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HomeMy WebLinkAbout02-3960Barbara Sumple-Sullivan, Esquire Supreme Cour~ #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LISA M. ALT, Plaintiff BRIAN W. ALT, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CIVIL ACTION - LAW : Custody COMPLAINT IN CUSTODY 1. Plaintiff is Lisa M. Alt, an adult individual residing in Camp Hill, Cumberland County, Pennsylvania 17011. At this time and in light of past occurrences between the parties, Plaintiff does not want to disclose her street address. 2. Defendant is Brian W. Alt, an adult individual residing at 25 Pine Drive, Manchester, York County, Pennsylvania 17345. 3. Plaintiffseeks sole legal and primary physical custody of the following child: NAME ADDRESS DOB Kyle W. Alt Camp Hill, Pennsylvania 17011 9/8/1995 The child was not born out of wedlock. During the past five (5) years, the child has resided with the following persons and at the following addresses: PERSONS Mother, Richard Husler and Cindy Husler ADDRESSES 875 King Street Lewisbcrry, PA 17339 DATES 9/1997 to 9/1999 Mother Mother 734 Trail Lane Rear Enola, PA 17025 Camp Hill, PA 17011 9/1999 to 1/2002 1/2002 to Present The mother of the child is Lisa M. Alt, currently residing in Camp Hill, Cumberland County, Pennsylvania 17011. The Father of the child is Brian W. Alt, currently residing at 25 Pine Drive, Manchester, York County, Pennsylvania, 17345. The parties are divorced. currently resides with the following persons: NAME Lisa M. Alt The relationship of the Plaintiff to that of the child is that of mother. The Plaintiff RELATIONSHIP Self currently resides with the following persons: NAME Michelle Kramlick/Anderson The relationship of the Defendant to the child is that of father. The Defendant 2 RELATIONSHIP Father's girlfriend Tyler Kramlick Emily Kramlick Father's girlfriend's Son Father's girlfriend's daughter 6. A previous custody action was filed under York County Docket No. 97-SU~ 01053-02C wherein an order was entered with the Court on June 22, 2000. A copy of said Order is attached. Venue of this action is appropriate in Cumberland County given the child's residence in the county since September, 1999. 7. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. 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. 9. The best interest and permanent welfare of the child will be served by granting mother sole legal and primary physical custody of the child. The reasons are as follows: Despite specific court mandates to the contrary, Defendant disregards all communications relating to the child. Defendant fails to participate in discussions concerning the child's well being. Defendant fails to follow through to ensure the child's participation in medically necessary activities such as counseling. Defendant will not take the child to his extracurricular events (such as soccer, baseball or tigercubs) at any time during his periods of partial custody, thus resulting in the child missing the opportunity to participate despite his expressed desire. The child fails to thrive while with his father. Defendant fails to allow the child to contact Plaintiff at any time during his periods of partial custody. 3 The above referenced behavior of Defendant, as well as his personal activities in the presence of the child, (including drinking and driving and other inappropriate conduct) is causing depression, deteriorating behavior and physical ailments in the child such as an eating disorder. I 0. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff requests the Court to grant shared legal and physical custody of the child. Defendant shall have rights of partial physical custody as follows. Dated: Respectfully suShi)ted, ~ >le-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LISA M. ALT, Plaintiff v~ BRIAN W. ALT, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW Custody VERIFICATION I, LISA M. ALT, hereby certify that the facts set forth in the foregoing CUSTODY COMPLAINT are tree and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. LISA M. ALT PLAINTIFF BRIAN W. ALT DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : 02-3960 CIVIL ACTION LAW : IN CUSTODY : ORDER OF COURT AND NOW, Wednesday, August 21, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, September 23, 2002 at 12:30 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/ Melissa P. Greevy, Esq. Custody Conciliator The Court of Common Pleas of Cmnberland 