HomeMy WebLinkAbout96-05836
MARK S, PIERUCCINI, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I
I CUMBERLAND COUNTY, PENNSYLVANIA
I
V. I CIVIL ACTION - LAW
I
I 96-5836 CIVIL TERM
SELMA J, PIERUCCINI, I
Defendant I IN CUSTODY
IN REI CUSTODY AGREEMENT
Proceedings held before the Honorable KEVIN A.
HESS, J., Cumberland County Courthouse, Carlisle,
Pennsylvania, on Friday, April 25, 1997, in
Court:oom Number Four.
APPEARANCES:
CHRISTOPHER HOUSTON, Esquire
For the Plaintiff
JOAN CAREY, Esquire
Legal Services, Inc,
For the Defendant
1 MR. HOUSTON: Good afternoon, Your Honor,
2 For the record, as we had indicated earlier when we met in
3 chambers with you, the parties have substantially reached an
4 agreement concerning issues regarding custody of the three
5 children -- excuse me, four children, subject to these
6 proceedings. Should I just outline for the record what we
7 had talked or.,.
8 THE COURT: Yes. I think what we can do io
9 we can outline for the record where there are areas of
10 agreement, and then where there are areas of disagreement,
11 and I will have the matter transcribed and study it based on
12 the testimony I have heard and enter an order in the next
13 several days.
14 MR. HOUSTON: The parties have agreed that
15 for purposes of jurisdiction that the father will have
16 primary custody, The parties have agreed that the parties
17 will otherwise share legal custody and physical custody, on
18 a schedule whereby father would have primary custody during
19 the school year, and the mother would have custody for a
20 period of eight weeks during the summer,
21 The parties have also agreed that for
22 Christmas vacation that mother would have custody on a
23 schedule of three Christmases, two out of the three
24 Christmases.
25 The parties have also agreed that they will
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1 exchange information concerning the children, including such
2 things as any counselors, names and addresses and telephone
3 numbers, medical providers, school infornlation and school
4 calendar, day-care information, including baby-sitters.
5 Mother would have telephone contact with the
6 children, and the father would have telephone contact with
7 the children when they are in the other party's respective
8 period of custody, at least once per week that they would be
9 permitted to call, And that if the children wanted to call
10 the parent that at the time does not have custody that the
11 parent that does have custody would facilitate that and
12 permit the children to be able to contact the other parent,
13 The parties have also agreed that father will
14 notify the mother if he intends on moving by giving at least
15 sixty days notice. We didn't actually discuss this
16 MS, CAREY: I was thinking ninety, but,..
17 MR, HOUSTON: Whatever, he is willing to give
18 sixty days notice. And he would also ask, I know we didn't
19 talk about this before, but he would also ask if she changes
20 her address that she would provide him with a change of
21 address. He would reque~t the same notice.
22 And with respect to transportation, the
23 parties would share tranDportation. I think we are going to
24 have to leave that somewhat flexible as far as where the
25 location is going to be, and they will just have to work
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those details out, but I guess the general intent here is
that the parties would drive and meet someplace halfway
with respect to the tranafers,
The father has indicated that he will be
agreeable at such times as the mother comes to Pennsylvania,
that he will facilitate and provide opportunities for her to
have the children when she is up here. And at such other
reasonable times as the parties can work out times when she
could have the,children. I think that's what I would
present as far as what I understand we have agreed to.
THE COURT: Okay.
MS. CAREY: Your Honor, in terms of custody
during the school year, we agreed that there would be shared
physical custody. I don't think we agreed that it would be
primary during the school year, We were agreed to not have
terms in there like that, that she would have custody in the
summer, and he would have custody during the school year
except for the times that we agreed to, Christmas and other
times that she is up in the area where the children reside.
She wants it to be clear that if she comes to
vinit the children she would be able to take the children on
trips or away from the father's home if she comes to this
area.
Regarding the summer, she wanted to maximize
her time a minimum of eight weeks, but she would like to
4
1 start from one week after school lets out until one week
2 before Achool begins.
3 And we also wanted to include that nothing in
4 the order would preclude her having additional time with the
5 children who aren't in school if she was able to work that
6 out. For example, at Thanksgiving time to get the younger
7 children, take them with her for an additional few weeks,
8 and then they would all return at the end of the Christmas
9 vacation, I presume that could happen at the beginning or
10 end of the summertime, until the beginning of the
11 summertime, or any other time that she can work it out.
12 And lastly, we would like the order to
13 contain a provision that neither party would alienate the
14 children from the other parent, say anything disparaging in
15 front of the other parent, And I think we agreed that the
16 mother would have Christmas '97 and '98,
17 MR. HOUSTON: We didn't actually talk about
18 any time periods.
19 MS. CAREY: We would like Christmas '97 and
20 '98 since he just had Christmas last year, And when we talk
21 about Christmas that's from the time the children are out of
22 school until the time that they go back to school.
23 THE COURT: And we are agreed about that? We
24 are talking about the entire -- rather than try to break up
25 the period, we are talking about the entire time?
5
1 MR. HOUSTON: Correct.
2 MS. CAREY: In terms of the spring visit,
3 Your Honor, if the school break is not long enough to have
4 the mother be able to take the children to Texas, then she
5 would try to come to the area where they are residing and
6 have them for a period of time, and any other time that she
7 can get off work.
S THE COURT: Okay.
