Loading...
HomeMy WebLinkAbout02-2721MITCHELL LINDSEY Plaintiff V KAREN LINDSEY Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : : :CIVIL ACTION - LAW :CUSTODY ACTION COMPLAINT FOR CUSTODY The plaintiffis Mitchell Lindsey, residing at 1351 Zimmerman Road, Carlisle, Pennsylvania 17013. The defendant is Karen Lindsey, residing at 211 Fern Avenue, Carlisle, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: Name Present Residence D/O/B Age Cameron Lindsey 211 Fern Avenue 8/25/94 7yrs 9moths Carlisle, PA 17013 The child was not bom out of wedlock. The child is presently in the custody ofKaren Lindsey who resides at 211 Fern Avenue, Carlisle, PA 17013. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons Karen Lindsey Mitchell and Karen Lindsey List All Addresses 211 Fern Avenue Carlisle, PA 17013 1351 Zimmerman Road Carlisle, PA 17013 Dates Apr. 98-presem Aug. 94-Apr. 98 The mother of the child is Karen Lindsey, currently residing at 211 Fern Avenue Carlisle, PA 17013. She is single. The father of the child is Mitchell Lindsey, curremly residing at 1351 Zimmerman Road Carlisle, PA 17013. He is married. 4. The relationship ofplaintiffto the child is that of Father. The plaintiffcurremly resides with the following persons. Name Relationship Seleena Lindsey Spouse 5. The relationship of defendant to the child is that of Mother. The defendant currently resides with the following persons. Name Relationship Cameron Lindsey Son Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiffhas no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plalntiffdoes not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief requested. 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 have been given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim WHEREFORE, plaintiff requests the court to grant Primary Physical custody of the child. Date: Respectfully Submitted, Mark F. Bayley, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID# 87663 Attorney for Plaintiff VERIFICATION I verify that the statements made in this complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Mit~c~!H L~ds c~y,~ p1 ·~ MITCHELL LINDSEY : PLAINTIFF V. : 02-2721 KAREN LINDSEY DEFENDANT : IN CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND NOW, Tuesday, June 11, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jaequeline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, July 09, 2002 at 2:30 PM for a Pre-Heating 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 aisc 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/ facqueline M. Verney. Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 JUL 1 MITCHELL LINDSEY, Plaintiff KAREN LINDSEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-2721 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this _//_7_~ day of ~.~ ,2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Mitchell Lindsey, and the Mother, Karen Lindsey, shall have shared legal custody of Cameron Lindsey, born August 25, 1994. Each parent shall have an equal right, to be exemised 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. 2. Mother shall have primary physical custody of the Child. 3. Beginning July 19, 2002, Father shall have the following periods of partial physical custody of the Child: II. During the months that Father has Mondays and Tuesdays off.' a. During summer vacation: alternating weekends from Friday at 7:00 p.m. to Tuesday at 7:00 p.m. b. During summer vacation: on the off week from Sunday at 7:00 p.m. to Tuesday at 7:00 p.m. c. During the school year: alternating weekends from Friday at 7:00 p.m. to Tuesday at 7:00 p.m. d. During the school year: on the off week Monday and Tuesday evenings from after school to 8:00 p.m. During the months that Father has Thursdays and Fridays off: a. During summer vacation: alternating weekends from Wednesday at 7:00 p.m. to Sunday at 7:00 p.m. b. During summer vacation: on the off week from Wednesday at 7:00 p.m. to Friday at 7:00 p.m. c. During the school year: alternating weekends from Wednesday at 7:00 p.m. to Sunday at 7:00 p.m. d. During the school year: on the off week, Wednesday and Thursday after school to 8:00 p.m. ¥tNVAI~$NN3d LU :8 !,)~ ~ I 'If'IF ......... O-l.~ 4. Each party shall be entitled to two (2) non-consecutive weeks during the year provided they give the other parent 30 days prior notification. 5. If either party remove the Child from the jurisdiction of Cumberland County, Pennsylvania, they must notify the other parent and provide an address and telephone number where the Child can be reached. 6. Mother shall have physical custody of the Child on Mother's Day from 9:00 a.m. to 7:00 p.m. Father shall have physical custody of the Child on Father's Day from 9:00 a.m. to 7:00 p.m. 7. The parties shall alternate the following holidays: Labor Day, Memorial Day and July 4th from 9:00 a.m. to 9:00 p.m. Father shall have physical custody of the Child on Labor Day, 2002. 