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HomeMy WebLinkAbout06-6490ALYCIA P. REITEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006 - G y 9o CIVIL TERM DAVID MARK, CIVIL ACTION-LAW Defendant IN CUSTODY CUSTODY COMPLAINT 1. Plaintiff is Alycia Reiten, an adult individual who currently resides at 520 Highland Court, Carlisle, Cumberland County, Pennsylvania, 17013-3923. 2. Defendant is David Mark, an adult individual who currently resides at 1201 Villa Court South, Walled Lake, Oakland County, Michigan, 48390-3380. 3. The parties are the natural parents of a minor child, Brenden Mark, born July 22, 2000, age 6. The child was born in wedlock. The child is presently in the custody of Plaintiff at 520 Highland Court, Carlisle, Cumberland County, Pennsylvania, 17013-3923. During the past five years, the child has resided with the following persons at the following addresses: Persons Residences Dates Alycia P. Reiten 520 Highland Court June, 2005- Present Carlisle, Pennsylvania, 17013-3923 Alycia P. Reiten 109 Winchester Gardens Carlisle, Pennsylvania, 17013 May, 2004- June, 2005 Alycia P. Reiten 59380 Werden Aveune Mason, WI 54856 March, 2003 - May, 2004 Alycia P. Reiten 54630 Blake Avenue, #8 March, 2001 - March 2003 Grandview, WI 54839 David Mark 1201 Villa Court South June 2005 - Present Walled Lake, MI 48390 David Mark 3729 Warringham Road May, 2001 - June, 2005 Warksford, MI 48329 The natural father of the child is David Mark, currently residing at 1201 Villa Court, Walled Lake, Oakland County, Michigan, 48390-3380. He is not married to the Plaintiff. The natural mother of the child is Alycia P. Reiten, currently residing at 520 Highland Court, Carlisle, Cumberland County, Pennsylvania, 17013-3923. She is not married to the Defendant. 4. The relationship of the Plaintiff to the child is that of natural mother. The plaintiff currently resides with the following persons: Names Relationship Brenden Mark Son 5. The relationship of the Defendant to the child is that of natural father. The defendant currently resides with the following persons: Names Relationship Connie Mark Sharon Andrian Tiffany House Wife Mother-In-Law Stepdaughter Sinjin Belanger Stepdaughter 6. 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. 7. 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 visitation of the child will be given notice of the pendency of this action and the right to intervene: none. WHEREFORE, Plaintiff requests your Honorable Court to grant her primary physical custody of the child and give Defendant partial custody at such times as the parties agree. Respectfully submitted, Date: November 7 , 2006 O'BRIEN, BARIC & SCHERER XP4111?? Michael A. Scherer, Esquire I.D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff mas/Domestic/Reitenlcustody. com p I I Y T; ALYCIA P. REITEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006 - CIVIL TERM DAVID MARK, CIVIL ACTION-LAW Defendant VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. ti Date: November , 2006 Aly P. Reiten v Q ? ?o ALYCIA P. REITEN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DAVID MARK DEFENDANT 06-6490 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Tuesday, November 14, 2006 , 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 Tuesday, December 19, 2006 at 10:30 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/ ac ueline M. Verne 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 9 oC l4d c ! !,?0 9C,0? DEC is zoos ALYCIA REITEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-6490 CIVIL ACTION - LAW DAVID MARK, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 18'" day of December, 2006, being notified that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, m • V4"? ac eline M. Verney, Esquire, Cu y Conciliator I V" iutyf .i" ?' ,h{F iJ 9 Z E I NV 6 1 330 90oz />,,- ,IAN 2 3 2007 ALYCIA P. REITEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-6490 CIVIL ACTION - LAW DAVID MARK, Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of S y'i _ , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The prior Order of Court dated February 11, 2002 from Wisconsin is hereby vacated. 2. The Mother, Alycia P. Reiten and the Father, David Mark shall have shared legal custody of Brenden Mark, born July 22, 2000. 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 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. Father is cognizant of Brenden's peanut allergy and the health threat that it poses. 