9 MR. HOUSTON: Just as far as a comment based
10 on those points, my client, again, is willing to indicate
11 that he is willing to be reasonable in trying to work out
12 other arrangements other than the summer and Christmas, He
13 does not feel it is appropriate to put in the order now any
14 specific provisions concerning the baby and time periods
15 that mother would have the baby other than that specific
16 Christmas holiday and the summer vacation.
17 THE COURT: Well, my inclination, as I play
lS with this in my mind, my inclination would be to fashion
19 perhaps some length of time that would be deemed in the eyes
20 of the court reasonable, I think to say keep the two
21 youngest children at the end of the summer all the way until
22 the following Christmas would be tantamount to separating
23 the siblings and would result in quite a different custody
24 arrangement than is contemplated. On the other hand, it
25 seems to me that if there is a time period, perhaps as long
6
1 as a month in which she has the children and then wants to
2 keep one or two of them for awhile, particularly while the
3 two older ones are in school, it se8mS to me that for a
4 reasonable period that that would be quite acceptable, not
5 to be exceeded, given the fact that the parties are
6 separated by such distance, But I will fine-tune that. I
7 understand his position on that issue.
8 MR. HOUSTON: The third child is starting
9 school, Shauna is starting school this fall.
10 THE COURT: So as a practical matter we are
11 only talking about the one child when push comes to shove.
12 MR, HOUSTON: And just so my client
13 understands, when we talk about this term primary custody,
14 we just want to make sure that, and I think when we agreed
15 upon this, that for purposes of jurisdiction that this is
16 the state of jurisdiction, And that other than that she has
17 them during the summer, and then you have them during the
18 school year. Do you understand that?
19 MR. PIERUCCINI: Yes,
20 THE COURT: And l~t me just say that, that's
21 the basic agreement, so that the question of primary custody
22 if you will has been resolved by the parties, and 80 then
23 fine-tuning the matters of partial custody is always, you
24 know, in this case like any other it is up to the court
25 ultimately, So neither of you have lost anything by not
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having more testimony this afternoon. I just want to assure
you I have enough information about the case where I think I
oan make an intelligent decision concerning what to you are
very important matters but actually to the court are minor
compared to the underlining question, and that is where are
the kids during the school year and where are the kids
during the holidays. You have resolved the major issue, and
I will resolve those finer points. Is there anything either
of you want to say about anything else?
MR. HOUSTON: Yes, Your Honor. There was the
matter of the proceedings in Texas. I think you had already
signed the order on jurisdiction. I think if we could have
a copy of that today so that we can get that down to Texas.
And I will advise my client's attorney in Texas that you
would be available if there would be any question next week
from the court down there,
THE COURT:
MS. CAREY:
Absolutely,
I have the fax number of her
counsel down there, I can fax that order, you say you
already signed it?
THE COURT: Yes.
(End of proceedings.)
8
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mlrkpltr.mem
MARK S. PIERUCCINI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
v
96-5B36 CIVIL TERM
SELMA J. PIERUCCINI,
Defendant
CUSTODY
PLAINTIFF'S HEARING MEMORANDUM
I. FACTS
On or about October 23, 1996, the Plaintiff filed a Complaint
for Custody and Petition for Special Relief seeking primary custody
of the minor children, Stephanie A. Pieruccini, date of birth
December lB, 19B5, Angela M. Pieruccini, date of birth July 29,
19~7, Shauna T. pieruccini, date of birth July 1, 1992, and Anthony
W. Pieruccini, date of birch February 4, 1996.
The ~inor children have been residing with their Father in
Pennsylvania since ~eptember 6, 1996. The Father had moved from
Texas where the Father had resided with the Defendant/Mother since
approximately May 1995. When Father came to Pennsylvania with the
children, he moved to his mother-in-law and brother-in-law's
residence in Shippensburg, Pennsylvania. Mother had grown up in
Pennsylvania, and the minor children have had a number of visits to
Pennsylvania. The school-age children are now currently enrolled
in the Shippensburg School District and attending the Church of the
Brethren Church in Shippensburg,
Father is employed in Pennsylvania and intends on staying in
Pennsylvania.
.
access to relevant evidence about the child and family." fuUnes v
Williams,
Super __,
, 635 A,2d 1077, 1081 (1993).
In Baines, the Superior Court determined under a "significant
contact" or parens partriae analysis, that the courts of
Pennsylvania should confer jurisdiction under the following factual
scenario:
Appellant testified at the February 23, 1993, hearing
that she was born and reared in Bucks County and that she
has extensive numbers of family members living there,
including her parents, two brothers, various aunts,
uncles, and cousins. She further testified that she and
her children are currently residing with her divorced
brother and his two children, ages 7 and 11, in a six
bedroom, two bathroom house in Levittown, Bucks County.
As part of her living arrangement with her brother,
Appellant takes care of the house and the children while
her brother works. Appellant's son, Bobby, attends
school in Bucks I,;ounty and is doing well. Appellant
further testified that all of the children are thriving
in Bucks County, are clean, well fed, properly clothed,
have many young relatives and neighborhood friends with
whom to play, and have no desire to return to Alabama.
Appellant also testified to her intention to remain in
Bucks County. Baines. supra at 1081.
The facts as presented in this case are that the Mother was
reared in Pennsylvania until she married Husband in 1985. Her
mother and two brothers live in Cumberland County. The children
initially resided with their grandmother and one uncle. The
children are currently enrolled in a school system located in
Cumberland County and appear to be doing fairly well in school.
