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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
9
STATE OF PENNA. pp
PATRICK L. HODGE,
j u....95-6243..... .Civil.... 1995
Plaintiff
Versus a
MICHELLE HODGE,
Defendant
01
DECREE IN
-'DIVORCE
AND NOW, ....1? iA........ V.9., 19.q6., it is ordered and
decreed that ....,,PATRICK.L. HODGE .............•,,,,,,,,,,,,,, plaintiff,
. .............•,,,,,,•,,,,,,, defendant,
. HODGE .
. ELLE.
and . . . . . . . . . MICH. ..
.
.
.
.
.
.
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet A
been entered;
A
.. None ................................ ./................. !t
By The rtt
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PATRICK L. HODGE,
Plaintiff
V.
MICHELLE HODGE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PRNNSYLVANIA
NO. 95-6243
IN DIVORCE
PRASCIPE TO TRANSMIT gZCogp
TO THE PROTHONOTARY:
Transmit the record, together with the following
information, to the court for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under
Section 3301(c) of the Divorce Code.
2. Date and manner of service of the complaint:
November 3, 1995, by certified mail.
3. Date of execution of the affidavit of consent required
by Section 3301(c) of the Divorce Code: by plaintiff:
February 7, :1996; by defendant: September 23, 1996.
4. Related claims pending: None.
5. Waiver of notice of intention to file pruacipe to
transmit record was filed by defendant on September 24, 1996.
?? L
Cindy E Sheaf ???fer, EQ ire
Attorn y I.D. No. 70327
806 Wer zville Road
P. O. Box 267
Enola, PA 1.7025
(717) '132-7971
Date: October 1, 1996
a
PATRICK L. HODGE, s IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. s No. 01 0-
s
MICHELLE R. HODGE, CIVIL ACTION - LAW
Defendant : IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Courthouse, at
the intersection of
Pennsylvania.
High and Hanover Streets, Carlisle,
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A OFFICE SET RTH BELOW TO ND OUT AFFORD WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR
CUMBERLAND CO COURTHOUSE 4th FLOOR
1 COURTHOUSE SQUARE
CARLISLE PA 17013 3387
(717) 240 6200
PATRICK L. HODGE,
Plaintiff
vs.
MICHELLE R. HODGE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No.
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IM DIVORCE UNDER SECTIONS 3301(c) or 3301(d)
OF THE DIVORCE CODE
COUNT I
The Plaintiff, Patrick L. Hodge, by and through his attorneys,
The Law Offices of Patrick F. Lauer, Jr., makes the following
Complaint in Divorce:
1. The Plaintiff, Patrick L. Hodge, is an adult individual who
is currently in the United States Army, 555 MPCO, Ft. Lee, Virginia
23801, E-5. Plaintiff's residence of record is 157 Lincoln Street,
Carlisle, Cumberland County, Pennsylvania 17013.
2. The Defendant, Michelle R. Hodge, is an adult individual
who currently resides at 46 Marilyn Drive, Carlisle, Cumberland
County, Pennsylvania 17013.
3. The Parties have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately
prior to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on October 11,
1993 in Prince George County, Virginia.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised that counseling is
available and that the Plaintiff may have the right to request that
the court require the parties to participate in counseling.
8. This action is not collusive.
The Plantiff requests this Honorable Court to enter a Decree
of Divorce in this matter.
COUNT II
The prior paragraphs of this Complaint are incorporated herein
by reference therto.
9. The parties are the parents of the following
unemancipated child whe resides with the Defendant, Michelle R.
Hodget
N. AGE DATE OF BIRTH
Leanisha Hodge 3 years 7-03-92
10. Plaintiff has not participated in any other litigation
concerning the child in this or any other state.
11. There are no other proceedings pending involving custody
of the child in this or any other state.
12. Plaintiff knows of no person not a party to these
proceedings who has physical custody of the child or who claims to
have custody, partial custody or visitation rights with repsect to
the child.
13. The best interest of the child will be served if custody
of her is confirmed in Plaintiff.
09,
II
The Plaintiff requests this Honorable Court to enter an order
confirming custody of the child to the Plaintiff.
Respectfully submitted,
H an J. PuhnlaI Sr., Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 52677 Tel. (717) 763-1800
Dates z•?4'
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PATRICK L. HODGE,
Plaintiff
Vs.
MICHELLE R. HODGE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND, PENNSYLVANIA
No.
CIVIL ACTION - LAW
IN DIVORCE
The undersigned, Brian J. Puhala, Sr., Esquire, hereby
verifies and states that:
1. He is the attorney for Patrick L. Hodge.
2. He is authorized to make this verification on his behalf;
3. The facts set forth in the foregoing Complaint are
known to him and not necessarily to his client;
4. The facts set forth in the foregoing Complaint are true and
correct to the best of his knowledge, information and belief; and
5. He is aware that false statements herein are made subject to
the penalties of 18 Pa. C.S. 4904, relating to unsworn
falsification to authorities.
Respectfully submitted,
i
i
Brian J.P a, Sr., Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 52677 Tel. (717) 763-1800
Date: Ly-l??