3. Mother shall have primary physical custody of the child. 4. Father shall have periods of partial physical custody as follows: A. In odd numbered years, from Easter Saturday to the following Sunday provided the child's spring break coincides with the Easter holiday. } t, . I: i J. ? f1r1 L I :Z ! SZ NIX L1231 _.. B. In 2007 from June 16, 2007 to July 4, 2007 and from August 3, 2007 to August 19, 2007. Father shall have similar periods in succeeding years and possibly more time if Brenden is ready for extended periods of time. C. In odd numbered years for the Christmas holiday from the Saturday before Christmas, provided he is off from school to December 31. In even numbered years from December 26 to December 31. D. Such other reasonable times as the parties agree. 5. Transportation shall be shared such that the parties will meet around Youngstown, Ohio at a place agreed by the parties. 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. cc: Michael A. Scherer, Esquire, Counsel for Mother David Mark, pro se 1201 Willa Court South Walled Lake, Michigan 48390-3380 0 ir ?, a?,?-7 ALYCIA P. REITEN, Plaintiff V. DAVID MARK, Defendant PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-6490 CIVIL ACTION - LAW : IN CUSTODY 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Brenden Mark DATE OF BIRTH CURRENTLY IN CUSTODY OF July 22, 2000 Mother 2. A Conciliation Conference was held in this matter on January 23, 2007, with the following in attendance: The Mother, Alycia P. Reiten, with her counsel, Michael A. Scherer, Esquire, and the Father, David Mark, by telephone, pro se. 3. There was a prior Order of Court dated February 11, 2002 from a court in Wisconsin providing for shared legal custody, Mother having primary physical custody and Father having periods of partial physical custody. Both parties agreed that the Order no longer applied. 4. The parties agreed to an Order in the form as attached. t-Z3-o7 Date A4. V acq line M. Verney, Esquire Custody Conciliator Michael A. Hynum, Esquire Supreme Court ID #85692 2608 North 3rd Street Harrisburg, PA 17110 (717) 7741357 Attorney for Defendant ALYCIA P. REITEN, Plaintiff vi. DAVID MARK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODYNISITATION NO. 06-6490 PETITION TO MODIFY ORDER OF CUSTODY AND NOW, Defendant, by and through his counsel, Michael A. Hynum, Esquire, files a Petition to Modify Order of Custody, and in support thereof, avers the following: 1. Petitioner is David Mark (Father), who currently resides at 2622 Watonga Drive, Commerce Township, Michigan 48382. 2. Respondent is Alycia P. Reiten (Mother), who currently resides at 263 South Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties hereto are the parents of the following minor child, who currently resides at 263 South Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013: Brenden Mark, born July 22, 2000, age 8 years 4. On January 24, 2007, this Honorable Court entered an Order of Court granting the parties shared legal custody of their child, primary physical custody to Respondent and partial physical custody to the Petitioner. A true and correct copy of this Order is marked Exhibit "A", attached hereto and made a part hereof. 5. The best interests and permanent welfare of the parties' child will be served by a modification of the Court's Order for the following reasons: (a) The current Order in paragraph 4-13 states that it would be possible for father to have more time with Brenden if Brenden is ready for extended periods of time. (b) Brenden's Father (Petitioner) believes that Brenden is ready for extended periods of time and would like additional time with Brenden. WHEREFORE, Petitioner respectfully requests that this Honorable Court modify its Order as follows: (1) change visitation to allow Father to have visitation with Brenden over Brenden's summer vacation from one week after school ends in the spring until one week before school begins in the fall; (2) provide for Father's visitation with Brenden each year during Easter or spring break from school; (3) provide for exchange of custody on Saturday so as to coordinate with father's work schedule; and (4) provide for both Mother and Father to share in provision of and/or cost of transportation for exchanges of custody. Respectfully submitted, f Michael A. Hynum, Esqui e Date: Z/ Z 3' Supreme Court ID #85692 1 2608 North 3`d Street Harrisburg, PA 17110 (717) 774-1357 Attorney for Petitioner Rx Date/Time FEB-23-2009(MON) 11:31 P. 002 F e b. 23. 