The children have friends in the neighborhood where they now
3
MARK S. PIERUCCINI, : IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
. 5'83(;
v 96- CIVIL TERM
SELMA J. PIERUCCINI, CIVIL ACTION - LAW
Defendant .
.
: IN CUSTODY
ORDER
AND NOW, this
day of October, 1996, upon a Complaint for
Custody and ?etition for Special Relief, it is hereby ordered and
directed that, pending a Custody Conciliation Conference and
further Order of Court, temporary legal and physical custody of the
minor children, Stephanie A. Pieruccini, date of birth December 18,
1985, Angela M. Pieruccini, date of birth July 29, 1987, Shauna T.
Pieruccini, date of birth July 1, 1992, and Anthony W. Pieruccini,
date of birth February 4, 1996, is awarded to the Father, Mark S.
pieruccini.
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By the Court,
J.
MARK S. PIERUCCINI, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
:
v 96- CIVIL TERM
SELMA J. PIERUCCINI, CIVIL ACTION - LAW
Defendant
. IN CUSTODY
.
ORDER OF COURT
AND now, this
consideration of the
the parties and
day of , 1996, upon
attached Petition, it is hereby di~ected that
their respective counsel appear before
Esquire, the Conciliator, at
, on the day of
, 1996, at .M., 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,
By the Court,
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law
to comply with the Americans with Disabilities 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 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
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
717 - 240-6200
pMtNccl.com
MARK S. PIERUCCINI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
96- SB 3"
CIVIL TERM
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.
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SELMA J. PIERUCCINI,
Defendant
CIVIL ACTION - LAW
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IN CUSTODY
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COMPLAINT FOR CUSTODY AND PETITION FOR SPECIAL RELll&F . ; :,J
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AND NOW, comes the Plaintiff, Mark S. Pieruccini, by andthrd4gh.!
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his attorneys, Broujos, Gilroy & Houston, P.C., who avers as
follows:
1
The Plaintiff is Mark S. Pieruccini, residing at 206 South Queen
Street, Shippensburg, Cumberland County, Pennsylvania.
2
The Defendant is Selma J. Pieruccini, last known to be residing at
9249 Twin Lakes Drive, Orange, Texas 77632.
3
Plaintiff seeks custody of the following children:
Name President Residence
Aqe
Stephanie A. Pieruccini 206 South Queen Street
Shippensburg, PA 17257
Angela M. Pieruccini 206 South Queen Street
Shippensburg, PA 17257
Shauna T. Pieruccini 206 South Queen Street
Shippensburg, PA 17257
Anthony w. Pieruccini 206 South Queen Street
Shippensburg, PA 17257
10
9
4
8 mo.
The children were not born out of wedlock.
5
The relationship of the Defendant to the children is that of
mother. The Defendant, it is believed, currently resides with the
following persons:
Name
Danny Meehan
Relationship
Paramour
6
Plaintiff has not participated as a party or witness, or in another
capacity in other litigation concerning the custody of the children
in this or another court.
7
The Plaintiff has no information of a custody proceeding concerning
the children pending in a court of this Commonwealth or any other
jurisdiction.
8
The Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the children or claims to
have custody or visitation rights with respect to the children.
9
The best interest and permanent welfare of the children will be
served by granting the relief requested because of tho. following:
A. Shortly after the birth of the parties' youngest child, the
Mother went into a deep depression and became suicidal,
B. Since February 1996, the Mother has been on various
medications to deal with her depression and anxiety.
C. Since April of 1996, the Mother has had a pattern of staying
out late after work and often not returning until the next day.
D. In February of this year, the Father quit his job while the
parties were living in Texas, so as to care for the children due to
Mother's inability to properly care for the children.
E. Mother has an ongoing ralationship with her paramour, Danny
Meehan, and has allowed Mr. Meehan to drive a vehicle while under
the influence of alcohol with the children in the vehicle.
F. On September 2, 1996, the Mother acted in a bizarre manner
while the family was on an excursion which included attempting to
jump out of the family vehicle on several different times while the
children were in the vehicle and consumed numerous prescription
drugs causing the Mother to act in an even more bizarre fashion,
all of which culminated in the Mother indicating that she was going
to move out of the family home in Texas.
G. On September 2, 1996, while the Mother was packing up her
belongings to leave the family residence, she continued to act in
a bizarre manner throwing items out of the house, running into a
glass storm door, all of which caused fear in the Father and in the
children. Father eventually summoned the police who appeared at
the family residence shortly after the Mother had left.
H. On September 3, 1996, Mother and Father met to discuss moving
to Shippensburg, Pennsylvania, which is where Mother's family
resides, so as to get family support for the parties during
Mother'. poriod of difficulties. Mother indicated that she needed
time to think about whether ahe wanted to leave or not, but stated
that Father should leave and take the children with him.
I. On September 4, 1996, Father and the children departed Texas
for Shippensburg, Pennsylvania, but only after Father checked with
the .chool authorities and obtained the two older children's school
record. for purposes of enrolling them in school here in
psnnsylvania.
J. On September 6, 1996, Father and the children arrive at
Mother's family home in Shippensburg, Pennsylvania, and on
September 8 the two older children were registered in school and
begin attending school in the Shippensburg School District.
K. From September 9, 1996, until the present, Mother has
indicated that she intends on moving from Texas to Pennsylvania;
however, her actions indicate otherwise, as follows:
1. She is now, it is believed, living with her
paramour, Danny Meehan;
2. She obtained new employment in Texas; and
3. On or about October 17, 1996, Mother advised Father that
she was going to be filing for divorce.