PATRICK L. HODGE,
Plaintiff
vs.
MICHELLE R. HODGE,
Defendant
s IN THE COURT OF COMMON PLEAS OF
s CUMBERLAND COUNTY, PENNSYLVANIA
s No. 46- -wq5 01; L,; ! Ttrm
s
s CIVIL ACTION - LAW
s IN DIVORCE
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.C.S. S 4904, relating to unsworn
falsification to authorities.
Dates ALL- Signatures A&reG _ ??6L
Patrick L. Hodge
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PATRICK L. HODGE,
Plaintiff
vs.
MICHELLE R. HODGE,
Defendant
I IN THE COURT OF COMMON PLEAS OF
s CUMBERLAND COUNTY, PENNSYLVANIA
s
t No. 6243-1995 Civil Term
t
t CIVIL ACTION - LAW
t IN DIVORCE
AMENDED COMPLAINT
AND NOW, comes the Plaintiff, Patrick L. Hodge, by and through
his attorneys, The Law Offices of Patrick F. Lauer, Jr., and amend
his original Complaint filed on October 31, 1995 as follows:
1. In Plaintiff original Complaint at paragraph 4, Plaintiff
erroneously indicated that the parties were married on October 11,
1993. The appropriate date of marriage was November 22, 1993.
2. The parties have been separated since, on or about,
September 91 1995.
WHEREFORE, Plaintiff respectfully request that a decree in
divorce be issued with regards to the above matter.
Respectfully submitted,
Bria J. uhala, Sr., Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 52677 Tel. (717) 763-1800
? Date s
PATRICK L. HODGE,
Plaintiff
vs.
MICHELLE R. HODGE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
s No. 6243-1995 Civil Term
: CIVIL ACTION - LAW
: IN DIVORCE
ATTORNEY VERIFICATION
The undersigned, Patrick F. Lauer, Jr., Esquire, hereby
verifies and states that:
1. He is the attorney for Patrick L. Hodge.
2. He is authorized to make this verification on his behalf;
3. The facts set forth in the foregoing Amendment are known to
him and not necessarily to his client;
4. The facts set forth in the foregoing Amendment are true and
correct to the best of his knowledge, information and belief; and
5. He is aware that false statements herein are made subject to
the penalties of 18 Pa. C.S. 4904, relating to unsworn
falsification to authorities.
Respectfully submitted,
Brian J.'Puhala, Sr., Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
Date: ID# 52677 Tel. (717) 763-1800
//??•%rf
PATRICK L. HODGE,
Plaintiff
vs.
MICHELLE R. HODGE,
Defendant
s IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
s No. 6243-1995 Civil Term
CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of the
foregoing Amendment upon the person, and in the manner, indicated
below, which service satisfies the requirements of the
Pennsylvania Rules of Civil Procedure, by depositing a copy of
the same with the United States Post Office at Camp Hill,
Pennsylvania, through first class mail, prepaid and addressed as
follows:
Michael R. Rundle
PO Box 208
Carlisle, PA 17013-0208
Bria J. PnhaT-Sr., Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 52677 Tel. (717) 763-1800
Dates
PATRICK L. HODGE, s IN THE COURT OF COMMON PLEAS OF
Plaintiff s CUMBERLAND COUNTY, PENNSYLVANIA
s
vs. s No. 95-6243 Civil Term
s
MICHELLE R. HODGE, s CIVIL ACTION - LAW
Defendant s IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301(cl OF THE DIVORCE CODS
1. A complaint in divorce under Section 3301(c) of the
Divorce Code was filed on the 31st day of October 1995 and Amended
on November 30, 1995.
2. The marriage of the Plaintiff and the Defendant is
irretrievably broken and ninety days have elapsed from the date of
the filing of the Complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
4. I verify that the statements made in this affidavit are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. S 4904 relating to
unsworn falsification to authorities.
Signature:
Patrick L. Hodge
Dated: February 7, 1996
PATRICK L. HODGE,
Plaintiff
V.
MICHELLE R. HODGE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-6243 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT] WAIVER OF NOTICE OF
INTENTION TO REQUEST ENTRY OF A DIVORCE DECREES
AND WAIVER OF MARRIAGE COUNSELLING
1. A Complaint in divorce under Section 3301(c) of the
Divorce code was filed on November 30, 1995.
2. The marriage of the plaintiff and the defendant is
irretrievably broken and ninety (90) days have elapsed from the
date of filing the complaint.
3. .I consent to the entry of a final decree of divorce
without further notice.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
5. I understand that I will not be divorced until a divorce
decree is entered by the court and that a copy of the decree will
be sent to me immediately after it is filed with the
Prothonotary.
6. I understand that counselling is available and that I
may have the right to request that the parties participate in
counselling.
-?1i cly??t? R W?dcA 9- a3-9tv
Michelle R. Hodge
DATE: September 23, 1996
a
a
PATRICK L. HODGE,
Plaintiff
v.
MICHELLE HODGE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 95-6243
: IN CUSTODY
ACCEtrI'ANCE OF SERVICE
I, Michelle Hodge, Defendant, certify that I received a certified copy of the Complaint in
Divorce in the above-captioned action on or about November 3, 1995, by certified mail.