8. The Thanksgiving holiday shall mn from the Wednesday before the holiday after school to the Friday after the holiday at 7:00 p.m. The parties shall alternate the Thanksgiving holiday. Father shall have physical custody of the Child in 2002. 9. The Christmas holiday shall be split such that Mother shall always have physical custody of the Child on Christmas Eve until 10:00 p.m. and Father shall always have physical custody of the Child from Christmas Eve at 10:00 p.m. to Christmas Day until 2:00 p.m. The remainder of the Christmas holiday break from school shall revert to the summer schedule listed in Paragraph 3 above. 10. Transportation shall be shared by the parties such that the receiving party shall pick up the Child at the other parent's home. There shall beno contact between the parties at these exchanges. The receiving party shall park at the curb and the other party shall send the Child out of the house to the car. 11. Neither party shall consume alcohol to the point of intoxication while the Child is in their physical custody. 12. Both parties shall have liberal telephone contact with the Child. 13. 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 TH~COURT, cc: Mark F. Bayley, Esquire, Counsel for Father Thomas Diehl, Esquire, Counsel for Mother/ ,tUL ! ! 2002 MITCHELL LINDSEY, Plaintiff KAREN LINDSEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 2002-2721 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCll,IATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Cameron Lindsey DATE OF BIRTH CURRENTLY IN CUSTODY OF August 25, 1994 Mother 2. A Conciliation Conference was held in this matter on July 9, 2002, with the following individuals in attendance: The Father, Mitchell Lindsey, with his counsel, Mark F. Bayley, Esquire and Mother, Karen Lindsey, with her counsel, Thomas Diehl, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date ~'acqtl~line M. Vemey, Esquire Custody Conciliator MITCHELL LINDSEY, Plaintiff KAREN LINDSEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-2721 CIVIL TERM : CIVIL ACTION - LAW : : IN CUSTODY PETITION FOR CONTEMPT AND NOW, comes Mitchell Lindsey, by and through his attomey, Mark F. Bayley, Esquire, and in support of this Petition avers as follows: 1. Petitioner has not been allowed to exercise his custodial rights as outlined in the July 22, 2002 Custody Order executed by the Honorable Judge Kevin A. Hess. (Attached as Exhibit "A".) 2. In particular, Respondent has refused to mm over the child during Mr. Lindsey's periods of visitation. 3. The Respondent is constantly late at transfers, which often interferes with Mr. Lindsey's ability to schedule. 4. The Respondent is otherwise resistant to abide by the Order in general, and has no interest in facilitating Mr. Lindsey's relationship with the child. 5. Petitioner is entitled to attorney fees from Respondent regarding legal expenses incurred from this Petition. 6. Petitioner is entitled to make up time for days which Respondent refused to follow said Court Order with regard to visitation. 7. Petitioner is entitled to all other appropriate relief to be determined by the Court. WHEREFORE, Petitioner requests that this Honorable Court find the Respondent in contempt of a Court Order and grant all proper and just relief, including attorney fees regarding this Petition. Respectfully submitted, ROMINGER & BAYLEY Mark F. Bayley, Esquire 155 S. Hmmver Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 87663 Attorney for Petitioner 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. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Mit~chell Lindsey, Plaintiff CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Petitioner, do hereby certify that I this day served a copy of the Petition for Contempt upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Karen Lindsey 211 Fern Avenue Carlisle, PA 17013 Dated: Mark F. Bayley, Esquire Attorney for Petitioner , Ul 1 ] 2002 MITCHELL LINDSEY, Plaintiff V. KAREN LINDSEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-2721 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this II-'~c~' day of ~ ,2002, upon consideration of the attached Custody Conciliati%n R~'port, it is ordered and directed as follows: 1. Thc Father, Mitchell Lindsey, and the Mother, Karen Lindscy, shall have shared legal custody of Cameron Lindsey, bom August 25, 1994. 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. 2. Mother shall have primary physical custody of the Child. 