L. During several telephone conversations with Mother since
Father has been in Pennsylvania, her speech has been slurred,
indicating that she is intoxicated on either drugs or alcohol.
5. The Commonwealth of Pennsylvania should decline to
exercise jurisdiction over the above captioned case for reasons
including the following:
a. Pennsylvania is not the home state of the children
at the time of filing the above captioned case in that:
i. The children have resided in Pennsylvania only
since approximately September 60 1996.
ii. The children had lived in Orange County,
Texas, since approximately August, 1995, when the
father took them to Pennsylvania without the
mother's consent and over her objection. Before
living in Texas, the children had lived in Georgia
for approximately two years, Florida for one and a
half years and George for four years.
b. Neither the children nor the parties have
significant contacts with Pennsylvania in that:
i. The father and children have resided in
Pennsylvania only since September, 1996.
ii. The motheros family is in Pennsylvaniao but
she has not lived with them since 19R5, and the
children have n8ver resided with them until
September, 1996. Furthermore, the mother does not
think it is in the children's best interest to
relocate to Pennsylvania.
ili. Any contacts with Pennsylvania are minimal
and were created by the father over tha mother's
objection; the father filed for custody one month
after fleeing with the children to Pennsylvania.
c. Substantial evidence as to the children's
educationo medical treatment, and religious upbringing
for the last year and evidence for their future careo
protectiono training and personal relationships is in
Orange Count Yo Texas where the children have lived and
where the mother wishes to return them.
d. The father's conduct warrants that this court
decline jurisdiction in that:
i. The father wrongfully took the children from
their home in Texas and brought them to
Pennsylvania without the consent of the mother and
over her objections.
ii. The father intended to benefit his position
in custody by convincing the mother to withdraw
the Protection from Abuse action she had filed
against him in Texas and by removing the children
from the custody of their mother when the Texas
court vacated the Temporary Protection Order which
gave the mother custody. Furthermoreo after the
father fled to Pennsylvania, he deprived the
mother of housing by having her utilities
disconnected, blocklng her access to insurance
- ._-
cards which she needed to register her car, and
threatening her safety at the marital residence.
Additionally, the father harassed the mother at
her place of employment causing her to lose her
job.
e. Pennsylvania is an inconvenient forum in which to
litigate the custody matter for reasons including the
following:
i. The mother presently has no income and cannot
afford to travel to Pennsylvania to litigate the
matter.
ii. Texas is the more appropriate forum and it is
in the children's best interest to hear the case
in that state since the children have significant
connections there, including, school, church,
their home, and friendso and it is where the
children lived for one and a half years prior to
the father's filing this action.
WHEREFORE, the petitioner requests that this court issue a
rule ordering the respondent to show cause why this court should
not decline to exercise jurisdiction over the above-captioned
caseo dismiss the case, and vacate the temporary custody order.
The petitioner further asks the cotJrt to order the
respondent to pay any costs and fees related to litigating this
matter.
.
\
,
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BROUJOS. GILROY 8< HOUSTON. p, c.
ATTOAN&V. AT L..Aw
.. NORTH HANOVI:" .TRIEIn"
CARUSL.B:. PENNSYLVANIA 17013
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OCT 2 31996V
MARK S, PIERUCCINI, IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
. S Ii 3C,
v 96- CIVIL TERM
SELMA J, PIERUCCINI, CIVIL ACTION - LAW
Defendant .
.
IN CUSTODY
ORDER
AND NOW, this L-:Jo:-' day of October, 1996, upon a Complaint for
Custody and Petition for Special Relief, it is hereby ordered and
directed that, pending a Custody Conciliation Conference and
further Order of Court, temporary legal and physical custody of the
minor children, Stephanie A. Pieruccini, date of birth December 18,
1985, Angela M, Pieruccini, date of birth July 29, 1987, Shauna T.
Pieruccini, date of birth July 1, 1992, and Anthony W. Pieruccini,
date of birth February 4, 1996, is awarded to the Father, Mark S.
Pieruccini.
By the Court,
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J.
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pl.ruccl.com
MARK S. PIERUCCINI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
96-
CIVIL TERM
SELMA J. PIERUCCINI,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
COMPLAINT FOR CUSTODY AND PETITION FOR SPECIAL RELIEF
AND NOW, comes the Plaintiff, Mark S. Pieruccini, by and thro~gh
his attorneys, Broujos, Gilroy & Houston, P.C., who avera as
follows:
1
The Plaintiff is Mark S. Pieruccini, residing at 206 South Queen
Street, Shippensburg, Cumberland County, Penlsylvania.
2
The Defendant is Selma J. Pieruccini, last known to be residing at
9249 Twin Lakes Drive, Orange, Texas 77632.
3
Plaintiff seeks custody of the following children:
Name President Residence Aoe
Stephanie A. Pieruccini 206 South Queen Street 10
Shippensburg, PA 17257
Angela M. Pieruccini 206 South Queen Street 9
Shippensburg, PA 17257
Shauna T. Pieruccini 206 South Queen Street 4
Shippensburg, PA 17257
Anthony W. Pieruccini 206 South Queen Street 8 mo.
Shippensburg, PA 17257
The children were not born out of wedlock.
5
The relationship of the Defendant to the children is that of
mother. The Defendant, it is believed, currently resides with the
following persons:
~ Relationship
Danny Meehan Paramour
6
Plaintiff has not participated as a party or witness, or in another
capacity in other litigation concerning the custody of the children
in this or another court.
