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HomeMy WebLinkAbout06-7268ANDREW C. VANGORDER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06 Civil Term STEPHANIE S. KRIBS, : CIVIL ACTION - LAW Defendant : IN CUSTODY 1. Plaintiff is Andrew C. VanGorder, who currently resides at 2417 Wooded Acres Drive, Waco, Texas, 76710. 2. Defendant is Stephanie S. Kribs, who currently resides at 7 High Street, Boiling Springs, Cumberland County, Pennsylvania, 17007. 3. Plaintiff is the father of the following minor children and seeks a custody order regarding the following children: NAME DOB/AGE ADDRESS Brendan D. VanGorder 1/3/92(14) 7 High St. Keegan E. VanGorder 1/31/94 (12) Boiling Springs, Pa. 17007 Sean M. VanGorder 12/15/95 (11) Mother and Father married on July 2, 1983 and a Decree in Divorce was entered in Cumberland County, Pennsylvania on March 7, 2006 under Docket No. 04 - 4831. Mother currently has primary physical custody of the children. CUSTODY COMPLAINT During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Stephanie S. Kribs 7 High Street Boiling Springs, Pa. 17007 August 2004 - present Stephanie S. VanGorder 7 High St. 2001 - August 2004 (n/k/a Stephanie S. Kribs) Boiling Springs, Pa. 17007 Chris VanGorder The mother of the children is Stephanie S. Kribs. She currently resides at 7 High St., Boiling Springs, Pa. 17007. She is divorced. The father the children is Andrew C. VanGorder. He currently resides at 2417 Wooded Acres Drive, Waco, Texas, 76710. He is divorced. 4. The relationship of plaintiff to the children is that of Father. The Plaintiff currently resides alone. 5. The relationship of defendant to the children is that of Mother. The Mother currently resides with the children. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a parry to the proceedings who has physical custody of the children or anyone who claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: The parties were divorced on March 7, 2006 in Cumberland County. At that time, the parties had few problems regarding cy and a separate custody action was not filed. Father now lives in Texas. He is seeking a formal custody Order regarding the parties' arrangement due to some recent difficulties regarding custody. A custody Order would be in the best interest of the children because it would better define the rights of the parties and provide the children with stability. 8. Each parent whose parental rights to the chidlren have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the children. Respectfully submitted, Date: l-'' e Adams, Esquire I. . No. 79465 5 94 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 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. §4904 relating to unsworn falsification to authorities. alp G. G_q S, -- Date: Andrew. G VanGorder, Plaintiff cr Y ? L1- ? v D N ANDREW C. VANGORDER IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. STEPHANIE S. KRIBS DEFENDANT 06-7268 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, January 02, 2007 , 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, January 25, 2007 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 VlNtlAWNN3,d grin '1W 80 :£ ltd C- NVF LODZ IEffl"HiQ` ` 3RL :10 301??MH f . JANE 6 2001 Q.1 f ANDREW C. VANGORDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-7268 CIVIL ACTION - LAW STEPHANIE S. KRIBS, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 31 s1 day of ?aNy bs y , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Andrew C. VanGorder and the Mother, Stephanie S. Kribs, shall have shared legal custody of Brendan D. VanGorder, born January 3, 1992, Keegan E. VanGorder, born January 31, 1994 and Sean M. VanGorder, born December 15, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their 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 children including, but not limited to medical, dental, religious or school records, the residence address of the children 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 children. 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. 2. Mother shall have primary physical custody of the children. 