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 heating or business before the court. You must attend the scheduled conference or heating. YOU SHOULD TAKE THIS PAPER TO YOUR ATrORNEY 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 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LISA M. ALT, Plaintiff BRIAN W. ALT, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-3960 : CIVIL ACTION - LAW : Custody AFFIDAVIT OF SERVICE I,'-/7~. --/TIc/d-~, being duly sworn according to law, deposes and states that at approximately /~;t'/ao-tgg.m. on 0~-dP~-o_x) at '~('~7 ~95td"/'T~~'A/% 1. Custody Complaint; and 2. Order Scheduling a Custody Conciliation for September 30, 2002 at 8:30 a.m. I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. Date: Sworn to and subscribed before me this ~ day of-.,~,J~,-~ , 20.02 ~IOTARY PUBLIC My Commission Expires: NOTARIAL SEAL ] LAURA A. TARASEWlCH, Notary VubticI susque~.~T~,, ~ Cou~ I My Commission Expires Aug. 30, 2004 I (SEAL) LISA M. ALT LISA M. ALT, BRIAN W. ALT, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3960 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY INTERIM ORDER OF COURT AND NOW, this t'_~,~l~ day of October, 2002, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: The Order of Judge Renn, dated June 22, 2000, Docket No. 97-SU-01053-02 C, York County Court of Common Pleas, is incorporated in its entirety with the following modifications: 1. Legal Custody. The Mother, Lisa M. Alt, shall have sole legal custody of the minor child, Kyle W. Alt, born September 8, 1995, with the exception of those times when the child needs acute medical care during any period of Father's custody. Mother having full responsibility for all decisions related to routine medical care, emergency medical care during her periods of custody, religious upbringing and educational decision making does not relieve her from the responsibility of keeping Father informed of the decisions which she had made in these areas. Mother shall keep Father informed of any changes in the child's care providers, serious acute medical conditions or ongoing health concerns via certified mail. For purposes of this provision related to Mother providing notice to Father, the presumptive correct address for Father shall be.' 25 Pine Drive, Manchester, Pennsylvania 17345, unless Mother is instructed otherwise. 2. Within ten (10) days of the date of this Order, Father shall provide Mother with telephone numbers where he can be reached via at work, his residence and through his cell phone. 3. The parties shall strictly comply with the terms of the June 22, 2000 Order with regard to facilitating the child's participation in extracurricular activities and the abstinence of alcohol (Page 6). NO. 02-3960 CIVIL TERM 4. Physical Custody. Father's period of physical custody shall be suspended until he participates in the care of the child as provided by Melinda Eash and Dr. Mary White. The next appointment with Dr. Mary White is Friday, October 4, 2002 at 3:30 p.m., and the next appointments with Melinda Eash are October 10, 2002 at 2:00 p.m.; October 23, 2002 at 2:00 p.m.; November 4, 2002 at 3:30 p.m.; and November 8, 2002 at 3:30 p.m. Once Father's periods of partial custody are restored, they will continue as scheduled. However, in the event that Father does not attend and participate in regularly scheduled appointments with the child's therapist and psychiatrist, his periods of partial custody will not occur again until he attends the necessary appointments. 5. In the event that Father is aggrieved by the terms of this Order, he may file a Petition to Modify with the Court and an additional Custody Conciliation Conference will be scheduled in due course. Dist: BY THE COURT~/~(~~ Harry M. Ness, Esquire, 43 N. Duke Street, York, PA 17401 Barbara Sumple-Sullivan, Esquire, 549 Bridge Street, New Cumberland, PA 17070 Brian W. Alt, 25 Pine Ddve, Manchester, PA 17345 OCT 0 8 2007. LtSA M. ALT, Plaintiff BRIAN W. ALT, . Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3960 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: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME Kyle W. Alt DATE OF BIRTH September 8, 1995 CURRENTLY IN THE CUSTODY OF Mother 2. A Custody Conciliation Conference was held on September 30, 2002 pursuant to Mother's Petition of August 19, 2002. In attendance at the Conference were the Mother, Lisa M. Alt, and her counsel, Barbara Sumple-Sullivan, Esquire. The Father, Brian W. Alt did not attend the hearing nor did he call until approximately one-half hour into the hearing time at which point he left a message in the Conciliator's voice mail. Father is reportedly represented by Harry Ness, Esquire. However, Mr. Ness did not appear on behalf of Mr. AIt~ nor did he seek a continuance of this Conference. It is believed that Mr. Ness is presently in trial in York County. 