MICHELLE HODGE
3
r.
PATRICK L. HODGE, : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION -LAW
V. : NO. 95-6243
MICHELLE HODGE,
Defendant : IN CUSTODY
AND NOW, this Inr" day of .loft , 1996, upon consideration of
the attached Complaint, it is hereby directed that the parties and their respective counsel appear
fore E L Lb er+ 6 i ill I" , the conci ator, at Pt<mlyr la itnf
l UL c? ??Ir? (_ ink / n , I 1?. ?(? l7U 13 on the
day of , 1996, at _h7 A M., for a Preheating Custody Conference.
At such conf nce, 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. Either party may bring the child who is the subject of this custody action to the
conference, but the child's attendance is not mandatory. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
FOR THE COURT:
By-J_L&k/ "6,l
Custody Conciliate
YOU SHQULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE, FOURTH FLOOR
CARLISLE, PA 17013
(717)240.6200
C i F)l C? G,-r^C??rA?Y
PE*zvES; A `?
PATRICK L. HODGE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION -LAW
V. : NO. 95-6243
MICHELLE HODGE,
Defendant : IN CUSTODY
1. The Plaintiff is Patrick L. Hodge, residing at 2005 Bellevue Road, Harrisburg,
Dauphin County, Pennsylvania 17104.
2. The Defendant is Michelle Hodge, residing at 530 First Street, Carlisle,
Cumberland County, Pennsylvania 17013.
3. Plaintiff seeks custody of the following child:
II
LeaNisha Renee Hodge
The child was bom out of wedlock.
Present R aidr= Au
530 First Street 4 years
Carlisle, PA 17013
The child is presently in the custody of Michelle Hodge, who resides at 530 First
Street, Carlisle, Cumberland County, Pennsylvania 17013.
During the past five years, the child has resided with the following persons and at
the following addresses:
Personit Addres Raton
Michelle Shaffer 106A Lincoln Street 7/92 - 1/94
TyRell Shaffer Carlisle, PA 17013
Pawns Address DA109
Michelle Hodge 420C Manilla Road 1/94 - 8/95
Patrick Hodge Fort Lee, VA
TyRell Shaffer
Whereabouts Unknown 8/95 - 10/95
Michelle Hodge 530 First Street 10/95 - present
TyRell Shaffer Carlisle, PA 17013
The mother of the child is Michelle Hodge, currently residing at 530 First Street,
Carlisle, Cumberland County, Pennsylvania 17013.
She is married.
The father of the child is Patrick L. Hodge, currently residing at 2005 Bellevue
Road, Harrisburg, Dauphin County, Pennsylvania 17104.
He is married.
4. The relationship of Plaintiff to the child is that of father. The Plaintiff currently
resides with the following persons:
NA= Malign"
Kevan Kern Friend
Larry Winters Friend
Alexis Winters Daughter of Friend
5. The relationship of Defendant to the child is that of mother. The Defendant
currently resides with the following persons:
N= Relationship
TyRell Shaffer Son
LeaNisha Hodge Daughter
2
•
6. 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.
Plaintiff has no information of a custody proceeding concerning the child pending
in a court of this Commonwealth.
Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect to the
child.
7. The best interest and permanent welfare of the child will be served by granting
the relief requested because Defendant has not allowed Plaintiff to have continuous contact with
the child, and Plaintiff has the desire and means io provide for the child.
S. 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 requests the Court to grant custody of the children to Plaintiff.
CINDY E/VMEAFFER, E
Attorney M No. 70327
P. O. Box 267
Enola, PA 17025
(717) 732-7971
Attorney for Plaintiff,
Patrick L. Hodge
Date: July 10, 1996
46
VERIFICATION
1 verify that the statements made in this Complaint are true and correct. I understand that
false statements herein arc mudc subject to the penulties of 18 Pa. C.S. p 4904 relating to unswurn
falsification to authorities.
.444 b
Patrick L. Hodge
PATRICK L. HODGEPlaintiff
V.
?j -yam`/G
s COMMON
CUMBERLAND COUNTY, PENNSYLVANIA
s
s CIVIL ACTION - LAW
IN THE COURT OF MICHELLE HODGEr Defendant
s
s NO. 95 - 6243 CIVIL
s
s CIVIL ACTION - CUSTODY
COURT ORDER
day of , 1996,
AND NOW, this
consideration of the attached Custo y one liation Report,
ordered and directed as follows:
1.
2.
3.
4.
5.
6.
A. On alternating weekends from Friday evening at
approximately 3:30 p.m. until Sunday evening at 6:00 p.m.
This time may be altered by the parties as they may
agree.
B. During the weekdays when mother is working and Father or
Father's mother are available to provide care for the
child, Father or Father's mother may have custody of the
minor child which contemplates the paternal
earansdother
picking the child up at approximately 300
until such time as the Mother is off work.
C. At such other times as agreed upon by the parties.
upon
it is
The Mother, Michelle Hodge, and the Father, Patrick L. Hodge,
shall enjoy shared legal custody of LeaNisha Renee Hodge, born
July 3, 1992.