3. Father shall have the following periods of partial physical custody: A. For the summer of 2007, 5 weeks as follows: June 25 to July 9 and July 29 to August 19 or similar times as the parties may agree. B. For subsequent summers, Father shall have physical custody of the children for six (6) weeks to be broken into two (2) periods of three (3) consecutive weeks, each at times agreed by the parties. However, the children are to return to Mother usually as close to one week before i school starts as possible. Father shall give Mother at least 30 days prior written notice of these times and Mother shall have one week to reject suggested times for good cause. C. The following holidays shall be alternated: Easter/spring break; Thanksgiving and Christmas. Father shall have physical custody for Easter/spring break in 2007 and the parties shall alternate the aforementioned holidays thereafter, i.e. Mother shall have Thanksgiving in 2007, Father Christmas in 2007. For these holidays, Father shall have physical custody beginning the day after school recesses to one day before school resumes. D. Long weekends provided Father give Mother 30 days prior written notice of said weekends and Mother shall have one week to reject the long week but only for good cause. In no instance shall Father be permitted to remove the children from school for these long weekends. E. Such periods of time when Father is in the Boiling Springs area, he shall give Mother 14 days prior written notice of such times and Mother shall have 3 days to reject the times for good cause. Pick up and drop off shall be at the Cafe in Boiling Springs F. Such other times as the parties agree. 4. Transportation shall be such that Father shall pay for all airline tickets for the children and Mother shall be responsible for transporting the children to/from the Harrisburg Airport. 5. Both parties shall have reasonable telephone contact with the children, meaning three times per week between 7:00 p.m. and 9:00 p.m. 6. Neither party shall do or say anything, nor permit any third party from doing or saying anything that may estrange the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. 7. 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, 1*Xkt cc: Jane Adams, Esquire, Counsel for Father Lori K. Serratelli, Esquire, Counsel for Mother a a - d' 07 ? ? :2 lH'l i - 9-IJ LOOZ %' (.1 t i ANDREW C. VANGORDER, Plaintiff V. STEPHANIE S. KRIBS, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-7268 CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Brendan D. VanGorder January 3, 1992 Mother Keegan E. VanGorder January 31, 1994 Mother Sean M. VanGorder December 15, 1995 Mother 2. A Conciliation Conference was held in this matter on January 25, 2007, with the following in attendance: The Father, Andrew C. VanGorder, by telephone, with his counsel, Jane Adams, Esquire, and the Mother, Stephanie S. Kribs, with her counsel, Lori K. Serratelli, Esquire. 3. The parties agreed to an Order in the form as attached. Date ac eline M. Verney, Esquire Custody Conciliator C --I. ANDREW C. VANGORDER, Plaintiff V. STEPHANIE S. KRIBS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CASE NO. 06-7268 : CIVIL ACTION - LAW : IN CUSTODY WITHDRAWAL OF APPEARANCE Please withdraw my appearance in the above-captioned matter on behalf of the Defendant, Stephanie S. Kribs. Respectfully submitted, of I I &A SL Lori K. Serratelli Esquire 2080 Linglestown Road Ste 201 Harrisburg, Pa 17110 ENTRY OF APPEARANCE Please enter my appearance in the above-captioned matter on behalf of the Defendant, Stephanie S. Kribs. Respectfully submitted, 1 Mark A. Mateya, E ire Attorney I.D. No. 78931 P.O. BOX 127 Boiling Springs, PA 17007 (717) 241-6500 Dated: ? ? ? 6 CERTIFICATE OF SERVICE I, hereby certify that I have served a copy of the foregoing Withdrawal of Appearance/Entry of Appearance on the following person(s) by depositing a true and correct copy of the same in the United States Mail, first class, postage prepaid, at Boiling Springs, Cumberland County, Pennsylvania addressed to: Jane Adams, Esquire 36 South Pitt Street Carlisle Pa 17013 L-?, ? . ? Mark A. Mateya, Esquire P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 Fax Dated: c ?' r.a C i t C; Hip to ?* tp F5 ANDREW C. VAN GORDER, Plaintiff VS. STEPHANIE S. KRIBS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2006 - 7268 Civil Term : ACTION IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW, comes Petitioner, Andrew C. VanGorder, by and through his counsel, Jane Adams, Esquire, and petitions the Court as follows: 1. Andrew C. VanGorder, Petitioner, (hereinafter referred to as "Father"), is the Plaintiff in the above-captioned matter, and is an adult individual currently residing at 2417 Wooded Acres Drive, Waco, Texas, 76710. 2. Stephanie S. Kribs, Respondent, (hereinafter referred to as "Mother") is the Defendant in the above-captioned matter, and is currently residing at 7 High Street, Boiling Springs, Cumberland County, Pennsylvania, 17007. 