THE COURT: -r Jrv f r. r' , F11 ... Z _ C, G r LESLIE LAMP IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. GREG STAHL 2006-5373 CIVIL ACTION LAW IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, _ Friday, January 29, 2010__ upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, February. 26, 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Hubert X. Ggro Es q. 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 .";i L' 2010 FEB - i i 1:: 6 Ile FEB a 1 2010 4-j LESLIE E. LAMP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. : NO. 2006 - 5373 CIVIL GREG A. STAHL, Defendant : IN CUSTODY ORDER OF COURT AND NOW this day of , 2010, upon consideration of the foregoing petition for special relief filed by the Defendant, the petition is hereby GRANTED and the following relief is ordered: (1) The Order dated January 27, 2009 [sic], which was issued January 27, 2010, is hereby VACATED. (2) Pending conciliation in this matter, Father shall have primary physical custody of the child, Skate Stahl (DOB March 19, 2001). (3) Mother shall have partial physical custody of the child on Tuesday evenings and alternating weekends from Friday after school until Sunday at 7:00 p.m. (4) The child shall be re-enrolled Newport Elementary School effective immediately. (5) The parties shall share legal custody of the child. (6) Should Mother deem necessary, the plaintiff/respondent in this action, shall file a petition to modify this Court's Order within 10 days of the date of this Order and the Court Administrator shall schedule this matter for an expedited custody conciliation. BY THE COURT: tribution: khan C. Wolf, Esquire for the Defendant ,,AVark F. Bayley, Esquire for the Plaintiff Court Administration ies a :L/ ltd HESS, P.J. ? N `r' l-i a. C LC MAR 0 Z 1U1U G,? LESLIE E. LAMP, Plaintiff IN THE COURT OF COMMON CUMBERLAND COUNTY, PEI }S OF 1LVANIA VS. GREG A STAHL, Defendant CIVIL ACTION - LAW NO. 2006-5373 IN CUSTODY COURT ORDER NOW, this Y' day of 2010, upon consic attached Custody Conciliation Report, it is ordered and directed that all prior custody in this case are vacated and replaced with this TEMPORARY Order: 1. The mother, Leslie E. Lamp, and the father, Greg A. Stahl, shall enjoy custody of Skate Alen Stahl, born March 19, 2001. 2. Physical custody shall be handled on a shared physical custody follows: A. The Mother shall have physical custody of the minor child on four weekends starting on Friday after school and ending on Mon( when the Mother shall return the child to school. In the event cannot get the child to school on time on Monday morning, N return the child to the Father on Sunday evening by 8:00 p.m. B. Mother shall also have custody every Tuesday from after Wednesday morning when the Mother shall return the child to scl if the Mother cannot get the child to school on Wednesday me appropriate time, the Mother shall return the child to the Father evening at 8:00 p.m. *a o 0 a = r?fi .c- am of the issued legal as out of ty mornmg he Mother other shall until 1. Again, ng at the Tuesday C. Father shall have physical custody of the minor child at times hat Mother does not enjoy custody as set forth above. 3. This is a TEMPORARY Order. The parties shall meet again for a custody conciliation conference on Friday, April 16, 2010, at 8:30 a.m. At that time and in the event the parties are unable to reach an agreement, the parties may advance any different position at a hearing before the Court. 4. The parents shall ensure that the child is only transported for exchange o custody by licensed drivers in vehicles which carry insurance. BY THE COURT, Kevin A/lIess, Judge cc: Mark F. Bayley, Esquire /Nathan C. Wolf, Esquire nn ? II I LESLIE E. LAMP, Plaintiff vs. GREG A STAHL, Defendant Prior Judge: The Honorable Kevin A. Hess IN THE COURT OF COMMON PLEjAS OF CUMBERLAND COUNTY, PENNS LVANIA CIVIL ACTION - LAW NO. 2006-5373 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject oft is litigation is as follows: Skate Alen Stahl, born March 19, 2001 2 A Conciliation Conference was held on February 26, 2010, with the following individuals in attendance: the mother, Leslie E. Lamp, with her counsel, Mark F. Bayley, squire, and the father, Greg A. Stahl, with his counsel, Nathan C. Wolf, Es uire. 3 Based upon the recommendation of the Conciliator, the parties agreed tq the entry of a TEMPORARY Order in the form as attached. Date: March -1-1 2010 HubeW X. Gil y, Esquire Custody Co iliator APR 2 0 2010 LESLIE E. LAMP, ; IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLV, ?ANZV ? VS. CIVIL ACTION - LAW z 'J"-1 C t> N GREG A STAHL, c: NO. 2006-5373 Defendant ? IN CUSTODY ti COURT ORDER C N NOW, this Z/ day of 14 oaet r , 2010, upon consideration of the attached Custody Conciliation Report, it is of ered and directed that all prior custody Orders issued in this case are vacated and replaced with the following Order: The mother, Leslie E. Lamp, and the father, Greg A. Stahl, shall enjoy shared legal custody of Skate Alen Stahl, born March 19, 2001. 2. Physical custody shall be handled on a shared physical custody arrangement as follows: A. The Mother shall have physical custody of the minor child on Monday and Tuesday to include the evenings, with father having physical custody of the minor child on Wednesday and Thursday to include the evenings overnight. B. The parties shall alternate custody on the weekends to include Friday, Saturday and Sunday overnight. =n 3. For purposes of school residence, the child shall be deemed to be residing with mother and the child shall attend school at the West Shore School District. 4. Pursuant to an agreement of the parties, the mother may claim the minor child as an exemption for purposes of federal income tax. 5. The parties shall share or alternate custody of the minor child on major holidays pursuant to a schedule as arranged between the parties. BY THE COURT, cc: Wk F. Bayley, Esquire /Nathan C. Wolf, Esquire LESLIE E. LAMP, Plaintiff VS. GREG A STAHL, Defendant Prior Judge: The Honorable Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-5373 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Skate Alen Stahl, born March 19, 2001 2. A Conciliation Conference was held on April 16, 2010, with the following individuals in attendance: The mother, Leslie E. Lamp, with her counsel, Mark F. Bayley, Esquire, and the father, Greg A. Stahl, with his counsel, Nathan C. Wolf, Esquire. 3. The parties agree to the entry of an Order in the form as attached. Date: April / 1 , 2010 Hubert X. Gilroy squire Custody Conci 'tor