The Mother shall enjoy primary physical custody of the minor
child.
The Father shall enjoy periods of temporary physical custody
with the minor child as follows:
Each parent shall have at least two weeks of vacation time
with the minor child which time may be taken consecutively.
The
an parties when lthadvise the other parent in a ey Intend to exercise the summer vacation.
It is anticipated the parties will modify or alter the above
schedule as necessary to Insure that the Mother shall spend
time with the minor child spend time with the minor child onF Fatheand the r's Day. Father shall
o /
It Is also themselves to share lore alternate holidays as shall they might agree.
i
I- ,_.._
7. This order is entered pursuant to an agreement reached by the
parties at a Custody Conciliation Conference. In the event
either party desires to modify this order, that party may
petition the Court to have the case again scheduled with the
Custody Conciliator. //))
By the Court/
cc: Michael R. Rundle, Esquire n,.c Io/(o?9fo.
Cindy B. Shaeffer, Esquire )
PATRICK L. HODGE, r IN THE COURT OF COMMON PLEAS OF
Plaintiff s CUMBERLAND COUNTY, PENNSYLVANIA
s
V. t CIVIL ACTION - LAW
s
MICHELLE HODGE, NO. 95 - 6243 CIVIL
Defendant s
s CIVIL ACTION - CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following reports
1. The information pertaining to the child who is subject of this
litigation is as follows:
LeaNisha Renee Hodge, born July 3, 1992
2. A Conciliation Conference was held on August 30, 1996.
Present were the Father, Patrick L. Hodge, with his counsel
Cindy E. Shaeffer, and the Mother, Michelle Hodge, with her
counsel, Michael Rundle, Esquire.
3. The parties agreed to the entry of an order in the form as
attached.
_
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Date Hubert X. Gilroy, Ea ire
Custody Conciliate
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RecerFt for Certified•e"rr
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PATRICK L. HODGE, : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANI
Plaintiff
CIVIL ACTION - LAW
V. NO. 95-6243
MICHELLE HODGE.
Defendant : IN CUSTODY
CERTIFICATF. OF SERVICE
I, Cindy E. Shcaffcr, Attorney for the Plaintiff, hereby certify that I have served a true
and correct copy of said Complaint for Custody and Order of Court on Michelle Hodge.
residing at 530 First Street. Carlisle. PA 17013, by depositing a copy of the sanuv in ilic
United States mail, certified delivery, return receipt requested, postage prepaid, d,vy 23id l',%
of July, 1996.
u?
Cindy E. affcr, F. quire L
Attorney 1W. No. 70327
P. O. Box 267
Enola. PA 17025
(717) 732-7971
PATRICK L. HODGE,
Plaintiff
V.
MICHELLE HODGE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 95-6243
CIVIL ACTION - LAW
IN CUSTODY
THIS MODIFICATION AND AGREEMENT entered into the day and year hereinafter set
forth, by and between PATRICKL. HODGE, (hereinafter referred to as "Father") and MICHELLE
HODGE, (hereinafter referred to as "Mother").
WHEREAS, the parties are the natural parents of one child, namely LEANISHA RENEE
HODGE born July 3, 1992 (hereinafter referred to as "Child"); and
WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive
stipulation and agreement relative to physical and legal custody of their Child.
NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as
hereinafter set forth, the parties stipulate and agree as follows:
1. Legal Custody:
a. The parties will share joint legal custody of LeaNisha Renee Hodge. The parties agree
that major decisions concerning their Child, including, but not necessarily limited to, the
Child's health, welfare, education, religious training and upbringing shall be made by
them jointly, after discussion and consultation with each other, with a view toward
obtaining and following a harmonious policy in the Child's best interest. Each party
agrees not to impair the other party's rights to shared legal custody of the Child. Each
party agrees not to attempt to alienate the affections of the Child from the other party.
Each party shall notify the other of any activity or circumstance concerning their Child
that could reasonably be expected to be of concern to the other. Day to day decisions
shall be the responsibility of the parent then having physical custody. With regard to any
emergency decisions, which must be made, the parent having physical custody of the
Child at the time of the emergency shall be permitted to make any immediate decisions
necessitated thereby. However, that parent shall inform the other of the emergency and
consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309,
2
each party shall be entitled to complete and full information from any doctor, dentist,
teacher, professional or authority and to have copies of any reports or information
given to either party as a parent as authorized by statute. Mutual agreement should be
made, in advance, regarding the following matters: enrollment or termination in a
particular school or school program, advancing or holding the Child back in school,
authorizing enrollment in college, authorizing their Child's driver's license or purchase
of an automobile, authorizing employment, authorizing either Child's marriage or
enlistment in the armed forces, approving a petition for emancipation, authorizing
foreign travel, passport application or exchange student status.
