Client seeks primary physical custody of her ten-year-old daughter. The existing custody order provides OP/father primary custody at his residence in Sicklerville, NJ and requires client, who has no car, to travel from Philadelphia to pick up and drop off her daughter. The current order notes that educational opportunity is greater in Sicklerville than in Philadelphia, or in the school in Minneapolis where client proposed to relocate. However, client’s daughter was frequently truant while in father’s custody because OP does not take her to school regularly. OP, who is represented, also has a history of abusive behavior towards client and daughter. Client has had difficulty complying with the present order, and a contempt hearing is scheduled for June 24, 2019, at 9:00 am before Judge Michael Fanning. A volunteer is needed to file a petition to modify custody and defend client in the upcoming contempt hearing. The client understands that representation may be limited to the contempt hearing and modification of the current order and has agreed to sign a pro se entry of appearance when the representation is concluded.

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