3. Counsel for Plaintiff produced an Affidavit of Service filed on September 24, 2002 indicating that the Defendant had been served on September 9, 2002 at his place of employment with the Custody Complaint and the Order scheduling today's Conference. 4. Mother's Petition: Although formed in a manner of a Complaint for Custody, Mother's Petition sounds in contempt. A prior Order exists in this matter of June 22, 2000 in the York County Court of Common Pleas, Docket No. 97-SU-01053-02 C. Mother sought the Conference because of concems that the child had reported to her and to the child's counselor that the Father is drinking and driving during his periods of custody, Father refuses to take the child to extracurricular activities, such as soccer, during his periods of custody, Father refuses to participate in the child's psychological care at Rie I & Associates and refuses to allow telephone contact when the child is with F~gt~e;'r Shienvold during his periods of custody. Apparently these parties have long had a custody conflict. They have NO. 02-3960 CIVIL TERM participated in a full custody evaluation and have been referred to mediation, in which Father refuses to participate to any meaningful extent. Mother's most recent concerns include an increase in the severity of the child's psychological symptoms. He was evaluated by Dr. Mary White on August 9, 2002. At that time, he was diagnosed with major depressive disorder, single episode, moderate to severe. Prescription medication was recommended, to which Mother agreed. However, until this past weekend, Father refused to dispense the medication during his custodial visits. According to Mother, Father has refused any contact with Dr. White, who has attempted to reach him about the child's condition. Melinda Eash, the child's therapist, has also made numerous attempts to be in contact with the Father regarding the child and has at times sent certified mail attempting to obtain a response. Unfortunately, he has made only one contact with Ms. Eash. This occurred after a report to Children 8, Youth was made based on bruises that were found on the child following a custodial visit with Father. Mother reports that Father will not communicate with her regarding the child or any of the decisions that they need to make under the terms of an Order which presently provides for shared legal custody. She has sent certified mail. He answered one letter asking her to please leave him alone. After that, he did not pick up further mail. The child apparently wanted to participate in baseball and Tiger Cubs this year. However, because Mother could not get a response from Father as to whether he would be willing to cooperate with this, she was not able to sign the child up for these activities. Mother's has offered make up time or to make a change in the schedule to allow the child to participate in the extracurricular activities and still have custodial time with Father. However, she has received no response. 5. The Conciliator spoke with Ms. Eash regarding the child's current circumstances. She reports that he has had decreased school and behavioral performance during the last half of the 2001-2002 academic year and that he had experienced weight loss and decreased appetite. This was apparently of concern to the child's pediatrician, Dr. Daly. Ms. Eash has tried several times to get Father engaged in the counseling services that she has been providing to Kyle. However, he came only once upon the insistence of his counsel. 