3. Beginning July 19, 2002, Father shall have 'the following periods of partial physical custody of the Child: I. During the months that Father has Mondays and Tuesdays off: a. During summer vacation: alternating weekends from Friday at 7:00 p.m. to Tuesday at 7:00 p.m. b. During summer vacation: on the offweek from Sunday at 7:00 p.m. to Tuesday at 7:00 p.m. c. During the school year: alternating weekends from Friday at 7:00 p.m. to Tuesday at 7:00 p.m. d. During the school year: on the off week Monday and Tuesday evenings from after school to 8:00 p.m. II. During the months that Father has Thursdays and Fridays off: a. During summer vacation: alternating weekends from Wednesday at 7:00 p.m. to Sunday at 7:00 p.m. b. During summer vacation: on the offweek ii'om Wednesday at 7:00 p.m. to Friday at 7:00 p.m. c. During the school year: alternating weekends from Wednesday at 7:00 p.m. to Sunday at 7:00 p.m. d. During the school year: on the offweek, Wednesday and Thursday after school to 8:00 p.m. 4. Each party shall be entitled to two (2) non-consecutive weeks during the year provided they give the other parent 30 days prior notification. 5. If either party remove the Child from the jurisdiction of Cumberland County, Pennsylvania, they must notify the other parent and provide an address and telephone number where the Child can be reached. 6. Mother shall have physical custody of the Child on Mother's Day from 9:00 a.m. to 7:00 p.m. Father shall have physical custody of the Child on Father's Day from 9:00 a.m. to 7:00 p.m. 7. The parties shall alternate the following holidays: Labor Day, Memorial Day and July 4th from 9:00 a.m. to 9:00 p.m. Father shall have physical custody of the Child on Labor Day, 2002. 8. The Thanksgiving holiday shall mn from the Wednesday before the holiday after school to the Friday after the holiday at 7:00 p.m. The parties shall alternate the Thanksgiving holiday. Father shall have physical custody of the Child in 2002. 9. The Christmas holiday shall be split such that Mother shall always have physical custody of the Child on Christmas Eve until 10:00 p.m. and Father shall always have physical custody of the Child from Christmas Eve at 10:00 p.m. to Christmas Day until 2:00 p.m. The remainder of the Christmas holiday break from school shall revert to the summer schedule listed in Paragraph 3 above. 10. Transportation shall be shared by the parties such that the receiving party shall pick up the Child at the other parent's home. There shall be.no contact between the parties at these exchanges. The receiving party shall park at the curb and the other party shall send the Child out of the house to the car. 11. Neither party shall consume alcohol to the point of intoxication while the Child is in their physical custody. 12. Both parties shall have liberal telephone contact with the Child. 13. 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: Mark F. Bayley, Esquire, Counsel for Father Thomas Diehl, Esquire, Counsel for Mother TRUE COPY FROM RECORD, In Tes'Hmony whereof, I here unto set my' and the seal of said Court at Carlisle, Pa. · /.~L~ _~ oo-.~--~ Th~s "75 ......... d? of .~. Prothonotary 2002 MITCHELL LINDSEY, Plaintiff V. KAREN LINDSEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2002-2721 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY 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: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Cameron Lindsey DATE OF BIRTH August 25, 1994 CURRENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on July 9, 2002, with the following individuals in attendance: The Father, Mitchell Lindsey, with his counsel, Mark F. Bayley, Esquire and Mother, Karen Lindsey, witla her counsel, Thomas Diehl, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date ~'acq~line M. Vemey, Esquire Custody Conciliator MITCHELL LINDSEY PLAINTIFF V. KAREN LINDSEY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 02-2721 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, Tuesday, August 05, 2003 , 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 Wednesday, Sel~tember 03, 2003 at 3:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ facqueline M. Verney, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans w/th 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 21:IE 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 MITCHELL LINDSEY, Plaintiff V. KAREN LINDSEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-2721 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT / AND NOW, this .~' day of J',e,~ ~ ,2003, upon consideration of the attache~ustody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated July 11, 2002 shall remain in full force and effect with the following additions: 2. Father's Petition for Contempt shall be held in abeyance. 3. In the event that either party intends to be out of the area overnight, they shall contact the non-custodial parent in a timely manner and offer the time to the non- custodial parent. 