3. The parties are the natural parents of four children, and three are under the age of eighteen, namely: Brendan D. VanGorder, born January 3,1992; Keegan E. VanGorder, born January 31,1994; and Sean M. VanGorder, born December 15,1995. 4. The parties are subject to an Order of Court dated January 31, 2006, which was a result of the parties' agreement at a custody conciliation conference. A copy of said Order and Stipulation is attached hereto and incorporated herein by reference as Exhibit "A". 5. The current order provides Father with two three-week visits with the children during the summer. Father is requesting a change in the custody order because such a provision puts an undue burden on Father due to the fact that Father must pay for six round-trip tickets for the children per summer to exercise his periods of custody and Mother refuses to consolidate the visit into one period or to allow the children to fly from any airport other than Harrisburg. 6. Such divided visits make it difficult for Father to travel with the children, and impacts the children's social life and ability to obtain employment when with Father. 7. Father is requesting that the visits be consolidated into one time period, or in the alternative, that Mother be required to share in the transportation costs for the visits. 8. It would be in the best interest of the children to modify this Order because the prior agreement and Order do not adequately provide for the custody of the children. 9. It is believed and averred that the best interest and permanent welfare of the children will be promoted by changes proposed in this custody petition because the modification will ensure the children' regular contact with both parents. WHEREFORE, Plaintiff requests the court to set a conciliation date to examine issues regarding custody of the children. Respectfully submitted, Date: 3 / b Adams, Esquire No. 79465 V. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER JAN 2 6 2007 e ANDREW C. VANGORDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-7268 CIVIL ACTION - LAW STEPHANIE S. KRIBS, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 31?:+ day of 2007, upon consideration of the attached Custody Conciliation eport, it is ordered and directed as follows: 1. The Father, Andrew C. VanGorder and the Mother, Stephanie S. Kribs, shall have shared legal custody of Brendan D. VanGorder, born January 3, 1992, Keegan E. VanGorder, born January 31, 1994 and Sean M. VanGorder, born December 15, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their 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 children including, but not limited to medical, dental, religious or school records, the residence address of the children 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 children. Each parent shall be entitled to frill 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. 2. Mother shall have primary physical custody of the children. Father shall have the following periods of partial physical custody: A. For the summer of 2007, 5 weeks as follows: June 25 to July 9 and July 29 to August 19 or similar times as the parties may agree. B. For subsequent summers, Father shall have physical custody of the children for six (6) weeks to be broken into two (2) periods of three (3) consecutive weeks, each at times agreed by the parties. However, the children are to return to Mother usually as close to one week before school starts as possible. Father shall give Mother at least 30 days prior written notice of these times and Mother shall have one week to reject suggested times for good cause. C. The following holidays shall be alternated: Easter/spring break; Thanksgiving and Christmas. Father shall have physical custody for Easter/spring break in 2007 and the parties shall alternate the aforementioned holidays thereafter, i.e. Mother shall have Thanksgiving in 2007, Father Christmas in 2007. For these holidays, Father shall have physical custody beginning the day after school recesses to one day before school resumes. D. Long weekends provided Father give Mother 30 days prior written notice of said weekends and Mother shall have one week to reject the long week but only for good cause. In no instance shall Father be permitted to remove the children from school for these long weekends. E. Such periods of time when Father is in the Boiling Springs area, he shall give Mother 14 days prior written notice of such times and Mother shall have 3 days to reject the times for good cause. Pick up and drop off shall be at the Cafe in Boiling Springs F. Such other times as the parties agree. 