6. Father's Position: Father did not attend. Following the Conference, the Conciliator received a voice message that Father had called about one-half hour after the Conciliation Conference had begun. He claimed to have just gotten in contact with his attorney who allegedly told him that they were not able to cancel today's Conference. He claims to have papers that tell him that he had to have counsel present with him for the Conference. He also claimed that he tried a couple of weeks ago to get today's Conciliation Conference cancelled because his attorney is in a rather lengthy trial in York. However, the Conciliator was never contacted by any counsel for Mr. Alt seeking a continuance of this Conference. NO. 02-3960 CIVIL TERM 7. On the day of the Conference, the Conciliator reviewed the psychiatric evaluation of August 9, 2002, spoke with Mother and counsel, and spoke with the child's therapist, Melinda Eash. The Conciliator was impressed with the chronicity of the conflict which these parties have experienced over the years and with Father's non-participation in the psychological and psychiatric care of this child. This concern was exacerbated by Father's failure to attend the Conference today, despite adequate time to arrange for counsel or a continuance. The Conciliator provides a recommended Interim Order which allows for Father to petition for a new Conciliation Conference should he desire to have the Court consider a modification thereof. Date "" "]~l~lis~a Pe~l (~reevy~ Esquire Custody Conciliator :163516 CUMBERLAND COUNTY COURT ADMINISTRATOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013 HARRY M. NESS, ESQUIRE 43 N DUKE STREET YORK, PA 17401 A ~1 INSUFFICIENT ADDRESS ,~11~1 I [] ATTEMPTED NOT KNOWN [] OTHER ~ NO SUCH NUMBER/STREET I[~..NOT DELIVERABLE AS ADORESSEI) / "~4JNADLE TO FORWARD h,,llh,,llh,,,,,Ih,lh,,Ih,,ll,th,,,,,/I,,,lll LISA M. ALT, Plaintiff, BRIAN W. ALT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3960 CIVIL TERM CIVIL ACTION - LAW CUSTODY PETITION TO MODIFY CUSTODY 1. The Defendant is BRIAN W. ALT, an adult individual residing at 25 Pine Street, Manchester, Yo~k County, Pennsylvania, 17345. 2. The Plaintiff is LISA M. ALT, an adult individual residing in Camp Hill, Cumberland County, Pennsylvania, 17011. Plaintiff refuses to disclose the location of her residence. 3. Plaintiff seeks partial custody (or visitation) of the following minor child: Name Present Residence DOB KYLE W. ALT with Plaintiff Sept. 08, 1995 4. The child was not born out of wedlock. 5. The child is presently in the custody of LISA M. ALT, Plaintiff, whose residence is unknown to the Defendant as per the demand of the Plaintiff. 6. During the past five years, the child has resided with the following persons at the following addresses: Name Address Date Mother, 875 King Street 09/1997 to Richard & Cindy Husler Lewisberry, PA 17339 09/1999 Mother Mother 734 Trail Lane Rear Enola, PA 17025 Camp Hill, PA 17011 09/1999 to 01/2002 01/2002 to Present 7. The mother of the child is LISA M. ALT, the Plaintiff, currently residing at ani undisclosed location in Camp Hill, Cumberland County, Pennsylvania, 17011 8. The father of the child is BRIAN W. ALT, the Defendant, currently residing 25 Pine Drive, Manchester, York County, Pennsylvania, 17345. 9. The relationship of the Defendant to the child is that of biological father. The Defendant currently resides with the following person(s): Name Relationship Michelle Kraml~ck-Anderson Girlfriend q~ler Kramlick Girlfriend's minor son 10. The relationship of the Plaintiff to the child is that of biological mother. It is unknown if the Plaintiff currently resides with any person(s) other than said minor child. 11. A previous custody action was filed under Cumberland County Docket 02-3960 on August 19, 2002, wherein an INTERIM ORDER OF COURT was entered on October 13, 2002. A copy of said Order is attached. 12. Defendant has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiff 'does not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 13. The best interest and permanent welfare of the child will be served by granting father joint legal custody and partial physical custody; or, in the alternative, joint legal custody and hberal visitation rights. The reasons are as follows: Defendant is the natural, biological father of the child. As such, father seeks and desires to re-establish and promote a parental relationship with the child. Because of his absence for a previous custody conference on September 30, 2002, father has been deprived of the opportunity to provide input into child's religious and education development, as well as the chilkt's healthcare. Father has been left largely unaware of such aspects of.his child's life and has expressed a sincere desire to establish a paternal~ presence in his son's life. 14. 