7
The Plaintiff has no information of a custody proceeding concerning
the children pending in a court of this Commonwealth or any other
jurisdiction.
8
The Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the children or claims to
have custody or visitation rights with respect to the children.
9
The best interest and permanent welfare of the child:en will be
served by granting the relief requested because of the following:
A. Shortly after the birth of the parties' youngest child, the
Mother went into a deep depression and became suicidal.
B. Since February 1996, the Mother has been on various
medications to deal with her depression and anxiety.
c. since April of 1996, the Mother has had a pattern of staying
out late after work and often not returning until the next day.
D. In February of ~his year, the Father quit his job while the
parties were living in Texas, so as to care for the children du~ to
Mother's inability to properly care for the children.
E. Mother has an ongoing relationship with her paramour, Danny
Meehan, and has allowed Mr. Meehan to drive a vehicle while under
the influence of alcohol with the children in the vehicle.
F. On September 2, 1996,' the Mother acted in a bizarre manner
while the family was on an excursion which included attempting to
jump out of the family vehicle on several different times while the
children were in the vehicle and consumed numerous prescription
drugs causing the Mother to act in an even more bizarre fashion,
all of which culminated in the Mother indicating that she was going
to move out of the family home in Texas.
G. On September 2, 1996, while the Mother was packing up her
belongings to leave the family residence, she continued to act in
a bizarre manner throwing items out of the house, running into a
glass storm door, all of which caused fear in the Father and in the
children. Father eventually summoned the police who appeared at
the family residence shortly after the Mother had left.
H. On September 3, 1996, Mother and Father met to discuss moving
to Shippensburg, Pennsylvania, which is where Mother's family
resides, so as to get family support for the parties during
Mother's period of difficulties. Mother indicated that she needed
time to think about whether she wanted to leave or not, but stated
that Father should leave and take the children with him.
I. On September 4, 1996, Father and the children departed Texas
for Shippensburg, Pennsylvania, but only after Father checked with
the school authorities and obtained the two older children's school
records for purposes of enrolling them in school here in
Pennsylvania.
J. On September 6, 1996, Father and the children arrive at
Mother's family home in Shippensburg, Pennsylvania, and on
September 8 the two older children were registered in school and
begin attending school in the Shippensburg School District.
K. From September 9, 1996, until the present, Mother has
indicated that she intends on moving from Texas to Pennsylvania;
however, her actions indicate otherwise, as follows:
1. She is now, it is believed, living with her
paramour, Danny Meehan;
2. She obtained new employment in T~xas; and
3. On or about October 17, 1996, Mother advised Father that
she was going to be filing for divorce.
L. During several telephone conversations with Mother since
Father has been in Pennsylvania, her speech has been slurred,
indicating that she is intoxicated on either drugs or alcohol.
4. Issues yet to be resolved: Custody.
5. The Plaintiff's position on custody is as follows: Plaintiff indicated that
he moved from Texas based upon an agreement that he had with his wife. When
he left, she was supposed to move with him but apparently decided against it.
Father allag'ls that Mother was exhibiting some strange behavior during the last
days that they lived in Texas. Further, he believes that he should be the primary
custodial parent given her abhorrent behavior and the fact that the children ara well
situated in Shippensburg, and that they have family near him.
6. The Defendant's position on custody is as follows: Mother's position is
that Father took the children away from Texas without her agreement. She wants
to have the children reside primarily with her. She indicated that she has been the
primary custodial parent throughout the children's lives and that there are no
problems that would prevent her from continuing in that role.
7. Need for separate counsel to represent children: Neither party requested.
8. Need for independent psychological evaluation or counseling: None
requested and the Conciliator does not believe any is necessary.
9. A hearing in this matter is expected to take one day.
10. Other matters or comments: Currently pending is the issue as to
whether or not this Court has jurisdiction. Obviously if the jurisdiction is decided
against the Plaintiff, then the Court will not have to hear the custody issues. If the
2
4. Issues yet to be resolved: Custody.
5. The Plaintiff's position on custody is as follows: Plaintiff indicated that
he moved from Texas based upon an agreement that he had with his wife. When
he left, she was supposed to move with him but apparentlv decided against it.
Father alleges that Mother was exhibiting some strange behavior during the last
days that they lived in Texas. Further, he believes that he should be the primary
custodial parent given her abhorrent behavior and the fact that the children are well
situated in Shippensburg, and that they have family near him.
6. The Defendant's position on custody is as follows: Mother's position is
that Father took the children away from Texas without her agreement. She wants
to have th9 children reside primarily with her. She indicated that she has been the
primary custodial parent throughout the children's lives and that there are no
problems that would prevent her from continuing in that role.
7. Need for separate counsel to represent children: Neither party requested.
8. Need for independent psychological evaluation or counseling: None
requested and the Conciliator does not believe any is necessary.
9. A hearing in this matter is expected to take one day.
10. Other matters or comments: Currently pending is the issue as to
whether or not this Court has jurisdiction. Obviously if the jurisdiction is decided
against the Plaintiff, then the Court will not have to hear the custody issues. If the
2
4. Issues yet to be resolved: Custody.
5. The Plaintiff's position on custody is as follows: Plaintiff indicated that
he moved from Texas based upon an agreement that he had with his wife. When
he left, she was supposed to move with him but apparently decided against it.
Father alleges that Mother was exhibiting some strange behavior during the last
days that they lived in Texas. Further, he believes that he should be the primary
custodial parent given her abhorrent behavior and the fact that the children are well
situated in Shippensburg, and that they have family near him.