2009 10: 33AM No. 7984 P. 2 I, DAVID MARK, verify that ft statements owwalned Ih the b,%Wnp iPETITON TO MODIFY CUSTODY are true and .corrw to the be# of my knee, k tormaboin and beaef. I undemumd that false dotalwts containied therein are made sWect to the penalties of 18 Pa.C.S. Sscwon 4M r lo% to uftwom falsification to sut rifts. Rata, , ? cn% David Msrk EXHIBIT "A" N 33 & ALYCIA P. REIT EN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-6490 CIVIL ACTION - LAW DAVID MARK, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this _Art_ day of , 2007. upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated February 11, 2002 from Wisconsin is hereby vacated. 2. The N.lother, Alycia P. Reiten and the Father. David Mark shall have shared legal custody of Brenden Mark. born JulN 22.2000. Fach parent shall have ate equal right. to be exercised;ointlti with the other parent. to make all major non- emergency decisions affecting the C'hill's general we'll-being including, but not limited to. III dtt&zinns regarding bi% health. cdacatinn anti religion. Pursuant to the terms or Pa.C.S. §5304, each parent shall be entitled to all records and Infortuation pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetioss and evaluations with regard to the minor child. Each parent shall be entitled to fiill and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. Father is cognizant of Brendcn's peanut allergy and the health threat that- it poses. Mother shall have primary physical custody of the child. 4. Father shall have periods of partial physical custody as follows: A. In odd numbered years, from Easter Saturday to the following Sunday provided the child's spring break coincides with the Faster holiday. B. In 2007 from June ib, 2007 to July 4, 2407 and from August 3, 2007 to August 19, 2007. Father, shall have similar periods in succeeding; years and possibly more time if Brenden is ready for extended periods of time. C. In odd numbered years for the Christmas bohiday from the Saturday before Christmas, provided he is off from school took ember 3l . In even numbered years from December 26 to 3 1. D. Such other reasonable times as the parties agree. j_ Transportation shall be shared such that the parties will meet around Youngstown, Ohio at a place agreed by the parties. 6. This Order is entered pursuant to an a9reemcnt of the parties at a Custodv Conciliation Conference. The parties may modify the provisions Order t i Order by mutual consent. In the absence of mutual consent, the terms of this BY THE COURT. 4 I. cc. Nlichacl A. Scherer, Esquire, Counsel for Mother David Mark, pro se 1201 Willa Court South Walled Lake. Michigan 48390-3390 rFM C*PY ROM me, la Ttwherop?,'I MNr1f?Ma rRy h??: MW tAe of 3atld at ?,. ; -a Qc -7, CERTIFICATE OF SERVICE On this 23rd day of FEBRUARY, 2009, I certify that a copy of the foregoing PETITION TO MODIFY CUSTODY was served upon the following party by placing the same in the United States mail, first class, addressed as follows: Alycia P. Reiten 263 South Pitt Street Carlisle, PA 17013 L /(- (ze'? Zn Michael A. Hynum, Esqui(k Hynum Law 2608 North 3rd Street Harrisburg, PA 17110 9z SU .G 00 tia ) ALYCIA P. REITEN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2006-6490 CIVIL ACTION LAW DAVID MARK IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, February 27, 2009 , 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, March 26, 2009 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/ ac ueline 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 *W AlkV P4 "V - 447 r-P r4w ;Z -40- -www,5, Ir.ww4V -,,tV ' E? Z- ?vw MAR 27 20ABg ALYCIA P. REITEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-6490 CIVIL ACTION - LAW DAVID MARK, Defendant/Petitioner : IN CUSTODY ORDER OF COURT AND NOW, this day of _M v G.L , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. of the Cumberland County Court House, on the &Z day of , 2009, atZ 30 o'clock, 4. M., at which time testimony wil be taken. For purposes of this Hearing, Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel 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. Pending further Order of Court or agreement of the parties, the prior Order of Court dated January 24, 2007 shall remain in full force and effect with the following modifications. 3. Father shall have physical custody of the child in the summer from June 16, 2009 to Sunday, July 5, 2009 and from Saturday, July 25, 2009 to Saturday, August 15, 2009. 