4. The parties shall initiate communication counseling with a counselor mutually agreed upon by the parties. The Child shall be included in the counseling when the counselor deems appropriate. 5. Neither parent will do anything nor permit a third party to do anything which may estrange the Child from the other party, or injure the opinion of the Child as to the other parent or which may hamper the free and natural development of the Child's love and respect for the other parent. 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'~mhael Whare, Esquire, Counsel for Fathe/ t~omas Diehl, Esquire., Counsel for Moth6r o9 MITCHELL LINDSEY, Plaintiff Vt KAREN LINDSEY, Defendant PRIOR JUDGE: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2002-2721 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY .CUSTODY CONCILIATION SUMMARY REPOR IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits thc following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Cameron Lindsey DATE OF BIRTH August 25, 1994 CURRENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on September 3, 2003, with the following individuals in attendance: The Father, Mitchell Lindsey, with his counsel, Michael Whare, Esquire and Mother, Karen Lindsey, with her counsel, Thomas Diehl, Esquire. 3. The Honorable Kevin A. Hess entered a prior Order of Court dated July 11, 2002 providing for shared legal custody, with Mother having primary physical custody and Father having partial physical custody. 4. Father filed a Petition for Contempt claiming that Mother delivered the child consistently late and refused to turn over the child one weekend. Father agreed to hold the contempt allegations in abeyance. Date The parties agreed to the entry of an Order in the form as attached. ~Jacqff~line M. Verney, EM d3 Custody Conciliator MITCHELL LINDSEY, Plaintiff VS, KAREN LINDSEY, Defendant ,N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002-2721 CIVIL TERM IN CUSTODY PETITION TO MODIFY AND NOW comes the above-named Plaintiff, by his attorney, Samuel L. Andes, and petitions the court to modify its prior order of custody in this matter, entered on 11 July 2002, based upon the following: 1. The Petitioner herein is the Plaintiff, Mitchell L. indsey, who resides at 1351 Zimmerman Road in Carlisle, Pennsylvania 17013. 2. The Respondent herein is the Defendant, Karen Lindsey, who resides at 211 Fern Avenue in Carlisle, Pennsylvania 17013 and who is, to Plaintiff's knowledge, represented by Thomas Diehl, Esquire. 3. The parties are the parents of one minor child, Cameron M. Lindsey, born 25! August 1994. 4. The child is the subject of a prior order of this court, dated 11 July 2002, a copy of which is attached hereto and marked as Exhibit A. That order was entered following a conciliation conference before Jacqueline M. Verney, Esquire. 5. Since the entry of the last order, circumstances regarding the child have changed which make a modification of the order appropriate and beneficial. The child is older, the Plaintiff's has changed so that he is in a better position to care for the child while in his custody, and the mother's situation has deteriorated. Moreover, mother's conduct in criticizing father and his home and family, is estranging the child from the father and disrupting the father's relationship with the child. As a result of these changes, Plaintiff seeks a modification of the order to grant him shared legal custody, both legal and physical, of the child. 6. Plaintiff also believes that the parties, the child, and the court will benefit from a psychological evaluation of all of the parties and the members of their household. Plaintiff believes the court should have that information to make an informed decision on this Petition. 7. The best interest of the child will be served by an order granting the relief requested by Plaintiff in this Petition. WHEREFORE, Plaintiff prays this court to order the parties and the members of their household to submit to a psychological or custody evaluation and to modify the terms of its prior order to grant both parents equal shared physical and legal custody of the child. SamUel I-. ~,nd~'~ Attorney for Plaintiff Supreme Court ID # 17225 525 North 1 2th Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Petition are true and correct. I understand that any false statements in this Petition are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: MI~CH~:LL LINDSEY / MITCHELL LINDSEY, Plaintiff V. KAREN LINDSEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-2721 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY ORDER OFCOURT AND NOW, this I1 ;l~ day of ~rv~C.- consideration of the attached Custody Conciliation Report, tbllows: · 2002, upon it is ordered and directed as 1. The Father, Mitchell Lindsey, and the Mother, Karen Lindsey, shall have shared legal custody of Cameron Lindsey, bom August 25, 1994. 