6. The Defendant's position on custody is as follows: Mother's position is
that Father took the children away from Texas without her agreement. She wants
to have the children reside primarily with her. She indicated that she has been the
primary custodial parent throughout the children's lives and that there are no
problems that would prevent her from continuing in that role.
7. Need for separate counsel to represent children: N'lither party requested.
8. Need for independent psychological evaluation or counseling: None
requested and the Conciliator does not believe any is necessary.
9. A hearing in this matter is expected to teke one day.
10. Other matters or comments: Currently pending is the issue as to
whether or not this Court has jurisdiction. Obviously if the jurisdiction is decided
against the Plaintiff, then the Court will not have to hear the custody issues. If the
2
~ .-....-
.,~,"-
. .
4
On or about December 11, 1996, the Custody Conciliator issued a
report to the Court which contained a proposed Order scheduling a
hearing on custody.
5
The hearing previously scheduled for December 19, 1996, was
continued by agreement of the parties pending receipt by the Court
of an Agreement concerning custody.
6
No agreement has been reached between the parties concerning
custody.
7
No action was taken by the Court on the Custody Conciliator' s
report, presumably because of the pending jurisdictional issue.
WHEREFORE, the plaintiff requests this Honorable Court +:0 schedule
a hearing on Defendant's Petition requesting that this Court
decline jurisdiction and, in the interest of judicial economy,
schedule a hearing, as recommended by the conciliator, on
Plaintiff's Complaint for Custody on the same date and time as the
hearing on the issue of jurisdiction.
DCT 2 J 1996
},..;
MARK S. PIERUCCINI, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNS,YL'{ANIf',
("- 0' '->1
v 96- 5"8 ?lID CIVIL TlrnM C) I
-R;" ~ d;Il
C,.. "~
SELMA J. PIERUCCINI, CIVIL ACTION - LAW (;;, N,
De fendant tf,: (11 )
IN CUSTODY ~'(:. ~'~~
--, ., ,-",
~-:;.(. ~ ~-)I
ORDER OF COURT ;> . . _.
. I'-':r!
AND NOW, this c7J1i.... day of ~)t'.b}IL(1 ' 1996;' u;'n .....
consideration of the attached Pet~tion, ~t is hereby directed that
the parties and their respective counsel appear before
~~~,itujJ y. r0'if'1 E.:.r ' EsaqJ.re, the CO!,!cilj.ator, at
i ~::d I<i.;~ _<!5t.. /J<,"L.' ~ , on the ;)/.f7 day of
1'b1N' , 1996, at 10: (){) ~.M., 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.
By the Court,
151 7"'-'~/~/'t! ~ ,L~7;-? fJ.-:-
Custody Conc~liator ?
(f J/J./pPI
The Court of Common Pleas of Cumberland County is required by law
to comply with the Americans with Disabilities Act of 1990. For
information about accessible facilities and reasonaQle
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 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
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
717 - 240-6200
EXHIBIT
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1I0ME TESTING INSTlTlITE
Ilear 1\1,", I',eruccini Arrol 1997
('l1rnplctin).t ynur cnd\lSed April mini-survl':/s IS the ,
perfe..:1 way III prllvlde imporlant feedback 10 h'day's
manufaclurers, These manufacturers IIse your input to /
deslJ.:11 and Improve the products being offered in Y\ll1r
favorife stores.
Please lake a moment to complete and retnrn the enclosed
min,-surveys, To thank you for your help, when We receive
your completed surveys on lime. you'll be entered into our
Spring ()rawin~' You can read more ahollt Ollr Spring
Drawin~ along with other fun-filled facts in the
enclosed issue of flanel Talk. So, make your opinions
cllnnt--complele your surveys today!
HOME PHONE:
717-532-8247
1',5. Please confirm your name, address and phone II. and
make corrections below if necessary,
Tha n k You,
~
1917
MRS SELMA PIERUCCINI
PO 80X 590
SHIPPENSBURG PA 17257-
75-0
~
V1H4001-48
3480665
:241606434:22&00:
3480665 750 9704 489
,I
~
~
"
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Committing family violence.
Removing Stephanie, Shauna, Angela and Anthony Pieruccini from the possession of Applicant.
L.
Transferring, encumbering, or otherwise disposing of property mutually owned or leased by the
parties except when in the ordinary course of business,
Granting Applicant exclusive posscssion of thc children, Stephanie, Shauna, Angela and Anthony
Pieruccini, and specifYing the terms of Respondent's access to the children,
Directly communicating with the Applicant in a threatening or harassing manner,
Going to or near the rcsidence or place of employment or business of Applicant or from going near
the daycare or school where the children attend, Applicant request the Court to specifically prohibit
Respondent from going within 100 yards of the residence or any other residence or place of
employment or business Applicant may acquire.
These temporary ex parte protective orders shall be effective immediately and are binding on
Respondent and shall continue in full force and effect until a hearing is held on the Application for
Protective Order or until they expire by operation oflaw not more than 14 days from this date,
The requirement of a bond is hereby waived.
IT IS FURTHER ORDERED that the Clerk shall issue notice to Respondent, Mark
Pieruccini, to appear, and Respondent is hereby ORDERED to appear, before this Court in the
Courthouse at Orange, Texas, on the ..26 -cP day of ~J'~ . 1996, at /.'J ~
o'clock -/--,m, , to show cause why, during the pendency of this action, Respondent should not be
ordered as follows:
Prohibiting Respondent from committing family violence.