2. Physical Custody:
a. Primary physical custody of the Child shall begin with Father on Tuesday, January 1,
2008.
b. Mother shall have partial physical custody of the Child as the parties may agree based on
Mother's work schedule.
c. The receiving party shall provide transportation, unless agreed otherwise.
d. The parent with physical custody during any given period of time shall communicate in
a prompt fashion with the other parent concerning the well-being of their Child, and
shall appropriately notify the other parent of any changes in health or educational
progress. Each parent shall execute any and all legal authorizations so that the other
parent may obtain information from the Child's schools, physicians, psychologists, or
other individuals concerning their progress and welfare.
3. Holidays:
a. The parties will share and/or alternate all major holidays. These will include the
following:
1. New Year's Day, Easter, Memorial Day, Fourth of July, Labor Day, and
Thanksgiving, Christmas Eve and Christmas Day.
b. Mother's Day
1. Mother will have physical custody of the Child on Mother's Day.
c. Father's Day
1. Father will have physical custody of the Child on Father's Day.
d. The holiday schedule shall take precedence over the regular custody schedule.
3
4. Summer:
a. During the summer months, Mother will be afforded at least a week (seven consecutive
days) of vacation with the Child, as long as she provides at least sixty (60) days written
notice to the other party of her selected weeks; as well as, the destination of the vacation
and a number where the Child can be reached.
5. Telephone Contact:
a. Each parent shall be entitled to reasonable telephone contact with the Child which shall
not be excessive as well as daily contact via e-mail with the Child when in the custody of
the other parent.
6. The parents shall organize ways for their Child to maintain their friendships, extracurricular
activities, and other special interests, regardless of which household they may be in. It is also
suggested that toys, clothes, etc. not become matters of contention. Major gifts should be
discussed and coordinated between the parents.
7. The parents shall permit and support the Child's access to all family relationships. Special
family events such as weddings, family reunions, family gatherings, funerals, graduations,
etc. shall be accommodated by both parties with routine visitations resuming immediately
thereafter. Each parent shall have the option of proposing time or date variations to the
other parent when special recreational options or other unexpected opportunities arise.
Each parent must confer with the other parent before arranging regularly occurring
extracurricular activities for the Child which might interfere with regular visitation.
8. During any period of custody or visitation the parties to this Order shall not possess or use
any controlled substance, nor shall they consume alcoholic beverages to the point of
intoxication, nor smoke cigarettes inside the residence or vehicle. The parties shall likewise
assure, to the extent possible, that other household members and/or houseguests comply
with this prohibition.
9. No Conflict Zone:
a. Each parent agrees not to attempt to alienate the affections of the Child from the other
and will make a special conscious effort not to do so. Both parents shall establish a no-
conflict zone for their Child and refrain from making derogatory comments about the
other parent in the presence of the Child and, to the extent possible, shall not permit
third parties from making such comments in the presence of the Child whether the
Child is sleeping or awake. Each parent shall speak respectfully of the other whether it
4
is believed the other reciprocates or not. Each parental figure shall refer to the other by
the appropriate role name such as Mom, Dad, your grandmother, etc. Each parent
should agree to refrain from encouraging the Child to provide reports about the other
parent. Communication should always take place directly between parents, without
using the Child as an intermediary. Each parent should encourage their Child to send
the appropriate holiday cards to the other parent.
10. Domestic Relations
a. Father agrees that with the signing of this Court Order to Modify Custody giving him
primary physical custody of the minor Child, he will not file a Petition for Child Support
at the Domestic Relations office in Cumberland County, Pennsylvania or in Baltimore
City, Maryland; unless there is a significant change in circumstance.
11. The parties stipulate that in making this Agreement, there has been no fraud, concealment,
overreaching, coercion, or other unfair dealing on the part of the other party.
12. The parties acknowledge that they have read and understand the provisions of this
Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is
not the result of any duress or undue influence.
WITNESSETH:
1
v
DATE
u?
DATE
PATRICK L. HODGE
MICELLE WODGE?5
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF ?l,tMiC?,AIWJJ
On this C?Y!L6 day of ern 2007, before me, the undersigned officer, personally
appeared PATRICK L. HODGE, known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Agreement, and acknowledged that she executed the same for the
purposes therein contained.
NOTARY PUBLIC
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Shannon L Freeman, Notary Public
Chambersburg Boro, Franklin County
My Commission Expires Apr. 7, 2009
COMMONWEALTH OF PENNSYLVANIA Member, Pennsylvania Association of Notaries
SS.
COUNTY OF eumber?-qnj
On this d 76 day of 6M , 2007, before me, the undersigned officer, personally
appeared MICHELLE HODGE, known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Agreement, and acknowledged that she executed the same for the
purposes therein contained.
OTARY PUBLIC
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Shannon L. Freeman, Notary Public
Chambersburg Boro, Franklin County
My Commission Expires Apr. 7, 2009
Member, Pennsylvania Association of Notaries
6
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PATRICK L. HODGE,
Plaintiff
V.
MICHELLE HODGE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6243
CIVIL ACTION - LAW
IN CUSTODY
AND NOW thisA?X_ day of 2008, the attached Custody
Modification and Agreement is hereby made an Order of Court.
Distribution:
Michelle L. Sommer, Esquire
Attorney for the Plaintiff
Abom & Kutulakis, L.L.P.