4. Transportation shall be such that Father shall pay for all airline tickets for the children and Mother shall be responsible for transporting the children to/from the Harrisburg Airport. 5. Both parties shall have reasonable telephone contact with the children, meaning three times per week between 7:00 p.m. and 9:00 p.m. 6. Neither party shall do or say anything, nor permit any third party from doing or saying anything that may estrange the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. 7. 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, psi-n,)? e"?a ,_ _ J. cc: Jane Adams, Esquire, Counsel for Father Lori K. Serratelli, Esquire, Counsel for Mother IHUE COPY FROM RECORD 1 TeWmony whereof, I here unb eet nN ham gad the s@W of said Court at Carmo, Pa. preftnttarv . ANDREW C. VANGORDER, Plaintiff V. STEPHANIE S. KRIBS, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-7268 CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Brendan D. VanGorder January 3, 1992 Mother Keegan E. VanGorder January 31, 1994 Mother Sean M. VanGorder December 15, 1995 Mother 2. A Conciliation Conference was held in this matter on January 25, 2007, with the following in attendance: The Father, Andrew C. VanGorder, by telephone, with his counsel, Jane Adams, Esquire, and the Mother, Stephanie S. Kribs, with her counsel, Lori K. Serratelli, Esquire. The parties agreed to an Order in the form as attached. Date ac eline M. Verney, Esquire Custody Conciliator VERIFICATION I verify that the statements made in this Petition 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. v- v Date: 127 OS Andrew C. anGor r, Petitioner 3 r c Q5 1 c o ? J e ANDREW C. VAN GORDER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. STEPHANIE S. KRIBS DEFENDANT 2006-7268 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 04, 2008 , 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, May 06, 2008 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. 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/ 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 bWhIri3d 91:? Nd h- VJV IOU I'll,11-1y1F?rt1 :10 7sd1?,"?G1 1. .% MAY 0 7 MR ANDREW C. VANGORDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-7268 CIVIL ACTION - LAW STEPHANIE S. KRIBS, Defendant IN CUSTODY ORDER OF COURT AND NOW, this h day of ?. , 2008, upon consideration of the attached Custody Conciliation eport, it is ordered and directed as follows: 1. The prior Order of Court dated January 31, 2007 shall remain in full force and effect with the following modifications: 2. The first sentence of Paragraph 3B shall be deleted and replaced with the following: Father shall have five consecutive weeks of physical custody of the children in 2008. from June 7 to July 12. In following years, Father shall have five consecutive weeks of physical custody of the children. The remainder of Paragraph 3B shall remain in full force and effect. 3. Paragraph 4 shall be modified to allow the children to fly in/out of Baltimore or Philadelphia airports only in the summer. Father shall reimburse Mother for her gas expense for transporting the children to/from other than Harrisburg Airport. 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. BY THE COURT, M.L. Ebert, Jr., cc: lane Adams, Esquire, Counsel for Father Mark A. Metaya, Esquire, Counsel for Mother Cap tes mial 64L J. 5 ,S' 4106 VINV 11ASNIN d ?dNnon $C .Z Wd 6- M $QOZ MVIONi HiGldd 3HI ?O 301J0-{M 4.-f , .% ANDREW C. VANGORDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-7268 CIVIL ACTION - LAW STEPHANIE S. KRIBS, Defendant : IN CUSTODY PRIOR JUDGE: M.L. Ebert, 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Brendan D. VanGorder January 3, 1992 Mother Keegan E. VanGorder January 31, 1994 Mother Sean M. VanGorder December 15, 1995 Mother 2. A Conciliation Conference was held in this matter on May 6, 2008, with the following in attendance: The Father, Andrew C. VanGorder, by telephone, with his counsel, Jane Adams, Esquire, and the Mother, Stephanie S. Kribs, with her counsel, Mark A. Metaya, Esquire. 3. The Honorable M.L. Ebert, Jr. previously entered an Order of Court dated January 31, 2007 providing for shared legal custody, Mother having primary physical custody and Father having periods of partial physical custody over the holidays and summer. 4. ,5-6 -eft Date The parties agreed to an Order in the form as attached. . QV-41 ?' - Acq ine M. Verney, Esquire Custody Conciliator