Prohibiting Respondent from removing Stephanie, Shauna, Angela and Anthony Pieruccini from the
possession of Applicant.
Prohibiting Respondent from transferring, encumbering, or otherwise disposing of property mutually
_ o~~_~ or !~a.sed by the parties except when in the ordinary course of business.
Granting Applicant exclusive possession of the children, Stephanie, Shauna, Angela and Anthony
Pieruccini, and specifYing the terms of Respondent's access to the children.
.
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IN THE MATTER OF .
SELMA PIERUCCINI .
AND .
MARK PIERUCCINI .
AND IN THE INTEREST OF .
STEPHANIE, SHAUNA, ANGELA, .
AND ANTHONY PIERUCCINI .
MINOR ClliLDREN .
IN THE
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APPLICATION FOR PROTECTIVE ORDER ~ Cfl
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1. Parties
This Application for Protective Order is brought by Selma Pieruccini, Applicant, who is a
resident of Orange County, Texas, Respondent is Mark Pieruccini, who works at Shooters Supply
(next to Academy), Beaumont, Jefferson County, Texas,
2. Relationship of Parties
Applicant and Respondent are spouses,
NQ suit for the dissolution of the marriage between Applicant and Respondent is pending.
The children h~rein for whom protective orders are sought are not subject to the continuing
jurisdiction of any court.
This application is brought on behalf of Selma Pieruccini by Charles Crawford, a licensed
prosecuting altomey in and for Orange County, Texas,
3, Grounds
Respondent has engaged in conduct that constitutes family violence, as follows:
On August 4, 1996, Respondent pushed Applicant into a dryer and threw Applicant onto the dryer.
___ ~es~~~de~~ ~so grabbed Applicant by th_e nec~ and t~ew her to the floor. Applicant has bruises and
soreness as a result of Respondent's actions. Respondent stated to Applicant that he intends to
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REAL ESTATE LEASE
This Lease Agreement (lhis "Leu..) is mad. effecliv. as of March 30. 1997, by and belween Telisa Michelle Chesson
('Landlord"), and Selma Pienll:cini ('Tenant.), The parties agree u follows:
PREMISES, Lan~lord, in cOlUideralion of the lease payments pro,ided in this Lease, leases to Tenant a three
bedroom house With one bath, (the "Premises") located al 408 Crepe Mynle, Orange, TX 77630,
TERM, The Ime term will begin on April I, 1997 and will terminate on March 30. 1998,
LEASE PAYMENTS, Tenant shall pay to Landlord a total annual lease paym.nt of 54,162,92. payable in advance, in
Installments of $346,91 per month on the fim day of each month, Leu. payments shall be mad. to the Landlord at
p, O. Box 80800 I, Pelalurna, CA 9497S-800 I, as may be changed from time to time by Landlord,
LATE PAYMENTS, Tenant shall pay a lale charge equal to $13,88 for each payment that is not paid within IS
day(s) after the due date for such Iste payment,
SECURITY DEPOSIT. At the time of the signing of this Lease, Tenant shall pay to Landlord, in trust. a security
deposit of 5300,00 to be held and disbursed for Tenant damages to the Premises (if any) u provided by law,
POSSESSION, Tenant shall be entitled to possession on the first day of the term of Ihis Lease, and shall yield
possession to Landlord on the last day of the term of this Lease, unless otherwise agreed by ,both parties in writing,
USE OF PREMISES/ABSENCES, Tenant shall occupy and use Ihe Premises.. a dwelling unit, Tenant shall notitY
Landlord of any anticipated extended absence from Ihe Premises not later than the first day of the extended absence,
MAINTENANCE, Tenant shall have Ihe responsibility to maintAin lhe Premises in good repair at all times,
ACCESS BY LANDLORD TO PREMISES, Subject to Tenant's consent (which shall not be unreasonably withheld),
Landlord shill bave the right to enter the Premi_ to make inspections. provide neceswy services. or show the unit
to prospective buyers. mortgagees, tenants or workers, As provided by law. in the cue of an c:mergency, Landlord
may enter the Premises without Tenant's consent.
UTILITIES AND SERVICES, Tenant shall be responsible tor all utilities snd services in connection with the
Premises,
PROPERTY INSURANCE. Landlord and Tenant shall each be responsible to maintain appropriate ilUurance for their
<aspeelive interests in the Premises and propeny located on lhe Premises
DEFAULTS, Tenant shall be in default of this Leue. if Tenant fails to fulfill any lease obligation or term by which
Tenant is bound, Subj""t to any governing provisions of law to the contrary, if Tenant fails to cure any financial
obligation within 30 day(s) (or any other obligation within 45 day(s)) after written notice of such default is provided
by Landlord to Tenant, Landlord may lake possession of the Premises without further notice, and without prejudicing
Landlord's rights 10 damages, In the a1temativ., Landlord may elect to cure any default and the cost of such action
shall be added to Tenant's financial obligations under this Lease Tenant .haIl pay all COSlS, damages. and expaMes
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Good Shepherd Preschool
Parent Handbook
1994-95
Welcome to the Good Shepherd Preschool! Much time, prayer, and
effort has been spent to open our preschool. We are delighted that you
have enrolled your child with us and believe our program will be a great
benefit to you and your children,
Mission Statement
The mission of the Good Shepherd Preschool is to provide a preschool
setting In which children can experience the love of Jesus and discover
their own God-given abilities and worth. We seek to help children bridge
the gap between home and a more formal educational routine by addressing
their spiritual, emotional, social, mental and physical needs in a
comprehensive, non-pressured, flexible atmosphere. This will be
accomplished though a variety of activities.