36 South Hanover Street
Carlisle, PA, 17013
Michelle Hodge
Pro Se Defendant
159 Lincoln Street
Carlisle, PA 17013
0a y Y-11A L L-C
?I
OM &
U ULAKIS
Michelle L. Sommer, Esquire
Attorney I.D. #: 93034
36 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
PATRICK L. HODGE,
Plaintiff
V.
MICHELLE HODGE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 95-6243
CIVIL ACTION -LAW
IN CUSTODY
TO THE HONORABLE EDGAR B. BAYLEY, JUDGE OF SAID COURT:
PETITION FOR CIVIL CONTEMPT
AND NOW, this 25 h day of January, 2008, comes the Petitioner, Patrick L. Hodge,
by and through his counsel, Michelle L. Sommer, Esquire, of ABOM & KUTULAKIS,
L.L.P., and files this Petition for Contempt and in support thereof avers the following:
1. Petitioner is Patrick L. Hodge, who is the Plaintiff in the above captioned action
between the parties.
2. Respondent is Michelle Hodge who is the Defendant in that action.
3. On or about January 2, 2008, This Honorable Court entered a Court Order on a
Custody Modification and Agreement. A true and correct copy of the Order of
Court is attached hereto as Exhibit A.
4. Respondent's obligations under This Court's Order have not, to date, been met in
full.
5. Respondent is in Contempt of Court for willfully failing to comply with the Order
of Court dated January 2, 2008, in that:
i. Respondent has refused to allow the minor child, LeaNisha Renee Hodge
(born July 3, 1992), to relocate to Baltimore, Maryland with her Father.
ii. Respondent has refused to allow the minor child to have contact with the
Father since the signing of the Court Order on January 2, 2008.
iii. Respondent and Petitioner have a fully executed agreement after multiple
conversations about the language and terms of the Modification and
Agreement to Custody through undersigned Counsel with Respondent
executing her Agreement on December 27, 2007 and the Petitioner
executing his Agreement on December 28, 2007.
iv. On January 1, 2008, the date of the custody exchange and relocation, the
minor child had some anxiety issues regarding relocating to another state
and starting a new school and she refused to leave; however, Respondent
refused to allow the Petitioner to have any contact with his minor child in
order to alleviate her fears and anxieties about the relocation.
v. It is believed and therefore averred Respondent refused to allow the
Petitioner to have any contact with his minor child on the day of the
exchange because she no longer wanted the child to relocate and has in
fact kept the Petitioner from having any contact with the minor child since
that day.
vi. It is believed and therefore averred that Respondent is taking advantage
of the minor child's fears about relocating and will not allow her to leave
after an agreement was reached between the parties and a Modification
and Agreement was signed by the Respondent on December 27, 2007.
6. Respondent has had the ability to comply with the relevant provisions of the
Order of the Court Order but has willfully failed to do so.
7. Respondent's breach of the terms of the Agreement is the sole reason Petitioner
had to file this petition for enforcement.
8. Petitioner has incurred attorney's fees and costs in connection with the
preparation and pursuit of this Petition and Respondent should be held
responsible for said costs.
WHEREFORE, Petitioner respectfully requests that this Honorable Court
enter an Order finding Respondent in Contempt of Court and directing Respondent to
immediately comply with This Honorable Court's Order, plus pay Petitioner's counsel fees
and costs.
Respectfully submitted,
ABOM & KUTULA"S. L.L.P.
Michelle L. So er, Esquire
Attorney I.D No.: 930344
36 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 249-0900
.Attorney for Petitioner
I, PATRICK L. HODGE, verify that the statements made in this Petition for
Contempt are true and correct to the best of my knowledge, information, and belief. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
§4904 relating to unsworn falsification to authorities.
Date C?
PATRICK L. HODGE
'JAN 2 200?
PATRICK L. HODGE, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 95-6243
MICHELLE HODGE, CIVIL ACTION - LAW
Defendant IN CUSTODY
AND NOW this 'vG\ day of 'ZAX 2008, the attached Custody
Modification and Agreement is hereby made an Order of Court.
BY THE COURT,
J.
12
Distribution:
Michelle L. Sommer, Esquire
Attorney for the Plaintiff
Abom & Kutulakis, L.L.P.
36 South Hanover Street
Carlisle, PA, 17013
Michelle Hodge
Pro Se Defendant
159 Lincoln Street
Carlisle, PA 17013
TRUE C 11" ?.x RE Cod
in "f stimeny r - l '
SiejA u{;to satiny halsu,
and the seal ?oof(said Court at Carlisle, N.
This f.. J u?"
4?VDa: •ee?e
" ee a ofhonwary
PATRICK L. HODGE,
Plaintiff
V.
MICHELLE HODGE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6243
CIVIL ACTION - LAW
IN CUSTODY`
o -n
Vii] C?
CUSTODY MO IFI .ATIOIN AND AGREEMENT t' ? ?>}C
C.ri -K
THIS MODIFICATION AND AGREEMENT entered into the day and year hereinafter set
forth, by and between PATRICKL. HODGE,, (hereinafter referred to as "Father") and MICHELLE
HODGE, (hereinafter referred to as "Mother").