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. 2. Mother shall have primary physical custody of the Child. 3. Beginning July 19· 2002, Father shall have the following periods of partial physical custody of the Child: I. During the months that Father has Mondays and Tuesdays off: a. During summer vacation: alternating weekends from Friday at 7:00 p.m. to Tuesday at 7:00 p.m. b. During summer vacation: on the offweek from Sunday at 7:00 p.m. to Tuesday at 7:00 p.m. c. During the school year: alternating weekends from Friday at 7:00 p.m. to Tuesday at 7:00 p.m. d. During the school year: on the off week Monday and Tuesday evenings from after school to 8:00 p.m. II. During the months that Father has Thursdays and Fridays off.' a. During summer vacation: alternating weekends from Wednesday at 7:00 p.m. to Sunday at 7:00 p.m. "~ b. During summer vacation: on the offweek frmn Wednesday at 7:00 p.m. to Friday at 7:00 p.m. c. During the school year: alternating weekends from Wednesday at 7:00 p.m. to Sunday at 7:00 p.m. d. During the school year: on the offweek, Wednesday and Thursday after school to 8:00 p.m. 4. Each party shall be entitled to two (2) non-consecutive weeks during the year provided they give the other parent 30 days prior notification. 5. If either party remove the Child from the jurisdiction of Cumberland County, Pennsy vania they nmst notify the other parent and provide an address and telephone number where the Child can be reached. 6. Mother shall have physical custody of the Child on Mother's Day from 9:00 a.m. to 7:00 p.m. Father shall have physical custody of the Child on Father's Day from 9:00 a.m. to 7:00 p.m. 7. Tile parties shall alternate the following holidays: Labor Day, Memorial Day and July 4th from 9:00 a.m. to 9:00 p.m. Father shall have physical custody of the Child on Labor Day, 2002. 8. 'fhe Thanksgiving holiday shall run from the Wednesday before the holiday after school to the Friday after the holiday at 7:00 p.m. The parties shall alternate the Thanksgiving holiday. Father shall have physical custody of the Child in 2002. 9. The Christmas holiday shall be split such that Mother shall always have physical custody of the Child on Christmas Eve until l 0:00 p.m. and Father shall always have physical custody of the Child from Christmas Eve at 10:00 p.m. to Christmas Day until 2:00 p.m. The remainder of the Christmas holiday break from school shall revert to the summer schedule listed in Paragraph 3 above. I 0. Transportation shall be shared by the parties such that the receiving party shall pick up the Child at the other parent's home. There shall be.no contact between the parties at these exchanges. The receiving party shall park at the curb and the other party shall send the Child out of the house to the car. 1 I. Neither party shall consume alcohol to the point of intoxication while the Child is in their physical custody. 12. Both parties shall have liberal telephone contact with the Child. 13. 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: Mark F. Bayley, Esquire, Counsel for Father Thomas Diehl, Esquire, Counsel for Mother cz. J. TRUE COPY FROM RECORD In Testimony whereof, I here unto set mt' h~n~ j ~nd the seal of said Court at Carlisle, Pa. · ! Jh,s ............ ~ ~ ............... ~ ....... ~ .......... ~ ....... Pr t onbt 2002 MITCHELL LINDSEY, Plaintiff V. KAREN LINDSEY, Defend:mt PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 2002-2721 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information conceming the Child who is the subject of this litigation is as follows: NAME Cameron Lindsey DATE OF BIRTH August 25, 1994 CURRENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on July 9, 2002, with the following individuals in attendance: The Father, Mitchell Lindsey, with his counsel, Mark F. Bayley, Esquire and Mother, Karen Lindsey, with her counsel, Thomas Diehl, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. q-Il Date remey, E~squi~re Custody Conciliator MITCHELL LINDSEY PLAINTIFF V. KAREN L1NDSEY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 02-2721 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, October 16, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the concili at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, November 18, 2003 at 8:30 for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; if this cannot be accomplished, to de£me and narrow the issues to be heard by the court, and to enter into a temporal order. All children age five or older may also be present at the conference. Failure to ap~oear at the conference ma 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 hearinl/. FOR THE COURT, ttor, M )r By: /s/ Jacqueline M. Verney, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the