The nursery school Is a ministry of the Shippensburg Church of the
Brethren. A Nursery School Team is directly responsible to the Christian
Education Commission of the church, and maintains a liaison relationship
with the church board.
We are open to any child, regardless of race, creed or religion. Although
Bible stories, songs and verses will be included in our curriculum, and the
school will be staffed by Christian teachers, no attempt will be made to
prejudice a child against the faith of his parents.
'.
Goals
I. Develop positive self image
2. Expand human relationships and Interaction with others
3. Learn personal hygiene and physical fitness
4. Teach readiness skills in language arts, math and science
5. Develop knowledge of who God is and how He shows His love and care
...' . ~oI' . - -.,.,., _....,.
.
THE STA1'E OF TEXAS
TO: MARK STEVEN PIERUCCINI
,:<:. ,.\ JIJCEN STREET
'itl':!'t".-:N':'.iCUnG. PA
Respondant, NOTICE:
YOU HAVE BEEN SUED. ~'l', ma'l ~mpl"lj an ,,"toT'nell. If you <Jr 'Jour
. /:., '1" r, ,( 1'110 cl WI'lt.':;.' answer IUllh lttl~ r.lerk luho l!:)sued this (Lt-
-,r (d' t.., i.., Qu.\ 1'1 on thf: j~ICf.ddY next fCJ1IOlUlnt) the explT'atlun of tUJ~nt4
"" .', i,iO'Ofor lj.~I.j Ulf.re serYel1 r'fl'3 r.lt"ati~ln and petltlon. a default
II.JI t.'nt ~.,~y I ~ takG'n ag~lln~ f you
S,ll~ ANSWER may be ,:, ,",' at the Ih,trict Clerk's Offlce at tr,-,
': r, n q" LOU 11 t,~ '~l.J I' tho use, 8'.1 i D 1 v I S ion S t I' e e t ,or by moJ i I in g 1 t toP, 0
tj(. .t2J, OranrJ~' fexas, "t'76'JlJ
Sdld
ORIGINAL PETITION FOR DIVORCE
w." rJlpo <H.d 'Ju.:keted in th.' Honorable 128TH DISTRICT COURT of Orange
:"'''''y. fe,as de the Dlstrict Clerk's Office at the Orange County
('(urthou'.;e. 801 Division Street, Orange, Te,as on Friday March 14, 1997 ln
tIp rolluwing styled and numuered cause,
CAUSE NO. 97032B-D
IN THE MATTER OF THE MARRIAGE OF
SELMA ~ANE PIERUCCINI AND MARK STEVEN PIERUCCINI
The name and address of the attorney '01' petitioner otherwise the
ac,j~P5' of Petitioner is: DENNIS POWELL
1601 W. MAIN ORANGE,TX 77630
ISSUED AND GIVEN 'md,,,. my hand and seal o' said Court at Orange,
i ,:. ( a!. . r ~, 1 S M~J r. f II 14 I 19Q7.
'1 PI..ii~FP.
1 t:H18lt s
::::-----
;::::;.:=;::.;;:t:.::
STELLA WINTER. District Clerk
Oran~e count~
,~~=====~~~=~'~======;=f~~~~~~~
RETURN
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t~l'~ ..~'ec\Jr;'?'l '.P "_____,.__ t~ounty, T8:..:as. at__
'11 ~.he '___'._. J.lI~ of _______.____, 19_, h'~ delivl?rinl;.
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citatio'~ rogethel with the -3cCf)mpafftJlTl,]
first ef',;JI.'.,rsed thereon tllP date :Jf d~t 1--
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'ct:.:\.tJtelj I~ ,.. the de~en" .nt
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THE STATE OF TEXAS
rc MARK STEVEN PIERUCCINI
. t I : I ,. t r ~
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,~,. I)'};\ l. I t1 ':
NOTICE
~nl) HAVE BEEN SUED
"
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ORIGINAL PETITION FOR fJIVORGE
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':Al'SF Nil .o70:J2S-D
'N THE MATrEr. or THE MARRIAGE OF
?fLM"I JANE P1EPUCCINI AND MARK STEVEN PIERUCCINI
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~~I:'lDn~r 1. DENNIS POWELL
1601 W. MAIN ORANGE,TX
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STELI.A WINTER. llist" ict Clerk
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destroys the legitimate ends of the marriage relationship and
prevents any reasonable expectation of reconciliation.
6. Child of the Marriaoe.
Petitioner and Respondent are the parents of children born of
this marriage who are residents of Pennsylvania.
7. Division of Communitv Property.
Petitioner requests the Court to order a division of the
estate of Petitioner and Respondent in a manner that the Court
deems just and right, as provided by law.
8. statement Concernino Protective Order.
There is no protective order under Chapter 71 or Section 3.581
of the Texas Family Code in effect and no application for a
protective order is pending with regard to the parties to the suit.
9. statement Concernina Alternative Dispute Resolution
The attached Statement Concerning Alternative Dispute
Resolution which has been executed by SELMA JANE PIERUCCINI is
incorporated herein by reference.
PRAYER
pp.titioner prays that citation and notice issue as required by
law and that the Court grant a divorce and such other relief
requested in this petit~on.
Petitioner prays for general relief.