4. Father shall have physical custody of the child over Christmas break as indicated in the prior Order, except that Father's end day shall be the Saturday before school starts. 5. 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, / J. esley Oler, Jr cc: lhchael A. Hynum, Esquire, counsel for Fa er Michael A. Scherer, Esquire, counsel for Mother COP 11W en"LtLfjc?-, 2 P y9 ryf v ? t ?y tt J ? 'r l?r?k! t A8V ALYCIA P. REITEN, Plaintiff/Respondent V. DAVID MARK, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-6490 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., 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 Brenden Mark July 22, 2000 Mother 2. A Conciliation Conference was held March 26, 2009 with the following individuals in attendance: The Father, David Mark, with his counsel, Michael A. Hynum, Esquire, and the Mother, Alycia P. Reiden, with her counsel, Michael A. Scherer, Esquire. 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court dated January 24, 2007 providing for shared legal custody, Mother having primary physical custody and Father having periods of partial physical custody during the Easter break, the Christmas break and 5 weeks in the summer. 4. Father's position on custody is as follows: Father seeks shaved legal and additional periods of partial physical custody in the summer, one week after school ends until one week before school begins. Father maintains that the child is ready to spend additional time with him in Michigan. 5. Mother's position on custody is as follows: Mother seeks shared legal custody and primary physical custody, with Father having periods of partial physical custody over the Easter holiday, the Christmas holiday and summer vacation. Mother disagrees with the amount of weeks Father should have in the summer, alleging that the child is not ready to stay with Father the entire summer. Mother is willing to add one additional week and see how the child reacts. She maintains that the child is bored while at Father's because Father does not provide any structured activity. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and providing Father with one additional week in the summer. It is expected that the Hearing will require one-half day. 3 -a4 -07 ( _?? ? ? A1, ] Date acq ine M. Verney, Esquire Custody Conciliator ALYCIA P. REITEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DAVID MARK, Defendant NO. 06-6490 CIVIL TERM IIN RE: PETITION FOR CUSTODY ORDER OF COURT AND NOW, this 0, day of April, 2009, upon agreement of the parties, the hearing previously scheduled in the above matter for June 11, 2009, is rescheduled to Tuesday, June 2, 2009, at 1:30 O.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. -Nlichael A. Scherer, Esq. Attorney for Plaintiff ,40fichael A. Hynum, Esq. Attorney for Defendant J rc BY THE COURT, !f:ZWJ 6-M6981 ALYCIA P. REITEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DAVID MARK, IN CUSTODY Defendant 2006-6490 CIVIL TERM ORDER OF COURT AND NOW, this 2nd day of June, 2009, upon consideration of Defendant's Petition To Modify Order of,Custody with respect to the parties' child, Brenden Mark (date of birth July 22, 2000), and pursuant to an agreement reached between the parties in open court and their respective counsel, Michael A. Scherer, Esquire, on behalf of the Plaintiff, and Michael A. Hynum, Esquire, on behalf of the Defendant, it is ordered and directed as follows: The prior orders in this matter dated January 24, 2007, and March 27, 2009, shall remain in full force and effect subject to the following modification which shall supercede the language in the prior orders relative to the summer custody schedule: For the summer of 2009, father shall have physical custody of the child beginning on June 20, 2009, and ending on July 11, 2009. In addition, father shall have the period of July 25, 2009, to August 15, 2009. For the summer of 2010, father shall have the period from June 12, 2010, until July 3, 2010. Additionally, the father shall have the period of July 17, 2010, until August 14,2010. The parties are permitted to modify the terms of any of the existing orders of Court provided both parties are in agreement with said modifications. By the Court, J. /Wesley Ole t/, Jr., J. Michael A. Scherer, Esquire /For the Plaintiff ? Michael A. Hynum, Esquire For the Defendant pcb pt?ES ,atLC 1 --T/11 FILED-0 'F1Cl OF THE 2009 JUN 12 PM 2: 59 ?,1.??•,??h554y} ?, Fi..'y?'f? 1,17 -i