American 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 schedule{] conference or hear/ng. / 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 Stree~l Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 MITCHELL LINDSEY, Plaintiff KAREN LINDSEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2721 CIVIL TERM IN CUSTODY TO THE PROTHONOTARY: PRAECIPE WITHDRAWAL OF APPEARANCE Please withdraw my appearance on behalf of the Plaintiff in the above-captioned matter. Date: Respe~ct.J~_~l_~ submitted, Th~m~s S. Diehl, EsquireXx.._ -l'West High Street P.O. Box 1290 Carlisle, PA 17013 ENTRY OF APPEARANCE Please enter my appearance on behalf of the Plaintiff in the above-captioned matter. Respectfully submitted, Date: GRIFF1E & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 MITCHELL LINDSEY, Defendant/Respondent VS. KAREN LINDSEY, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-2721 CIVII., ACTION - LAW 1N CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW, comes the above-named Plaintiff, Karen Lindsey, by and through his attorney, Brian C. Bornman, Esquire, and the law firm of Griffie & Associates and petitions the Court as follows: 1. Your Petitioner is the above-named Plaintiff, Karen Lindsey, an adult individual currently residing at 211 Fern Avenue, Carlisle, Cmnberland County, Pennsylvania. 2. Your Respondent is the above-named Defendant, Mitchell Lindsey, an adult individual currently residing at 1351 Zimmerman Road, Carlisle, Cumberland County, Pennsylvania. 3. The parties are the natural parents of one child, namely, Cameron M. Lindsey, bom August 25, 1994. 4. The parties are subject to an Order of Court which ,vas entered by agreement on July 11, 2002, a copy of which is attached hereto and incorporated herein by reference as Exhibit "A." 5. Since the entry of the aforementioned Order, Respondent has failed to utilize the periods of time during which he has the child in his .custody and has instead chosen to place the child in the care of other providers. Further, the child has expressed a desire to spend less time with Respondent. 6. Petitioner believes and, therefore, avers that the above-mentioned child would benefit from spending less time with Respondent. 7. Respondent had previously filed a Petition for Modification of Custody in this matter. A conciliation in this matter is presently scheduled before Jacqueline M. Verney, Conciliator, on January 20, 2004, at 9:30 a.m. WHEREFORE, Petitioner requests your Honorable Court to schedule this Petition for Modification to be heard concurrently with the conciliation in this matter, which is scheduled for January 20, 2004, at 9:30 a.m. and to enter an Order reducing the amount of time that the child is required to spend with Respondent. Respectfully submitted, Date Brian C. Bornman, Esquire Attorney for Defendant/Petitioner Supreme Court ID # 89105 GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243<5551 (800) 347-:5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworu falsifications to authorities. MITCHELL LINDSEY, Plaintiff V. KAREN LINDSEY, Defendant : 1N THE COURT OF COMMON PLEAS OF · ' CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-2721 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT A AND NOW. this II;O~ dayof cons~dcratmn of the attached Custody Concflmtion Report, tbllows: ,2002, upon it is ordered and directed as 1. The Father, Mitchell Lindsey, and the Mother, Karen Lindsey, shall have shared legal cnstody of Cmneron Lindsey, bom Aogust 25, 1994. 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.. 2. Mother shall have prirnary physical custody of the Child. 3. Beginning July 19, 2002, Father shall have the following periods of partial physical custody of the Child: I. During the months that Father has Mondays and Tuesdays off: a. During summer vacation: alternating weekends from Friday at 7:00 p.m. to Tuesday at 7:00 p.m. b. During summer vacation: on the offweek from Sunday at 7:00 p.m. to ~' Tuesday at 7:00 p.m. c. During the school year: alternating weekends from Friday at 7:00 p.m. to Tuesday at 7:00 p.m. d. During the school year: on the off week Monday and Tuesday evenings from after school to 8:00 p.m. II. During the months that Father has Thursdays and Fridays off: During summer vacation: alternating weekends from Wednesday at 7:00 p.m. to Snnday at 7:00 p.m. During summer vacation: on the off week from Wednesday at 7:00 p.m. to Friday at 7:00 p.m. During the school year: alternating weekends from Wednesday at 7:00 p.m. to Sunday at 7:00 p.m. During the school year: on the off week, Wednesday and Thursday after school to 8:00 p.m. 4. Each party shall be entitled to two (2) non-consecutive weeks during the year provided they give the other parent 30 days prior notitlcatlon. 