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. WHEREFORE,' Plaintiff respectfully requests this Honorable Court to grant join~ legal custody and partial custody of the parties' minor child; or, in the alternative, grant joint legal custody and liberal wsitat~on- ' rights with the parties' minor child. J. Michael Sheldon, Esquire Pa. ID #83098 6059 Allentown Boulevard Harrisburg, PA 17112 Tel: (717) 657-3464 Fax: (717) 671-1258 Attorney for Defendant LISA M. ALT, Plaintiff, BRIAN W. ALT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3960 CIVIL TERM CIVIL ACTION - LAW CUSTODY VERIFICATION STATEMENT 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. Cons. Stat. Ann. § 4904, relating to unsworn falsification to authorities. Date: 2003 BRIAN W. ALT, Defendant LISA M. ALT, Plaintiff, BRIAN W. ALT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3960 CIVIL TERM CIVIL ACTION - LAW CUSTODY CERTIFICATE OF SERVICE I, J. Michael Sheldon, Esquire, hereby certify that I served a true and correct copy of the foregoing COMPLAINT via United States mail, first-class postage, and by United States Mail certified, restricted delivery to the following: Barbara Simple-Sullivan 549 Bridge Street New Cumberland, PA 17070-1931 DATE: ~5~ ~, 2003 J. Michael Sheldon, Esquire Pa. ID #83098 6059 Allentown Boulevard Harrisburg, PA 17112 Tel: (717) 657-3464 Fax: (717) 671-1258 Attorney for Defendant LISA M. ALT : PLAINTIFF : BRIAN W. ALT DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-3960 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, November 14, 2003 ., upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, December 15, 2003 at 9:00 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/ Melissa P. Greevy, 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 32 South Bedford Street Carlisle, Pennsylvania 1'7013 Telephone (717) 249-3166 LISA M. ALT, BRIAN W. ALT, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3960 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY I~NTERIM ORDER OF COURT AND NOW, this 2--~,,~ da,, of ~T-__ ~ of the -- ..', :' --~ ~'J)~'--~- ) _, 200 ~, upon consideration attached Custody Conc~llabon Summary Report, i~is hereby ordered and directed as follows: - 1. Father shall attend therapeutic family counseling with Melinda Eash and with Dr. Mary White, if requested, regarding Kyle's needs and to discuss the process of re- establishing a father-son relationship with Kyle. Ms. Eash shall issue a report with recommendations to include when and how to include Kyle in the therapeutic meetings with Father. She shall also provide her feedback regarding Father's commitment to the work needed to re-establish this relationship. The report shall be made available to counsel by March 31, 2004. 2. Upon letter request from counsel for either party made within fourteen (14) days of receipt of Ms. Eash's report, the Custody Conciliation Conference may be scheduled to reconvene. 3. There shall be no disclosure to the child of the process which is being undertaken regarding the potential reuniting of his relationship with Father, prior to receipt of the recommendation by Ms. Eash. 4. Through counsel, Mother shall disclose her residential address by March 31, 2004, if Father has followed through with the counseling described above. 5. Father shall be responsible to pay all unreimbursed costs of the counseling. 6. Mother shall Participate to support this process as recommended by the therapist, including but not limited to, transportation of Kyle to appointments with the therapist and Father, if so indicated. NO. 02-3960 CIVIL TERM 7. Father is reminded that he must demonstrate his unwavering commitment to this process in order to demonstrate the seriousness of his purpose in the repair of the relationship and in his role as Father to this child. Dist: BY THE COURT: ~rbara Sumple-Sullivan Esqu re, 549 Bride Stre LISA M. ALT, BRIAN W. ALT, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3960 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPOR I 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 litigatJon is as follows: .NAME Kyle W. Alt DATE OF BIRTH September 8, 1995 CURRENTLY IN THE CUSTODY OI- Mother 2. The Custody Conciliation Conference was convened on December 23, 2003 following Father's Petition to Modify Custody filed on or about November 6, 2003. Attending the conference were: the Mother, Lisa M. Alt, and her counsel, Barbara Sumple-Sullivan, Esquire; the Father, Brian W. Alt, and his counsel, J. Michael Sheldon, Esquire. 3. The parties reached an agreement as to ~rder as attached. Dat!¢~/~ ~' ---~eli~ss~~ eel Greevy, ~ssquire Custody Conciliator :222524