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