WHEREAS, the parties are the natural parents of one child, namely LEWISHA RENEE
HODGE, born July 3, 1992 (hereinafter referred to as "Child"); and
WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive
stipulation and agreement relative to physical and legal custody of their Child.
NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as
hereinafter set forth, the parties stipulate and agree as follows:
1. Legal Custody:
a. The parties will share joint legal custody of LeaNisha Renee Hodge. The parties agree
that major decisions concerning their Child, including, but not necessarily limited to, the
Child's health, welfare, education, religious training and upbringing shall be made by
them jointly, after discussion and consultation with each other, with a view toward
obtaining and following a harmonious policy in the Child's best interest. Each party
agrees not to impair the other party's rights to shared legal custody of the Child. Each
party agrees not to attempt to alienate the affections of the Child from the other party.
Each party shall notify the other of any activity or circumstance concerning their Child
that could reasonably be expected to be of concern to the other. Day to day decisions
shall be the responsibility of the parent then having physical custody. With regard to any
emergency decisions, which must be made, the parent having physical custody of the
Child at the time of the emergency shall be permitted to make any immediate decisions
necessitated thereby. However, that parent shall inform the other of the emergency and
consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. X5309,
2
each party shall be entitled to complete and full information from any doctor, dentist,
teacher, professional or authority and to have copies of any reports or information
given to either party as a parent as authorized by statute. Mutual agreement should be
made, in advance, regarding the following matters: enrollment or termination in a
particular school or school program, advancing or holding the Child back in school,
authorizing enrollment in college, authorizing their Child's driver's license or purchase
of an automobile, authorizing employment, authorizing either Child's marriage or
enlistment in the armed forces, approving a petition for emancipation, authorizing
foreign travel, passport application or exchange student status.
2. Physical Custody:
a. Primary physical custody of the Child shall begin with Father on Tuesday, January 1,
2008.
b. Mother shall have partial physical custody of the Child as the parties may agree based on
Mother's work schedule.
c. The receiving party shall provide transportation, unless agreed otherwise.
d. The parent with physical custody during any given period of time shall communicate in
a prompt fashion with the other parent concerning the well-being of their Child, and
shall appropriately notify the other parent of any changes in health or educational
progress. Each parent shall execute any and all legal authorizations so that the other
parent may obtain information from the Child's schools, physicians, psychologists, or
other individuals concerning their progress and welfare.
3. Holidays:
a. The parties will share and/or alternate all major holidays. These will include the
following:
1. New Year's Day, Easter, Memorial Day, Fourth of July, Labor Day, and
Thanksgiving, Christmas Eve and Christmas Day.
b. Mother's Day
1. Mother will have physical custody of the Child on Mother's Day.
c. Father's Day
1. Father will have physical custody of the Child on Father's Day.
d. The holiday schedule shall take precedence over the regular custody schedule.
3
4. Summer:
a. During the summer months, Mother will be afforded at least a week (seven consecutive
days) of vacation with the Child, as long as she provides at least sixty (60) days written
notice to the other party of her selected weeks; as well as, the destination of the vacation
and a number where the Child can be reached.
5. Telephone Contact:
a. Each parent shall be entitled to reasonable telephone contact with the Child which shall
not be excessive as well as daily contact via e-mail with the Child when in the custody of
the other parent.
6. The parents shall organize ways for their Child to maintain their friendships, extracurricular
activities, and other special interests, regardless of which household they may be in. It is also
suggested that toys, clothes, etc. not become matters of contention. Major gifts should be
discussed and coordinated between the parents.
7. The parents shall permit and support the Child's access to all family relationships. Special
family events such as weddings, family reunions, family gatherings, funerals, graduations,
etc. shall be accommodated by both parties with routine visitations resuming immediately
thereafter. Each parent shall have the option of proposing time or date variations to the
other parent when special recreational options or other unexpected opportunities arise.
Each parent must confer with the other parent before arranging regularly occurring
extracurricular activities for the Child which might interfere with regular visitation.
8. During any period of custody or visitation the parties to this Order shall not possess or use
any controlled substance, nor shall they consume alcoholic beverages to the point of
intoxication, nor smoke cigarettes inside the residence or vehicle. The parties shall likewise
assure, to the extent possible, that other household members and/or houseguests comply
with this prohibition.
9. No Conflict Zone:
a. Each parent agrees not to attempt to alienate the affections of the Child from the other
and will make a special conscious effort not to do so. Both parents shall establish a no-
conflict zone for their Child and refrain from making derogatory comments about the
other parent in the presence of the Child and, to the extent possible, shall not permit
third parties from making such comments in the presence of the Child whether the
Child is sleeping or awake. Each parent shall speak respectfully of the other whether it
4
is believed the other reciprocates or not. Each parental figure shall refer to the other by
the appropriate role name such as Mom, Dad, your grandmother, etc. Each parent
should agree to refrain from encouraging the Child to provide reports about the other
parent. Communication should always take place directly between parents, without
using the Child as an intermediary. Each parent should encourage their Child to send
the appropriate holiday cards to the other parent.