5. If either party remove the Child from the jurisdiction of Cumberland County, Pennsylvania, they must notify the other parent and provide an address and telephone number where the Child can be reached. 6. Mother shall have physical custody of the Child on Mother's Day from 9:00 a.m. to 7:00 p.m. Father shall have physical custody of the Child on Father's Day from 9:00 a.m. to 7:00 p.m. 7. The parties shall alternate the following holidays: Labor Day, Memorial Da.',, and July 4 tro n 9 00 a.m. to 9:00 p.m. Father shall have physical custody of the Clfild on Labor Day, 2002. 8. The Thanksgiving holiday shall run from the Wednesday before the holiday after school to the Friday after the holiday at 7:00 p.m. The parties shall alternate the Thanksgiving holiday. Father shall have physical custody of the Child in 2002. 9. The Christmas holiday shall be split such that Mother shall always have physical custody of the Child on Christmas Eve until 10:00 p~m. and Father shall always have physical custody of the Child from Christmas Eve at 10:00 p.m. to Christmas Day until 2:00 p.m. The remainder of the Christmas holiday bre. ak from school shall revert to the summer schedule listed in Paragraph 3 above. 10. Transportation shall be shared by the parties such that the r~ceiving party shall pick up the Child at the other parent's home. There shall be.no contact between the parties at these exchanges. The receiving party shall park at the curb and the other party shall send the Child ont of the house to the car. 1 I. Neither party shall consume alcohol to the point of intoxication while the Child is in their physical custody. 12. Both pm'ties shall have liberal telephone corttact with the Child. 13. 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: Mark F. Bayley, Esquire, Counsel for Father Thomas Diehl, Esquire, Counsel for Mother TRUE COPY FROM RECORD In Testimony whereof, I here unto set my and the seal of said Court at Carlisle, Pa. Ihs Iz/'t~'2' day nf ~,,-~-~ r "l ..................................... 5"~"F'"' ....... Prothonotary MITCHELL LINDSEY, Plaintiff V. KAREN L1NDSEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. : 2002-2721 CIVIL TERM : : CIVIL ACTION - ]LAW : : IN CUSTODY 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: 1. The pertinent information concerning the Child who is the subject of this litigation is as folloxvs: NAME Cameron Lindsey DATE OF BIRTH August 25 1994 CURKENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on July 9, 2002, with the following individuals in attendance: The Father, Mitchell Lindsey, with his counsel, Mark F. Bayley, Esquire and Mother, Karen Lindsey, with ]her counsel, Thomas Diehl, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date ~acqtmline M. em y, q Custody Conc:.iliator MITCHELL LINDSEY PLAINTIFF V. KAREN LINDSEY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 02-2721 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, Thursday, January 08, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before J_a_cqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, January 20, 2004 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be lyresent 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/ Jacqueline M. Verney, Esq. Custody Concflmto 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 TttE OFFICE SET FORTH BELOW TO F1ND OUT WHERE YOU CAN GET LEGAL ttELP. Cmnberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~OW~O-C!3q!.4 MITCHELL LINDSEY, Plaintiff V. KAREN LINDSEY, Defendant JAN~ 200 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-2721 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this :Z'~'4 da" -~ ---. .~t,, consideration of the attached Custody Concilia~ign ~epdrt, follows: ,2004, upon it is ordered and directed as 1. The prior Order of Court dated July 11, 2002 shall remain in full force and effect with the following modifications and additions: 2. Paragraph 3 II (which is effective during the months that Father is off from work on Thursdays and Fridays) shall be replaced in its entirety with the following: A. Beginning Wednesday, January 21, 2004 Father shall have periods of partial physical custody of the child on week one from Wednesday after school to Friday at 8:00 p.m. and on week two beginning January 28, 2004, from Wednesday after school to Sunday at 8:00 p.m. Said weeks shall alternate thereafter. 3. The parties shall initiate as soon as feasible and cooperate with co- parenting counseling with Paul Hardick of PA Counseling Service or anyone else with whom the parties mutually agree. 4. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for April 22, 2004 at 9:30 a.m. BY THE COURT, ccvS/'amuel Andes, Esquire, Counsel for Father / ' ,C\ ~ian Bo~, Esquire, Co~sel for Mother ~ ~~ MITCHELL LINDSEY, Plaintiff KAREN LINDSEY, Defendant PR/OR JUDGE: Kevin A. Hess, J. JAN 2 2 ZOO4 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2002-2721 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPOR, 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 Cameron Lindsey DATE OF BIRTH August 25, 1994 CURRENTLY 1N CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on January 20, 2004, with the following individuals in attendance: The Father, Mitchell Lindsey, with his counsel, Samuel Andes, Esquire and Mother, Karen Lindsey, with her counsel, Brian Bornman, Esquire. 3. The Honorable Kevin A. Hess entered a prior Order of Court dated July 11, 2002 providing for shared legal custody, with Mother having primary physical custody and Father having partial physical custody. 4. Both parties filed Petitions for Modification. 5. The parties agreed to the entry of an Order in the form as attached. Date ~d~/cqt/~.line M. Vemey, Esquire Uustody Conciliator MITCHELL LINDSEY, Plaintiff V. KAREN LINDSEY, Defendant APR 2 3 2004 : IN THE COURT O]? COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2002-2721 CIN'IL TERM : : IN CUSTODY ORDER OF COURT AND NOW, this c~C~/day of ..~.~.~t~--~ consideration of the attached Custody Conciliation Report, follows: ,2004, upon it is ordered and directed as 1 A Hearing is schedpled in Com2t Room No. q , of the Cumberland County ~ourt House, on the ~ day of ~_.~.~~, 2004, at__~: ~ O o'clock, 24 - M., at which time testimony will be t~ken. For purposes of this Heating, the 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 ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Orders of Court dated July 11, 2002 and January 23, 2004 shall remain in full force and effect. 3. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, MITCHELL LINDSEY, Plaintiff V. KAREN LINDSEY, Defendant : IN THE COURT O]F COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2002-2721 CI'*qL TERM : : IN CUSTODY PRIOR JUDGE: Kevin A. Hess, J. CUSTODY CONCHiIATION 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 Cameron Lindsey DATE OF BIRTH August 25, 1994 CURRENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held April 22, 2004 with the following individuals in attendance: The Father, Mitchell Lindsey, with his cotmsel, Samuel Andes, Esquire, and the Mother, Karen Lindsey, with her counsel, Brian Bornman, Esquire. 3. The Honorable Kevin A. Hess entered Orders of Court dated July 11, 2002 and January 23, 2004, (which modified the prior Order of Court.) Said Orders of Court provide for shared legal custody, with Mother having eight (8) overnights in a fourteen- day period and Father having six (6) overnights in a fourte~m-day period. 4. Father's position on custody is as follows: Father is satisfied with the current Orders of Court. He maintains that the Child is doing well under the current custodial arrangement. He maintains that the Child's grades have gone up in some classes and down in some, but that he is still an A/B student. Co-parenting counseling was ordered in January, 2004 and Father believes it is going well. Mother raises issues concerning Father taking appropriate care of the Child citing a broken moth and illness that Father did not attend to. Father asserts that he has tak{m proper care of the Child and alleges he had no knowledge of the broken moth and now accuses Mother of not advising him of the broken moth. 5. Mother's position on custody is as follows: IVlother seeks shared legal custody and primary physical custody with Father having allemating weekends. She believes that the multiple transfers between parents has disntpted the Child's education, causing his grades to drop. She further alleges that Father did not adequately care for the Child during a recent illness, not did he respond adequately to the Child's broken tooth. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and continuing the prior Order of Courts. It is expected that the Hearing will require one day. Date ~cqudi~e M. Vemey, Esquire Custody Conciliator MITCHELL LINDSEY, Plaintiff KAREN [LINDSEY] HOUK, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 02-2721 CIVIL TERM : 1N CUSTODY PRAECIPE TO THE PROTHONOTARY: Please make note that the above captioned action shall[ be changed to reflect Defendant, Karen Lindsey's, name change of Karen Houk. Date: Respectfully subraitted, Attorney for Defendant GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 MITCHELL LINDSEY, Plaintiff VS. KAREN [LINDSEY] HOUK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND ,COUNTY, PENNSYLVANIA CIVIL ACTION .. LAW NO. 02-2721 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW this g' day of ~.s and Agreement is hereby made an Order of Court. ,2004, the attached Custody Stipulation BY THE COURT, CCi Brian C. Bomman, Esquire Attorney for Defendant ',.,..8'amuel L. Andes, Esquire Attorney for Plaintiff