10. Domestic Relations
a. Father agrees that with the signing of this Court Order to Modify Custody giving him
primary physical custody of the minor Child, he will not file a Petition for Child Support
at the Domestic Relations office in Cumberland County, Pennsylvania or in Baltimore
City, Maryland; unless there is a significant change in circumstance.
11. The parties stipulate that in making this Agreement, there has been no fraud, concealment,
overreaching, coercion, or other unfair dealing on the part of the other party.
12. The parties acknowledge that they have read and understand the provisions of this
Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is
not the result of any duress or undue influence.
WITNESSETH:
DATE
- DATf
--? ' - +
E
?i i7 e? C2
PATRICK L. HODGE
MIC E5
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF 1 I LLm `it'd fa?C? On this day of Jf'1(-'e1nbL-j-, 2007, before me, the undersigned officer, personally
appeared PATRICK L. HODGE, known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Agreement, and acknowledged that she executed the same for the
purposes therein contained.
NOTARY PUBLIC
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Shannon L. Freeman, Notary Public
Chambersburg Boro, Franklin County
My Commission Expires Apr. 7, 2009
COMMONWEALTH OF PENNSYLVANIA Member Pennsylvania A-'"ciatinn of Notaries
j1 J SS.
COUNTY OF f u X n kt° d_ n C'
On this ,d 7th day of 6M , 2007, before me, the undersigned officer, personally
appeared MICHELLE HODGE, known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Agreement, and acknowledged that she executed the same for the
purposes therein contained.
J
NOTARY PUBLIC
COMMONV&AL1 H 0r- PENNSYLVANIA
Notarial Seal
Shannon L. Freeman, Notary Public
Chambersburg Boro, Franklin County
My Commission Expires Apr. 7, 2009
Member, Pennsylvania Association of Notaries
6
PATRICK L. HODGE,
Plaintiff
V.
MICHELLE HODGE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 95-6243
CIVIL ACTION - LAW
IN CUSTODY
AND NOW, this 25"' day of January, 2008, I, Michelle L. Sommer, Esquire, hereby
certify that I did serve a true and correct copy of the foregoing PETITION FOR CIVIL
CONTEMPT upon the Respondent of record via certified mail, restricted delivery, return
receipt requested, addressed as follows:
Michelle Hodge
159 Lincoln Street
Carlisle, PA 17013
ABom & KurULASIS, L.L.P.
Michelle L. So , Esquire
Attorney I.D No.: 93034
36 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 249-0900
Attorney for Petitioner
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PATRICK L. HODGE IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
MICHELLE HODGE
DEFENDANT
1995-6243 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, January 29, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, February 28, 2008 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. 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/ Hubert X. Grim Es q.
Custody Conciliator -pr I
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
400
.71-17
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MAR 0 5 2006
PATRICK L. HODGE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
MICHELLE HODGE NO. 1995-6243
Defendant IN CUSTODY
COURT ORDER
` (aA-A
AND NOW, this r C day of X4bmaf?, 2008, upon consideration of the attached
Custody Conciliation Report, it is ordered and directed as follows:
1.
2.
Father's Petition to hold Mother in contempt is held in abeyance pending further Order of
this Court.
The Existing Court Order of January 2, 2008, is modified on a TEMPORARY basis as
follows:
a. Mother shall continue to have primary physical custody and the minor child shall
continue to attend the Carlisle Area School District.
b. Father shall enjoy temporary custody on alternating weekends from Friday
evening until Sunday evening. If Mother's work schedule is compatible with
transportation, Father shall handle transportation on Friday and the parties shall
meet halfway between Baltimore and Carlisle on Sunday.
C. Legal counsel for the parties shall select a counselor to work with the minor child
to identify her desires with respect to a custody arrangement and also identify other
appropriate issues that will aid the child and both parents in maintaining a healthy
relationship. The counselor shall be independent and shall have the ability to share
the results of the counseling with both parties and legal counsel for both parties.
After any applicable insurance is used for payment of the counselor, the
counselor's expenses shall be paid equally by the parties.
3. If there are any difficulties with the custody arrangement or other matters in this Order,
legal counsel for the parties may contact the Conciliator directly without the need of filing
any petition to either schedule another Custody Conciliation Conference or conference call
with the Conciliator to address those issues.'
cc: " Dirk Berry, Esquire
-Michelle Sommer, Esquire
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MUJ -t
PATRICK. L. HODGE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
MICHELLE HODGE NO. 1995-6243Defendant : IN CUSTODY
PRIOR JUDGE: Honorable Edgar B. Bayley
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information pertaining to the child who is the subject of this litigation is as
follows:
LeaNisha Renee Hodge, born July 3, 1992.
2. A Conciliation Conference was held on February 21, 2008, with the following
individuals in attendance:
Michelle Hodge, Mother, was present with her counsel, Dirk Berry, Esquire, and
Patrick L. Hodge, Father, with his counsel, Michelle Sommer, Esquire.
3. The parties agreed to the entry of an Order in the form as attached.
? I a ? ?L
Date: 3
ubert X. Gilro , Esquire
Custody Concil ator